Milligan v. State

Summary

The Delaware Supreme Court affirmed April Milligan’s convictions for driving under the influence and improper lane change. The court held that admitting chain-of-custody documents without live testimony from every person who possessed the blood sample did not violate the Sixth Amendment Confrontation Clause. The court also held that the trial court did not abuse its discretion in admitting the blood-test results, because alleged chain-of-custody inconsistencies affected the evidence’s weight rather than its admissibility.

Holdings

1. The Sixth Amendment Confrontation Clause does not require every individual who possessed or handled physical evidence to provide live testimony when the evidence is offered solely to establish chain of custody. Delaware's chain-of-custody statute therefore was not unconstitutional as applied here.
2. The Superior Court did not abuse its discretion by admitting the blood-test results because the State established a reasonable probability that the sample was not misidentified or adulterated and provided a sufficient foundation for the test results.

Questions Presented

1. Whether admission of chain-of-custody documentation without live testimony from every person who possessed the blood sample violated the Sixth Amendment Confrontation Clause.
2. Whether the Superior Court abused its discretion by admitting Milligan's blood-test results despite alleged chain-of-custody and foundational deficiencies, including an unsigned possession log, an allegedly inconsistent report signature, the analyst's incomplete recollection, an incorrect autosampler date, and uncertainty about who prepared control samples.

Disposition

affirmed