Coleman v. State

Summary

The Supreme Court of Delaware affirmed Coleman’s conviction for possession of a firearm by a person prohibited. It held that the Lolly/Deberry missing-evidence framework applies to physical evidence that the State failed to collect or preserve, not to an officer’s failure to document the location of physical evidence that was collected, preserved, and introduced at trial. The court also concluded that the omitted location information was not sufficiently exculpatory to support the requested instruction.