United States v. Leedy, 345 F. Supp. 3d 941

Jory Leedy was indicted on multiple counts of aggravated sexual abuse of a child; defense sought a document shown to the minors before their forensic interviews (apparently containing information about Leedy's prior convictions).
The Government delayed producing the specific document; on Nov 22, 2016 it emailed materials it believed satisfied the request; defense objected by email but did not copy the Court; the Court entered an order treating the production as complete and denied Leedy's motion to dismiss.
Defense later learned the actual document shown to minors had been in the Greene County JFS (GCJFS) file and that GCJFS caseworker Alina Whittaker shredded her handwritten notes and some paperwork on Dec 31, 2015 when she left employment.
An evidentiary hearing produced testimony from Whittaker, Hamilton County Detectives Todd and Minnich, and revealed (1) Whittaker had shown at least a sex-offender registry printout to the family and minors may have seen highlighted material, (2) Whittaker shredded handwritten notes per her understanding of GCJFS practice, and (3) federal involvement began around Dec. 29, 2015 with limited time to preserve GCJFS materials before shredding.
Leedy moved for reconsideration seeking dismissal for due-process violations and prosecutorial misconduct based on destruction of potentially exculpatory evidence; the Court found the destruction was newly discovered evidence but denied dismissal after applying Trombetta/Youngblood analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether destruction of GCJFS document violated due process	Govt failed to preserve a critical impeachment document; dismissal warranted	Document destruction irreparably prejudices defense and impaired fair trial	Denied — document at best "potentially useful" and no gov't bad faith shown (Youngblood)
Whether Trombetta (material exculpatory) or Youngblood (potentially useful) applies	Document was clearly exculpatory and material; Trombetta applies	Document was at best potentially useful impeachment evidence; Youngblood applies	Court: evidence not clearly materially exculpatory; Youngblood standard governs
Whether federal/prosecution acted in bad faith in preservation	Failure to obtain/preserve shows bad faith and prosecutorial misconduct	Federal involvement began Dec 29, 2015; no evidence of bad faith; GCJFS was not government agent	Denied — no evidence government acted in bad faith; preservation letters would have been impractical in the short window
Whether dismissal is warranted under supervisory power for prosecutorial misconduct	Prior or current misconduct warrants dismissal to protect fairness	No demonstrated longstanding prosecutorial misconduct or prejudice that cannot be cured by lesser remedies	Denied — dismissal is disfavored; no demonstrated longstanding misconduct or prejudice requiring dismissal

California v. Trombetta, 467 U.S. 479 (explains material-exculpatory-evidence standard and requirement for comparable evidence)
Arizona v. Youngblood, 488 U.S. 51 (holds bad-faith destruction of potentially useful evidence required for due-process violation)
Illinois v. Fisher, 540 U.S. 544 (clarifies distinction between material exculpatory and potentially useful evidence under Youngblood)
United States v. Collins, 799 F.3d 554 (6th Cir.) (discusses Trombetta/Youngblood framework and application)
United States v. Jobson, 102 F.3d 214 (6th Cir.) (articulates factors applied under Youngblood in Sixth Circuit)