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People v. Eagen12/29/1994
of the defenses was that the accident was the result of mechanical failures in the car. In that situation, physical evidence of the car was crucial in that the vehicle had been driven over 100,000 miles, its brakes were worn to the rivets, and one of the tires had only fourteen pounds of pressure. Here, the only defense that the prosecution was aware of lay in the allegation that the deceased had grabbed the steering wheel. There was never any allegation of mechanical difficulties with the car.
We therefore remand this matter to the trial court for factual findings under the standards enunciated below.
The court should first determine whether the exculpatory value of the vehicle here satisfies the Trombetta standard. In doing so, the evidence must be evaluated in light of both the state trooper's testimony concerning the exculpatory value of the vehicle, and defendant's claim that the accident was caused by the deceased grabbing the steering wheel. If the exculpatory value of the evidence does not meet this standard, this case falls within the confines of Youngblood, and, because the trial court found no bad faith on the part of the state, there would have been no due process violation.
Accordingly, the judgment dismissing the charges is vacated, and the cause is remanded to the trial court for a new determination under the legal standards articulated in this opinion.
CHIEF JUDGE STERNBERG and JUDGE ROTHENBERG concur.
Disposition
JUDGMENT VACATED AND CAUSE REMANDED WITH DIRECTIONS
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