Patterson v. State

Summary

The Delaware Supreme Court affirmed Tajiir Patterson’s conviction for invasion of privacy. The Court held that the State did not violate Superior Court Criminal Rule 16 by making a cell-phone extraction available for inspection without identifying the significance of particular photographs, and that the Superior Court properly admitted a photograph from the extraction.

Holdings

1. The State complied with Rule 16 because it provided Patterson access to inspect and copy or photograph the relevant cell-phone extraction, and Rule 16 did not require the State to review the discovery for the defense, explain its litigation strategy, or provide a curated summary of relevant photographs.
2. The Superior Court did not abuse its discretion by admitting Photo 2 because the State did not violate Rule 16.

Questions Presented

1. Whether the State violated Superior Court Criminal Rule 16 by making a large cell-phone extraction available for inspection without identifying the photographs it considered significant or intended to use at trial.
2. Whether the Superior Court abused its discretion by admitting Photo 2, which was contained in the disclosed cell-phone extraction.

Disposition

affirmed