Raniford v. State, 199, 2016

Two separate January 2013 incidents led to separate trials and convictions of Yanique Rainford: a high‑speed car chase (Jan. 16) and a controlled heroin sale (Jan. 31).
After the car chase, police located a Bravada registered to Rainford’s girlfriend; fingerprints, clothing and pay stubs tied Rainford to the vehicle. He was later tried and convicted for disregarding an officer’s signal, resisting arrest, and aggressive driving.
On Jan. 31 detectives conducted a controlled buy: an undercover officer arranged for Rainford to deliver heroin to a hotel. Police arrested Rainford and found 49 bags of heroin, cash, two cell phones (numbers matching earlier investigation), and other drug evidence; a companion, Franklin Hanna, also had heroin and later gave a videotaped statement.
At the drug trial, the State introduced Hanna’s videotaped post‑Miranda statement after Hanna testified he could not recall or verify the statement’s voluntariness or accuracy.
Rainford was convicted at trial of drug dealing, second‑degree conspiracy, possession of marijuana, and possession of paraphernalia; the Superior Court imposed concurrent sentences for both incidents. Rainford appealed, raising three issues.

Issue	Rainford's Argument	State's Argument	Held
Admissibility of Hanna’s videotaped statement (voluntariness)	Hanna’s statement was involuntary and should not be admitted	Statement was voluntary: Miranda warnings given, brief interview, judge reviewed circumstances under §3507	Court affirmed admission: judge properly found statement voluntary and §3507 requirements met
Sufficiency of evidence for conspiracy (2d degree)	Evidence insufficient to show Rainford intended to promote/facilitate a felony conspiracy	Evidence (Hanna’s videotaped admission that he “assumed” Rainford would sell drugs, prior sale, Hanna drove him to hotel) supported inference of agreement and overt act	Court held evidence sufficient for a rational juror to find conspiracy beyond a reasonable doubt
Prosecutor’s opening remarks re: drug complaints and passerby description	Opening improperly referenced out‑of‑court statements and suggested drug activity; argued for mistrial	Prosecutor had good‑faith basis (detective testimony anticipated; exceptions to hearsay for present sense impression/excited utterance); remarks were background and not highly prejudicial	No plain error; trial court did not abuse discretion in denying mistrial

Turner v. State, 5 A.3d 612 (Del. 2010) (standard of review for admission of out‑of‑court statements)
Woodlin v. State, 3 A.3d 1084 (Del. 2010) (trial judge must assess voluntariness before admitting prior statements)
Maddrey v. State, 975 A.2d 772 (Del. 2009) (standard of review for sufficiency of the evidence)
Baker v. State, 906 A.2d 139 (Del. 2006) (plain error standard for unpreserved claims)
Wainwright v. State, 504 A.2d 1096 (Del. 1986) (definition and scope of plain error)
Urquhart v. State, 133 A.3d 981 (Del. 2016) (uninvolved bystander’s description held admissible as present sense impression/excited utterance)