State v. Woelke, 2017 Ohio 4034

Defendant Mark D. Woelke was tried on consolidated burglary and grand-theft indictments after a co-defendant (Jennifer Godsey) cooperated and identified locations and stolen items during a January 2016 ride-along and a recorded interview.
Detective Reinbolt took handwritten notes during the ride-along (allegedly five addresses), later incorporated those notes into a formal investigative report, and destroyed the original handwritten notes.
Defense requested all statements and investigative notes in discovery; the State produced the formal report and the recorded interview but not the original handwritten notes, asserting they were work product and had been destroyed after incorporation.
At trial the recorded interview was played and both Godsey and Detective Reinbolt testified; Godsey’s testimony at trial largely matched the recorded interview and the investigative report.
Woelke moved to compel the notes and for acquittal on due-process grounds for nondisclosure/destruction of exculpatory evidence; the trial court denied relief, and the jury convicted Woelke on multiple burglary and grand-theft counts.
On appeal Woelke argued the destroyed handwritten notes were materially exculpatory (or at least potentially useful) and that their nondisclosure violated due process.

Issue	State's Argument	Woelke's Argument	Held
Whether Detective Reinbolt’s destroyed handwritten ride-along notes were materially exculpatory evidence whose nondisclosure violated due process	Notes merely listed addresses; their contents were incorporated into and available in the formal report and the recorded interview; not exculpatory	Notes could show inconsistencies or impeachment material not reflected in the report or recording and thus were exculpatory or at least potentially useful	Notes were not materially exculpatory; the record showed comparable evidence was available (report, recording, trial testimony); no showing of bad faith by the State; no due-process violation; motions denied and convictions affirmed

California v. Trombetta, 467 U.S. 479 (1984) (establishes standard for materially exculpatory evidence and requirement for preservation)
U.S. v. Bagley, 473 U.S. 667 (1985) (standard for disclosure of evidence favorable to accused and materiality test)
State v. Johnston, 39 Ohio St.3d 48 (1988) (discusses remedy when prosecution suppresses materially exculpatory evidence)
State v. Powell, 132 Ohio St.3d 233 (2012) (distinguishes materially exculpatory evidence from potentially useful evidence and addresses bad-faith requirement)
State v. Geeslin, 116 Ohio St.3d 252 (2007) (requires bad faith to prevail where only potentially useful evidence was lost)