State v. Hawkinson
2013 Minn. LEXIS 222
| Minn. | 2013Background
- Hawkinson was charged with misdemeanor DWI after a blood test showed BAC 0.11.
- Hawkinson demanded preservation of all evidence, including blood tests, but the State did not forward the request to the BCA.
- BCA later informed Hawkinson that the blood sample would be destroyed twelve months after the April 2010 report; the sample was destroyed.
- Hawkinson moved to suppress the blood-test results on due process grounds; the district court suppressed them and the court of appeals affirmed the suppression on due-process grounds.
- The State appealed, challenging the district court’s suppression and raising Confrontation Clause and discovery-procedure arguments.
- The Supreme Court of Minnesota reversed, holding the blood sample was not protected under Brady and that destruction did not occur in bad faith; cross-examination of the physical evidence is not required; destruction did not violate discovery rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Destruction of blood sample after preservation request violated due process? | Hawkinson | State | No due-process violation; evidence was only potentially useful |
| Confrontation Clause right to cross-examine against physical evidence? | Hawkinson relied on Crawford/Bullcoming to extend to physical evidence | Confrontation rights apply to witnesses, not the physical sample | Not required; cross-examination does not extend to physical evidence |
| Did destruction violate Minnesota Rules of Criminal Procedure? | State failed discovery/preservation duties | Rules complied and test results disclosed | No violation; discovery requirements satisfied in misdemeanor context |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (due process requires disclosure of favorable evidence when material)
- California v. Trombetta, 467 U.S. 252 (U.S. 1984) (destruction of evidence must involve apparent exculpatory value)
- Arizona v. Youngblood, 488 U.S. 51 (U.S. 1988) (bad-faith standard for destruction of potentially useful evidence)
- Illinois v. Fisher, 540 U.S. 479 (U.S. 2004) (preservation requests do not automatically negate bad-faith requirement)
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (confrontation rights for testimonial evidence)
- Bullcoming v. New Mexico, 131 S. Ct. 2705 (U.S. 2011) (cross-examination of forensic analyst's testimony)
- State v. Nissalke, 801 N.W.2d 82 (Minn. 2011) (bad-faith analysis in destruction of evidence)
- State v. Jenkins, 782 N.W.2d 211 (Minn. 2010) (standard procedures and destruction evidence)
- State v. Bailey, 677 N.W.2d 380 (Minn. 2004) (Youngblood-trombetta framework in Minnesota)