In a case of interest to Illinois DUI lawyers, the founder of the International Polo Club raised 13 issues before Florida’s Fourth District Court of Appeal regarding his DUI manslaughter conviction. The appeals court affirmed, addressing only three of the issues raised by Goodman: (1) whether the State prematurely released his vehicle after his first trial in violation of his due process rights and requiring dismissal under California v. Trombetta; (2) that the jury instructions on the failure to render aid enhancements violated due process by failing to require that he knew that the accident resulted in injuries or death; and (3) that his blood was drawn without a warrant, violating the Fourth Amendment Search and Seizure Clause. Following a late-night car accident, in which the other driver died after his vehicle was submerged in a canal, the defendant was charged with DUI manslaughter with failure to render aid and vehicular homicide with failure to render aid. He was convicted and sentenced following his first trial. After juror misconduct came to light, the first conviction was vacated, and he was granted a new trial. In the second trial, he was again found guilty.
Regarding the defendant’s first challenge on appeal, the court agreed with the state and held that the court did not err in denying the motion to dismiss due to the loss of the car. Pursuant to Trombetta, the constitutional duty of the state to preserve evidence must be limited to evidence that might be expected to play a significant role in the suspect’s defense. To meet this standard of constitutional materiality, evidence must both possess an exculpatory value that was apparent before the evidence was destroyed and be of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means.
The appeals court agreed with the trial court that the state did not act in bad faith in releasing the car. Therefore, it had to determine whether the car constituted materially exculpatory or only potentially useful evidence. The trial court held a full hearing on the issue of the exculpatory nature of the car and concluded that it was merely potentially exculpatory. It reasoned that the defendant’s expert, by his own testimony, had already formed an opinion of the malfunction and that his opinion on the state of the car at the time of the crash was complete. The “mere possibility of helping the defense” by conducting more testing on the car, which was already subjected to extensive testing by three experts, did not rise to the level of constitutional materiality.