State of Delaware, Defendant-Below, Appellant v. Jacquez Robinson, Plaintiff-Below, Appellee.

Summary

The court held that the State violated Robinson's Sixth Amendment right to counsel by intentionally searching, seizing, and reviewing privileged defense materials containing trial strategy. Although the violation caused actual prejudice, the court held that dismissal of the indictment was not sufficiently tailored because the record did not establish irreparable taint, prejudice, or a sufficiently proven pattern of misconduct. The court therefore reversed the dismissal and remanded with sanctions requiring disqualification of exposed personnel and destruction of existing trial work product.