Jones v. State
534, 2015
| Del. | Dec 5, 2016Background
- On Oct. 4, 2010, a fire at 101 Clinton Street in Delaware City killed Teyonna Watts and her two children; Travis Jones (Watts’s boyfriend) was present and later made statements implicating himself.
- Evidence included Jones’s statements to a doctor, friends, and a jailhouse informant describing admitting responsibility and actions (e.g., disabling a smoke alarm); an ATF agent concluded the fire was incendiary though the ignition source was not identified.
- Defense presented arson expert Robert Paul Bieber, who relied on NFPA 921 illustrations and discussed flashover/full-room involvement to argue the fire’s origin could not be determined; State’s expert Paul Gemmato disagreed about flashover and located origin on the kitchen’s north wall.
- Jones was indicted for three counts of first-degree murder and one count of first-degree arson; jury convicted him of three counts of manslaughter (lesser-included) and acquitted on the arson count.
- On appeal Jones argued four prosecutorial comments in closing/rebuttal amounted to misconduct requiring reversal; the State filed a cross-appeal challenging trial rulings but failed initially to obtain timely personal authorization under 10 Del. C. § 9902(e).
Issues
| Issue | Jones’s Argument | State’s Argument | Held |
|---|---|---|---|
| Prosecutor’s NFPA slide remark (calling defense slides “wrong”) | Remark mischaracterized Bieber’s slides and attacked credibility unfairly | Comment was minor, judge sustained objection and instructed accuracy; not prejudicial | Not reversible; comment did not amount to prejudicial misconduct |
| Mischaracterization of Carmen study (said investigators went to scenes vs. lab exercise) | Prosecutor knowingly misstated study to discredit expert | Prosecutor misspoke during long trial and promptly corrected when objected to | Not reversible; treated as an inadvertent mistake corrected at trial |
| Soliciting jury sympathy for victims ("Is it fair to Teyonna…") | Urged juror sympathy for victims, improper and prejudicial | Claimed argument was about judging credibility; court ordered curative instruction | Prosecutorial misconduct but cured by immediate curative instruction; no reversal |
| "Walking through the fire" rebuttal (Speakman testimony) | Misstated or sandbagged defense—Speakman didn’t walk through the kitchen as claimed | Argued inference from Speakman’s testimony supported rebuttal to flashover theory | Held to be fair argument from evidence and permissible rebuttal |
| State cross-appeal authorization under 10 Del. C. § 9902(e) | (N/A for Jones) | State contended appeals of trial rulings merited review; later obtained authorization after filing | Cross-appeal procedurally defective because personal authorization was not given before filing; dismissed |
Key Cases Cited
- Baker v. State, 906 A.2d 139 (Del. 2006) (harmless-error framework for preserved prosecutorial-misconduct claims)
- Hughes v. State, 437 A.2d 559 (Del. 1981) (three-factor test for assessing prejudice: closeness, centrality, mitigation)
- Hunter v. State, 815 A.2d 730 (Del. 2002) (repetitive prosecutorial errors and integrity of process review)
- Dyson v. United States, 418 A.2d 127 (D.C. 1980) (quoted in Hughes regarding prejudice factors)