Steven Baynum, Defendant Below-Appellant v. State of Delaware, Plaintiff Below-Appellee

Summary

The Supreme Court of Delaware affirmed Baynum’s convictions and held that the State had no duty to record or preserve an alleged inconsistent statement made by the victim during an unrecorded period when she was alone in an interview room. The court also held that, even assuming a breach, a missing-evidence instruction was unwarranted because there was little or no negligence or bad faith, reliable substitute evidence remained available, and the trial evidence was sufficient to sustain the convictions.