Supreme Court of Delaware

Swanson v. State

December 31, 2025

Summary

The Court affirmed Swanson’s conviction because he failed to file a required pretrial motion to suppress evidence or otherwise object to its admission. It held that Superior Court Criminal Rule 12 waives an untimely suppression claim absent cause, and that plain-error review is unavailable when the failure to move to suppress prevented development of the evidentiary record. The Court declined to reach the merits of Swanson’s Fourth Amendment challenge.