Garland v. Commonwealth
Annotate this CaseAfter a jury trial, Appellant was convicted of three counts of murder and sentenced to death. After Appellant’s convictions were affirmed, he filed a motion to obtain DNA testing and analysis of certain evidentiary items. The circuit court denied the motion. The Supreme Court reversed and remanded the matter for an evidentiary hearing. At the hearing, the court was informed that two of the items of evidence had been subjected to DNA testing but that one item was not subjected to DNA testing because police officers had discarded the evidence immediately following Appellant’s trial. Appellant moved for a new trial on the grounds that the officers had acted in bad faith in destroying the evidence, thus violating his due process rights. The trial court denied the motion. The Supreme Court affirmed, holding (1) Appellant previously abandoned his request to have the evidence tested by DNA analysis and therefore waived any complaint he may have had about their unavailability for DNA testing; and (2) Appellant failed to establish that the officers acted in bad faith when they destroyed the evidence.
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