Adkins v. State, 580, 2016

Defendant Tyrone Adkins was convicted by a Superior Court jury of three counts of drug dealing based on three undercover heroin purchases documented in the first of two related trials.
Police packaged the drugs in labeled envelopes, sealed and stored them; NMS Labs received evidence in two sealed boxes but discovery showed inventory sheets had been swapped between boxes.
NMS employees corrected the inventory-sheet mix-up, noted it in their file, and testified police had completed some NMS custody forms improperly.
Adkins argued at trial that careless handling (not tampering) of evidence undermined chain of custody and requested a specific instruction on that theory.
The trial court refused Adkins’s proposed chain-of-custody instruction, instead giving a standard instruction that referenced tampering and required proof beyond a reasonable doubt that the admitted drugs were those seized from Adkins.
After the jury reported a deadlock following ~50 minutes, the court gave an Allen charge that mentioned the time, resources, and expense of retrying the case; the jury then convicted Adkins on all counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency/wording of chain-of-custody instruction	Instruction should permit acquittal based on careless handling; offered instruction without references to "tampering."	Given instruction improperly emphasized tampering and thus foreclosed careless-handling theory.	Court affirmed: given instruction accurately stated law, did not restrict jury from finding reasonable doubt due to carelessness, and required proof the trial evidence were the defendant's drugs.
Allen charge content (coercion/due process)	Allen charge was coercive by mentioning retrial costs and implying the State would retry, violating due process.	Court has previously approved similar Allen charges; language about resources/retrial not coercive here.	Court affirmed: declined to overrule prior precedent; charge not coercive in violation of due process.

Flamer v. State, 490 A.2d 104 (Del. 1984) (standards for reviewing jury instructions and considering the instruction as a whole)
Burrell v. State, 953 A.2d 957 (Del. 2008) (jury-instruction review principles)
Newnam v. Swetland, 338 A.2d 560 (Del. 1975) (jury must be able to intelligently perform duty returning a verdict)
Storey v. Castner, 314 A.2d 187 (Del. 1973) (quoted in Newnam regarding jury’s duty and instructions)