Bryan v. State

Summary

The Delaware Supreme Court affirmed Andre Bryan’s convictions for second-degree rape and related felony sexual offenses. The Court held that the trial court’s requirement that Bryan testify entirely through a Spanish interpreter was not plain error because the issue was unpreserved and no material prejudice was shown. The Court also held that the Superior Court did not abuse its discretion in denying severance of charges involving two complainants because the evidence was sufficiently cross-admissible under the Getz framework.

Holdings

1. The trial court's interpreter ruling did not constitute plain error warranting relief because Bryan failed to identify binding authority establishing a right to alternate between English and interpreter-mediated testimony and failed to show clear prejudice to his substantial rights.
2. The Superior Court did not commit reversible error by ruling from the bench before trial and later issuing a written memorandum opinion because it stated the essential bases for its decision at the hearing, and Bryan identified no concrete prejudice caused by the later written explanation.
3. The Superior Court acted within its discretion in denying severance because the evidence concerning the two alleged episodes was cross-admissible under Delaware Rule of Evidence 404(b), and Bryan failed to show unfair prejudice.

Questions Presented

1. Whether the Superior Court plainly erred by requiring Bryan to testify exclusively through a Spanish interpreter after he elected to use an interpreter.
2. Whether the Superior Court inadequately explained its denial of Bryan's motion to sever by ruling from the bench before issuing a later written memorandum opinion.
3. Whether the Superior Court abused its discretion by denying severance of the charges involving the two complainants where the evidence was cross-admissible under Delaware Rule of Evidence 404(b).

Disposition

affirmed