Supreme Court of Delaware

Johnson v. State

July 14, 2025

Summary

The Court affirmed Johnson’s convictions, holding that the trial court did not plainly err by failing to give a sua sponte limiting instruction concerning a detective’s narration of surveillance footage. The detective provided factual descriptions and context rather than lay-opinion identification testimony, and the jury was instructed that it alone determined the facts and witness credibility. Even assuming an instruction was required, any error did not affect the verdict because the evidence was substantial and the claimed prejudice was speculative.