The State appealed an order dismissing an accusation against Daniel Cain for driving under the influence after a patrol-car camera recording of his field sobriety tests, arrest, and implied-consent advisement was lost. The trial court found that the State had acted in bad faith by failing to preserve potentially relevant evidence. The Georgia Court of Appeals reversed. Due process does not require police to preserve every item that might conceivably help the defense. When lost evidence is not known to have been exculpatory, the defendant must show that its exculpatory value was apparent before destruction and that police acted in bad faith. The record showed a system malfunction, an unsuccessful attempt to download the recording, and the eventual expiration of the camera’s storage period. It did not show that the video had apparent exculpatory value or that officers intended to withhold constitutionally material evidence. The court held that the lost recording and speculation about its contents did not justify dismissal of the DUI accusation.