What is the standard of review for destroying or destroying evidence?

If "no more can be said [of the evidence] than that it could have been subjected to tests, the results of which might have exonerated the defendant," a due process violation will be found only if law enforcement acted in bad faith. (Arizona v. Youngblood (1988) 488 U.S. 51, 57 (Youngblood); People v. Alvarez (2014) 229 Cal.App.4th 761, 773 ["[I]f the best that can be said of the evidence is that it was 'potentially useful,' the defendant must also establish bad faith on the part of the police or the prosecution."].)

Negligent destruction or failure to preserve potentially exculpatory evidence, without evidence of bad faith, will not give rise to a due process violation. (Youngblood, supra, 488 U.S. at p. 58.) A finding as to "whether evidence was destroyed in good faith or bad faith is essentially factual: therefore, the proper standard of review is substantial evidence." (People v.

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Memro (1995) 11 Cal.4th 786, 831.) On review, an appellate court must determine whether, viewing the evidence in the light most favorable to the trial court's finding, there was substantial evidence to support its ruling. (People v. Carter (2005) 36 Cal.4th 1215, 1246.)