Summary
The Supreme Court of Delaware affirmed Glenn E. MacDonald's first-degree murder conviction. The court rejected claims concerning mistrial requests, impeachment with prior statements, references to pre-arrest counsel and a prior trial, admission of evidence under Delaware Rule of Evidence 404(b), and limits on cross-examination regarding the victim's time of death.
Topics
Practice areas
Questions Presented
- Whether the prosecutor's cross-examination concerning MacDonald's failure to tell his trial exculpatory story during earlier pre-arrest statements violated Doyle v. Ohio or otherwise required a mistrial.
- Whether the prosecutor's reference to MacDonald's pre-arrest representation by counsel required the trial court to declare a mistrial sua sponte.
- Whether cryptic references to MacDonald's prior trial required a mistrial or constituted plain error.
- Whether testimony concerning MacDonald's conduct toward Spencer and other women, his alleged threats, and his license plate constituted inadmissible character evidence or unfairly prejudicial evidence.
- Whether the trial court improperly limited cross-examination of a detective concerning a notation about the time Spencer's body could have been on the beach.
Holdings
- The State did not violate Doyle v. Ohio by cross-examining MacDonald about his prior inconsistent pre-arrest statements, including his failure to implicate Smith after voluntarily speaking with police following Miranda warnings. The denial of a mistrial was not an abuse of discretion.
- The prosecutor's reference to MacDonald's representation during a pre-arrest police interview did not require a sua sponte mistrial and was not plain error, particularly because the trial court promptly instructed the jury not to infer guilt from the hiring of counsel.
- The cryptic references to MacDonald's prior trial did not require a mistrial and did not constitute plain error. MacDonald waived objection to the references and, in any event, the jury could only speculate about the outcome of the earlier trial.
- The Superior Court did not abuse its discretion by admitting evidence concerning MacDonald's conduct toward Spencer and other women, his threats, his obsessive behavior, and related evidence. Some evidence was properly admitted under Delaware Rule of Evidence 404(b), and other evidence was relevant to establish MacDonald's attitude toward Spencer and was not substantially outweighed by unfair prejudice.
- The trial court did not abuse its discretion by limiting cross-examination of Detective Alstadt concerning a notation about the possible time Spencer's body had been on the beach.
Key quotations
“The State was not using MacDonald's post-Miranda silence for impeachment purposes. Rather, the State properly impeached MacDonald's credibility using his pre-arrest prior inconsistent statements, voluntarily given in spite of his Miranda rights.” (754)
“We find no error in the various evidentiary rulings of the Superior Court and accordingly AFFIRM the judgment of conviction.” (757)
Factual background
Glenn E. MacDonald had a stormy relationship with Julie Spencer, who began dating another man after the relationship ended. Spencer planned to visit MacDonald's home to retrieve a videotape before disappearing; her body was later found in a marshy area. MacDonald gave several pre-arrest statements to police, including statements after learning that Spencer's body had been found, but denied knowledge of her whereabouts. At trial, he testified that he had been an unwitting accomplice to Allan Smith, whom he identified as the actual murderer.
Procedural history
MacDonald was indicted in October 1990 for first-degree murder. His first trial in March 1992 ended with a deadlocked jury; at a second trial in February 1993, he was convicted and sentenced to life imprisonment without probation or parole. After the Delaware Supreme Court reversed the denial of postconviction relief based on the involuntary waiver of his direct appeal, MacDonald pursued this appeal challenging the denial of mistrials and several evidentiary rulings.