State of Delaware v. Brittany Anderson, 1611018151

Defendant Brittany A. Anderson was charged with DUI, failure to remain in a single lane, and possession of marijuana following an arrest on November 28, 2016. Trial was scheduled for May 4, 2017.
The Court ordered the State to produce all discovery by March 1, 2017; the State provided no discovery by that date and instead produced materials by email on May 1, 2017 and an MVR copy on May 3, 2017.
On May 4, 2017, Defendant moved to dismiss or, alternatively, to exclude all evidence produced after the discovery deadline. The Court denied dismissal and declined to exclude all untimely evidence but excluded blood-draw and blood-chemical-analysis evidence. Trial was continued for other reasons.
Defendant filed a motion for reargument arguing the denial to exclude all untimely evidence was manifestly unjust and would fail to deter repeated State discovery violations.
The State acknowledged the late disclosure but characterized it as negligent (not willful) and argued exclusion of all evidence was unnecessary because the defense then had possession and time to prepare.
The Court denied reargument: it applied Civil Rule 59(e) standards, held sanctions are case-specific, found the chosen sanction (excluding blood-related evidence) appropriate, and concluded Defendant failed to show newly discovered evidence, legal error, or manifest injustice.

Issue	State's Argument	Defendant's Argument	Held
Whether the Court should exclude all evidence produced after the discovery deadline	Exclusion of all evidence is too severe; late disclosure was negligent and defense ultimately received materials before trial	All untimely evidence must be excluded to remedy prejudice and deter recurring discovery violations	Denied; exclusion of blood evidence only was an appropriate, case-specific sanction
Whether the Court should dismiss the case for discovery violation	Dismissal is unwarranted absent willful/egregious misconduct and substantial prejudice	Dismissal or full exclusion necessary to enforce scheduling orders and preserve case-review integrity	Denied; dismissal not warranted
Whether a motion for reargument under CCP rules is appropriate here	No new evidence, change in law, or misapprehension of facts; Civil Rule 59(e) governs reargument	Argues manifest injustice based on inconsistency with other cases and need for deterrence	Denied; movant did not meet Rule 59(e) standards (no manifest injustice, new law, or overlooked controlling precedent)
Whether broader deterrence of State misconduct justifies harsher sanction	Sanctions under Rule 16 are remedial for the particular defendant, not to punish hypotheticals	Court should impose stronger sanctions to deter future State violations	Rejected; sanctions are individualized and not designed primarily to deter future hypothetical misconduct

Oliver v. State, 60 A.3d 1093 (Del. 2013) (discusses balance between public interest and defendant's fair-trial rights)
Cabrera v. State, 840 A.2d 1256 (Del. 2004) (principles on balancing societal needs and defendant rights in scheduling and trial management)
Washington v. State, 844 A.2d 293 (Del. 2004) (trial court discretion to manage docket and scheduling orders)
In re Hillis, 858 A.2d 325 (Del. 2004) (purpose and importance of case review process to conserve trial resources)