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Valentin v. State

Supreme Court of Delaware

August 26, 2013

KLINE VALENTIN, Defendant Below, Appellant,
v.
STATE OF DELAWARE, Plaintiff Below, Appellee

Submitted: June 12, 2013

Upon appeal from the Superior Court of the State of Delaware in and for Sussex County Cr. ID No. 1202002945

Tasha Marie Stevens, Fuqua, Yori and Willard, P.A., Georgetown, Delaware for appellant.

Abby Adams, Department of Justice, Georgetown, Delaware for appellee.

Before STEELE, Chief Justice, JACOBS and RIDGELY, Justices.

STEELE, Chief Justice

This appeal addresses the State's obligation to produce relevant material in response to a defendant's discovery request. A Superior Court jury convicted the defendant of Failing to Stop at the Command of a Police Officer, Reckless Driving, and several other offenses. The State failed to produce a recording of the officers' communications with the dispatcher in response to the defendant's discovery request. This recording contained evidence that the officers' siren had not been activated, contrary to the officers' testimony. We conclude that the dispatch recording fell within the scope of the defendant's discovery request and Superior Court Criminal Rule 16. The failure to produce this evidence prejudiced the defendant because the siren's presence was material to the State's case and impeached the credibility of its key witnesses. Accordingly, we REVERSE the Superior Court's judgment regarding the appealed convictions and REMAND for a new trial.

I. FACTUAL AND PROCEDURAL BACKGROUND

A. Kline Valentin's Arrest

Shortly before midnight on February 3, 2012, Sergeant Nicholas Couch and Corporal Gavin Davis of the Delaware Department of Natural Resources (DNREC) were patrolling the Horsey Pond Wildlife Area in a pickup truck. The officers' truck was unmarked, but it had colored lights on its grill and along its visor that would flash when activated. Couch testified that he observed a car in the back of the wildlife area's parking lot with its lights turned off. Because the wildlife area is closed from sunset to sunrise, [1] the officers approached the vehicle to investigate. Couch claimed that he activated the truck's emergency lights and called a police dispatcher to report the planned vehicle stop. As Davis started to get out of the truck, the car's driver started his car and left the parking lot. Couch told the dispatcher that the officers planned to pursue the car.

By the time the officers had turned the truck around, the car had left the parking lot, traveled down a nearby road, and was turning onto Delaware Route 24. The officers testified that the driver failed to stop at a stop sign and did not use the car's turn signal (perhaps understandable for a person in flight). Couch and Davis pursued the car into a nearby residential development but lost sight of it. Upon rediscovering the car, the officers attempted to block its escape, but the driver evaded them by driving into some grass. Once the officers regrouped, they again trapped the car by blocking an intersection. Davis claimed he yelled "Police, Stop!" in the car's direction. This time the driver complied. The officers later identified the car's driver as Defendant–Appellant Kline Valentin. Couch testified that Valentin exceeded the speed limit while fleeing and that Couch activated the truck's siren as soon as the officers began their pursuit. According to Davis's police report, Valentin thought that the officers were "park police" and that they would not pursue him once he left the wildlife area's parking lot.

B. Valentin's Discovery Request

As part of her trial preparation, Valentin's attorney requested discovery from the State. The discovery request contained two paragraphs relevant to this case. Those paragraphs sought:

19. Disclosure of statements, interviews, reports or other information relating to the credibility of any prosecution witness, including but not limited to ...

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