Irvan Adams, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The Supreme Court of Delaware held that the Superior Court improperly excluded a witness's prior consistent affidavit offered to rebut an express or implied charge that the witness recently fabricated his trial testimony to help the defendant. Although the affidavit repeated evidence already presented, it was admissible for the distinct purpose of rebutting the alleged improper motive, and its exclusion was not harmless beyond a reasonable doubt because the State emphasized the witness's supposed fabrication and the case depended heavily on credibility determinations. The judgment was reversed and the case was remanded for further proceedings.