Washington v. State, 94, 2016

Anthony Washington was convicted after a three-day Superior Court jury trial of multiple offenses including aggravated possession, Tier 4 drug dealing, possession of a firearm during a felony, possession of drug paraphernalia, and second-degree conspiracy (Oct. 2015).
On appeal Washington challenged two pretrial evidentiary rulings by the Superior Court: (1) the court’s grant of the State’s Motion for Extension to produce a controlled-substances lab report, and (2) the denial of his Motion in Limine to exclude DNA evidence under D.R.E. 403.
The lab report was produced on September 21 after the State missed deadlines and sought an extension; Washington did not object at the time or in later motions.
The lab report confirmed field-test results that the seized items were drugs; Washington did not contest that the substances were drugs at trial.
The DNA evidence showed a profile consistent with Washington and indicated that only one in eleven African Americans would match that profile; it did not conclusively identify Washington but tended to support the State’s theory he was one of several handlers of the firearms.
The Superior Court allowed the late production after granting an extension and admitted the DNA evidence, finding its probative value not substantially outweighed by prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Superior Court abused its discretion by granting the State’s Motion for Extension to produce the lab report	Washington: extension and late production prejudiced his defense; exclusion required	State: extension was permissible; report merely confirmed field tests and caused no prejudice	Waived for review under Supreme Court Rule 8 (no timely objection); alternatively, no abuse of discretion and no prejudicial effect
Whether the Superior Court abused its discretion by denying Washington’s Rule 403 motion to exclude DNA evidence	Washington: DNA evidence was confusing, misleading, and unfairly prejudicial relative to its probative value	State: DNA probative to show Washington as one of several handlers; any confusion mitigable by cross-examination	No abuse of discretion—probative value outweighed prejudice; evidence admissible

Wainwright v. State, 504 A.2d 1096 (Del. 1986) (only issues fairly presented to the trial court may be raised on appeal)
Coleman v. PricewaterhouseCoopers, LLC, 902 A.2d 1102 (Del. 2006) (appellate review of discretionary trial-court discovery rulings)
Hopkins v. State, 893 A.2d 922 (Del. 2006) (reversal for discovery error requires showing substantial rights were prejudicially affected)