Supreme Court of Delaware

Watson v. State

August 13, 2024

Summary

The Supreme Court of Delaware affirmed Watson’s Assault Second Degree conviction, holding that the trial court’s isolated use of “victim” and its failure to give an unrequested character-evidence instruction did not constitute plain error. The court reasoned that Watson admitted striking Howard, making self-defense—not whether an assault occurred—the central dispute, and that the jury instructions as a whole adequately explained its fact-finding and reasonable-doubt duties. The court also distinguished cases in which judicial use of “victim” or omission of a character instruction more directly impaired the defense.