Valentin v. State
2013 Del. LEXIS 432
| Del. | 2013Background
- Valentin was charged with multiple offenses after a police pursuit of his vehicle near a wildlife area.
- Valentin requested discovery including statements or information relating to credibility of prosecution witnesses and Jencks-like materials.
- The State did not disclose a dispatch recording of officer communications, which allegedly would show no siren during the pursuit.
- The trial court ruled the discovery request did not cover the dispatch recording and that it was not a 26.2 statement.
- Valentin’s counsel brought the missing recording to the court’s attention during trial, prompting post-trial appeals.
- The court held the dispatch recording fell within Rule 16, found the failure to disclose prejudicial, and reversed for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the dispatch recording fall within discovery under Rule 16? | Valentin | State | Yes; within discovery scope and material to defense |
| Did the State's failure to produce the dispatch recording prejudice Valentin? | Valentin | State | Yes; prejudicial to substantial rights; new trial required |
Key Cases Cited
- Johnson v. State, 550 A.2d 903 (Del. 1988) (full responses to discovery not contingent on exact wording)
- Hopkins v. State, 893 A.2d 922 (Del. 2006) (discovery obligations and failure to disclose shifting review)
- Fuller v. State, 922 A.2d 415 (Del. 2007) (mitigation of disclosure violations in certain contexts)
- Taylor v. State, 982 A.2d 279 (Del. 2008) (undisclosed material and prejudice analysis guidance)
- Oliver v. State, 60 A.3d 1093 (Del. 2013) (scope of discovery and prejudice considerations in Del. law)
- Secrest v. State, 679 A.2d 58 (Del. 1996) (court's approach to discovery issues and remedy)