Idaho v. Sarbacher
Annotate this CaseThe State charged Keith Sarbacher with grand theft by receiving or possessing stolen property: a 2001 Dodge pickup truck. After Sarbacher’s arrest, the State inventoried and photographed the truck and then returned it to the insurance company, who then sold the truck before Sarbacher’s attorneys could examine it. Sarbacher moved the district court for dismissal, arguing that the State violated his constitutional right to due process by disposing of evidence that was material and potentially exculpatory. The district court granted Sarbacher’s motion and dismissed the State’s case. The State appealed, arguing the evidence at issue was of unknown exculpatory value and the trial court expressly found that the State had not acted in bad faith. The Idaho Supreme Court concluded after a review of the district court record, it would have been entirely speculative for the district court to conclude that any of the additional analyses Sarbacher wanted to conduct would have resulted in the discovery of any exculpatory evidence to exonerate him. "the evidentiary value of the truck as the corpus delicti of the crime was sufficiently preserved by the State through its inventorying and photographing the vehicle prior to its release to Hunt’s insurance company." The Court vacated the district court's decision and remanded for further proceedings.
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