Jonathan Stevens, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The court affirmed Stevens’s convictions, holding that his unpreserved challenges to improper third-party comments in a recorded interrogation were not reviewable for plain error because defense counsel withdrew the objection, declined a curative instruction, and did not seek a mistrial or additional redactions. The court nevertheless reiterated that substantive third-party comments embedded in a witness’s statement are inadmissible under the statutory prior-statement rule and should be removed before the recording is presented to the jury.