The following excerpt is from U.S. v. Malone, 947 F.2d 951 (9th Cir. 1991):
The consequence of the government's destruction of potentially exculpatory evidence in its custody is controlled by California v. Trombetta, 467 U.S. 479 (1984) and Arizona v. Youngblood, 488 U.S. 51 (1988). Trombetta held that to warrant dismissal, the
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