Joel R. Stevenson, Defendant-Below, Appellant v. State of Delaware, Plaintiff-Below, Appellee

Summary

The Supreme Court of Delaware affirmed Stevenson’s convictions, holding that the trial court properly admitted the children’s videotaped prior consistent statements after the defense introduced an improper-influence theory through its opening statement, cross-examination, and closing argument. The statements were admissible under D.R.E. 801(d)(1)(B) because they rebutted that theory, and the court did not reach the alternative statutory basis for admission. Stevenson’s challenge to the videotapes’ redactions was waived because counsel affirmatively approved the redacted versions and, independently, failed to provide the necessary record for appellate review.