Must State Show that Destroyed Evidence Would Not Have Supported Defendant's Claim of Innocence?

State of Ohio v. Michael Lupardus, Case no. 2008-2487

4th District Court of Appeals (Washington County)

ISSUE: When evidence in a criminal case is destroyed by an agent of the state after the defendant has entered a general discovery request, does the state assume the burden of proving that the missing evidence was not "materially exculpatory" (would not have supported the defendant's claim of innocence)?