Kline Valentin, Below v. State of Delaware, Below

Summary

The court held that the State violated its discovery obligations by failing to produce a police-dispatch recording that fell within the defendant's discovery request and was material to the defense. Because the recording could have impeached the officers' testimony about whether the siren was activated, the nondisclosure prejudicially affected the defendant's substantial rights. The court reversed the convictions for failing to stop at a police command and reckless driving and remanded for a new trial.