Supreme Court of Delaware

Hudson v. State

January 9, 2024

Summary

The Supreme Court of Delaware affirmed Hudson’s convictions and sentence, holding that the State’s STRmix-based DNA expert testimony satisfied the reliability requirements of Delaware Rule of Evidence 702 and that the trial court acted within its discretion in denying a separate Daubert hearing. The Court also held that the cell-tower-dump warrants were sufficiently particular and supported by probable cause under the Fourth Amendment. The Court declined to decide whether obtaining the tower-dump CSLI required a warrant and did not reach Hudson’s separate state constitutional claim because it was inadequately presented.