People v. Jagotka

Markman, P.J.

(concurring in part and dissenting in part). Although I generally subscribe to the interpretation of MCL 780.655; MSA 28.1259(5) (hereafter § 5), accorded by the majority, and specifically agree that suppression is not a necessary sanction where *357the statute has been breached, I respectfully dissent from its determination that the statute has been breached in the instant case. I would therefore affirm the circuit court order reversing the district court order suppressing the blood alcohol test results.

The operative language of § 5 provides that “[t]he property and things so seized shall be safely kept by the officer so long as necessary for the purpose of being produced or used as evidence on any trial.” In my judgment, there are considerations relevant both to blood samples generally as well as to the blood samples in this case specifically, that lead me to the conclusion that the preservation of such samples was not “necessary for the purpose of being produced or used as evidence on any trial.” By finding to the contrary, I believe that the majority would considerably alter traditional police practices pertaining to the preservation of blood samples.1

First, and most importantly, the chronology of this case indicates that the defendant had a reasonable period within which to request further testing of the blood samples before their destruction. The test results were available by March 15, 1995, and the samples were not destroyed until May 16, 1995. At least two weeks before the destruction of the samples, the defendant appears to have been presented both the results of their testing and their destruction schedule. Despite this, he did not request further testing or preservation of the samples until after they had been destroyed. I agree with the majority that a *358defendant is under no affirmative obligation to object to the destruction of evidence under § 5, and I further believe that a defendant’s mere awareness of an otherwise unreasonable destruction schedule does not suffice to excuse police noncompliance with § 5. However, in my judgment, the destruction schedule in this case was reasonable, altogether routine and well-established, administered in good faith, and communicated to the defendant in a manner sufficient to enable his timely and convenient objection. Thus, the defendant’s failure to object to the destruction of the sample gives rise, I believe, to a strong inference concerning its lack of exculpatory potential. Indeed, I cannot think of a clearer statement by a defendant himself that a sample is not “necessary” for use at trial than the fact of his nonobjection to its destruction.2 Is it possible to conceive that a defendant who truly believed that the preservation of evidence could lead to his exoneration would fail to ensure such preservation? Is it possible that such a defendant would tolerate the destruction of evidence “necessary” at his trial in exchange for the adverse inference *359instruction prescribed by the majority?3 Where a defendant has effectively acquiesced in the destruction of evidence, I do not believe that an inference adverse to the prosecutor ought to arise from such destruction.

Second, underscoring the inference — drawn from a defendant’s nonobjection to the destruction of evidence after having been apprised of its imminent destruction — that such evidence is not potentially exculpatory is the simple fact that blood samples themselves are rarely “produced or used as evidence” at trial. Rather, what typically constitutes evidence are the test results relating to samples. For example, in Michigan’s implied consent statute, MCL 257.625a(8); MSA 9.2325(1)(8), relating to trials for operating a motor vehicle while under the influence of intoxicating liquor (ouil), it is the “test results” themselves that are the evidence that must be preserved for trial, not the blood, breath, or urine samples that are the basis of the testing.4 See also People v Stoney, 157 Mich App 721, 725; 403 NW2d 212 (1987); People v Tebo, 133 Mich App 307, 309-310; 349 NW2d 172 (1984); People v Stark, 73 Mich App 332, 337-338; 251 NW2d 574 (1977); California v Trombetta, 467 US 479, 487-488; 104 S Ct 2528; 81 L *360Ed 2d 413 (1984). The blood samples are rarely produced, and therefore rarely “necessary,” at trial. In focusing upon things seized “for the purpose of being produced or used as evidence,” we must take into consideration that it is the test results, rather than the samples, that ordinarily constitute the “evidence” in a drunk driving trial.

Third, in light of the high level of accuracy and integrity of blood alcohol tests, it is extraordinarily unlikely that additional testing on the unpreserved blood samples in this case would have produced results contrary to those of the police laboratory and, therefore, have been exculpatory for the defendant. See id. at 489-490 (observing that, in light of the accuracy of Breathalyzer tests, the chances were “extremely low” that unpreserved breath samples would have been exculpatory). Unlike areas of analysis in which experts might reasonably disagree about the meaning or significance of evidence, blood alcohol tests are scientifically routine and impose virtually no interpretative burden upon those assessing the results, making it highly improbable that the defendant’s access to the sample itself would have made a difference at trial. Indeed, the very fact that the destruction of blood samples is a routine procedure among most police departments illustrates the virtual absence of controversy regarding the accuracy of the scientific testing of blood alcohol content. Thus, in comparison to other forms of unpreserved evidence, the burden of demonstrating prejudice relative to an *361unpreserved blood sample will normally be a much greater one.* ***5

Fourth, even absent unpreserved blood samples, a defendant still possesses a reasonable means of impeaching the alcohol content test results where there is actual concern about the accuracy of the results. At trial, he retains the opportunity to raise questions regarding the accuracy and procedures of the particular test results at issue (e.g., equipment condition, margins of error, compliance with testing norms and practices, and human error) without resort to the blood sample itself.6 6 See Stoney, supra at 727; Trombetta, supra at 491.

Finally, with respect to the majority’s analysis, I note that no evidence has been offered here by either party concerning the extent to which blood samples deteriorate or degrade over time and, at some point, cannot effectively be tested for alcohol content. Even under the majority’s analysis, I do not believe that § 5 — requiring the retention of evidence “so long as *362necessary for the purpose of being produced or used as evidence on any trial” — requires the preservation of samples beyond their effective testing life. Additionally, even under the majority’s analysis, I do not believe that an adverse inference instruction need be given where either the trial court itself has approved the destruction of evidence or the testing procedure itself has necessarily resulted in its destruction.

I respectfully dissent and would affirm the order of the circuit court.

Indeed, I am also concerned about the implications of this decision for the police department’s obligations to retain evidence in other contexts where it is not currently common practice, such as the preservation of large amounts of drugs seized pursuant to a search warrant.

This is especially true in view of the fact that the defendant did not have the benefit of the instant decision when he chose to allow destruction of the samples. While, as a result of this decision, future defendants may be able more credibly to argue that their acquiescence in the destruction of blood samples should not generate an inference that the samples were viewed as unnecessary at trial, here the majority concedes that “[t]he parties have not cited, and our research has not revealed, a case where the police violated § 5 by failing to preserve seized items for trial in the context of a criminal case.” Ante at 351, 353. Given this legal uncertainty confronting defendant at the time he made his decision to allow the destruction of evidence to proceed, it can hardly be surmised that he considered such evidence to be “necessary” in any way for his defense. That this decision itself was an altogether reasonable one, see the discussion that follows.

While I agree with the majority that such an adverse inference instruction may generally be appropriate where there is destruction of evidence under § 5, including under some circumstances the destruction of blood samples, such an instruction does not seem appropriate where defendant’s own conduct has demonstrated the inaccuracy and impropriety of such an inference.

Although I recognize that the implied consent law is not dispositive with respect to blood samples drawn pursuant to a search warrant, it does nevertheless offer insight regarding what the Legislature considered to be relevant “evidence” in connection with the investigation and trial of ouil criminal charges.

Indeed, defendant himself has not claimed that he was harmed or prejudiced in any specific way by police procedures in this case. He does not specifically claim that access to the blood sample would have allowed him to offer exculpatory evidence, explain or mitigate the original test results, or in any other way provide himself with a stronger defense.