Campbell v. State, 474, 2016

Shaquille Campbell was convicted by a jury of Attempted Murder in the First Degree, two counts of Possession of a Deadly Weapon During the Commission of a Felony, Reckless Endangering in the First Degree, and Possession of a Firearm by a Person Prohibited; some related counts were later nol-prossed by the State.
Key eyewitnesses were Waynetta Wilson and the victim, Brian Bey; both identified Campbell and gave statements to police and trial testimony; surveillance footage of the incident existed and was shown at trial.
A police officer witness (Det. Ricardo Flores) was asked multiple times whether Wilson’s and Bey’s statements and trial testimony were consistent with the surveillance footage; Campbell objected only once on relevancy grounds.
At the close of the State’s case, defense counsel indicated Campbell did not intend to testify; after lunch, Campbell confirmed he would remain silent and the defense later moved for judgment of acquittal on certain counts; the Superior Court deferred ruling and sent the charges to the jury.
Campbell appealed on two principal grounds: (1) that the State’s repeated questions to the officer impermissibly vouched for eyewitnesses, and (2) that deferring the Rule 29(a) motion deprived him of a proper ruling before he had to elect whether to testify.

Issue	Plaintiff's Argument (Campbell)	Defendant's Argument (State)	Held
Whether repeated questions asking a police officer if eyewitness statements/testimony matched surveillance footage constituted improper vouching requiring reversal	Repeated questions by the State impermissibly vouched for Wilson and Bey, bolstering their credibility	Questions were innocuous and any improper form of vouching was not preserved by contemporaneous objection; no prejudice shown given the evidence	No plain error; affirm — officer’s answers were inartful/irrelevant but not prejudicial and overwhelming evidence supported conviction
Whether the Superior Court erred by deferring a Rule 29(a) motion at close of State’s case, allegedly forcing Campbell to decide whether to testify without a ruling	Deferring the motion violated Rule 29(a) and impermissibly burdened Campbell’s choice to testify	The record shows Campbell had already decided not to testify; the court reasonably treated the defense as resting and deferral raised no prejudice; any technical error not preserved	No plain error; affirm — deferral did not prejudice Campbell and record contradicts claim that his choice was affected

Wainwright v. State, 504 A.2d 1096 (Del. 1986) (sets plain error standard for appellate review)
Weedon v. State, 647 A.2d 1078 (Del. 1994) (objections must specify grounds at trial or the issue is waived on appeal)