Commonwealth v. Snyder, et al. J-56ABCD-2008
Topic: Suppression of Results from Destroyed Evidence
Summary: Where the prosecution has destroyed evidence before the defense has the opportunity to test and/or examine the evidence, suppression may only be granted if the evidence is exculpatory and the prosecutor acted in bad faith. Therefore, to merit suppression, the defendant must show that the evidence is “materially exculpatory,” not merely “potentially useful” and show that the prosecutor acted in bad faith in destroying the evidence. The Pennsylvania Supreme Court also reaffirmed the proposition that a defendant has no right to an independent chemical evaluation of evidence.
http://www.pacourts.us/OpPosting/Supreme/out/J-56abcd-2008mo.pdf