Supreme Court of Delaware

Tyrell Oliver, Below v. State of Delaware, Below

February 4, 20132013 Del. LEXIS 52

Summary

The Supreme Court of Delaware held that the State violated its discovery obligations by failing to disclose technical laboratory reports underlying its forensic chemist's conclusions. Although the trial court properly recognized the violation, its overnight continuance was insufficient to mitigate the substantial prejudice caused by the late disclosure. The judgment was reversed and the case remanded for further proceedings.