Stickel v. State

Summary

The Supreme Court of Delaware affirmed Frederick Stickel's convictions for two counts each of second-degree vehicular homicide and driving under the influence of alcohol. The court held that the trial judge properly admitted toxicology reports showing that the two deceased motorcyclists had not consumed drugs or alcohol because Stickel had placed their potentially dangerous driving behavior at issue.

Holdings

1. Because Stickel placed the decedents' driving behavior in issue by asserting that they were speeding, drag racing, or otherwise driving dangerously, evidence that they had not consumed drugs or alcohol was relevant and admissible.
2. The trial judge did not abuse his discretion in admitting the toxicology reports.

Questions Presented

1. Whether the Superior Court abused its discretion by admitting toxicology reports showing that the decedents had not consumed drugs or alcohol.
2. Whether the toxicology reports were relevant to the issue of whether the decedents' conduct caused the accident.

Disposition

affirmed