Strickland v. State, 328 A.3d 286

Rakiim Strickland was captured on Dover Housing Authority surveillance video in possession of an assault weapon and discharging it toward another individual; he was a convicted felon prohibited from firearm possession.
Strickland was charged and convicted for possession of a firearm and ammunition by a person prohibited (PFBPP and PFABPP), but not for crimes related to the discharge of the weapon.
At trial, the prosecution introduced surveillance videos and testimony from Detective Barrows, as well as introduced the criminal convictions of the defense's only witness, Taron Walker.
The defense did not object to the admission of the surveillance video or request a limiting instruction; however, Strickland later argued on appeal that a limiting instruction should have been given sua sponte.
The defense did object to the admission of two out of three of Walker’s prior felony firearm-related convictions under D.R.E. 609, claiming they were unduly prejudicial.
The Superior Court admitted the evidence, and Strickland was sentenced to 60 years, suspended after 35, and appealed both evidentiary rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to give limiting instruction on video evidence	Jury could misuse video of shooting as evidence of bad character/uncharged crimes; a limiting instruction was required sua sponte	Video evidence directly proved the charged offenses (possessory crimes), so no 404(b) or instruction required	No error; evidence was intrinsic to the charged offense and no instruction was mandated
Admission of two additional prior convictions for defense witness	Court based its balancing test on an erroneous finding of a defense concession; failure to properly balance prejudice vs. probative value	Court did the proper D.R.E. 609 balancing; any error was harmless due to evidence and credibility issues	No abuse of discretion; any error was harmless given the overall evidence against Strickland

Getz v. State, 538 A.2d 726 (Del. 1988) (explains the genesis and application of D.R.E. 404(b) on character evidence)
Dougherty v. State, 21 A.3d 1 (Del. 2011) (plain error review standard applies to unobjected-to jury instruction flaws)
Weber v. State, 547 A.2d 948 (Del. 1988) (discusses the requirement for limiting instructions when prior crimes evidence is introduced under D.R.E. 404(b))
Hines v. State, 248 A.3d 92 (Del. 2021) (adequacy of Rule 609 balancing test explained)
Morris v. State, 795 A.2d 653 (Del. 2002) (abuse of discretion standard for evidentiary rulings)