Adams v. Delaware

In October, 2014, a Superior Court jury convicted Irvan Adams of possession of a firearm by a person prohibited, possession of ammunition by a person prohibited, carrying a concealed deadly weapon, and conspiracy second degree. The Superior Court judge sentenced Adams to five years at Level V on the conviction for possession of a firearm by a person prohibited, and suspended the terms of imprisonment on the remaining offenses for probation. On appeal. Adams argued the Superior Court abused its discretion when it refused to admit into evidence a prior consistent statement of Adams's brother, Javan Cale. Adams claimed the affidavit supported Cale's exculpatory testimony at trial and rebutted the State's implication of recent fabrication on Cale's part. The trial judge refused to admit the affidavit, ruling it was superfluous. The Supreme Court found that the trial court erred when it sustained the State's objection and excluded the affidavit from evidence, and that the exclusion was not harmless error beyond a reasonable doubt. The Court therefore reversed Adams's conviction and remanded for further proceedings. View "Adams v. Delaware" on Justia Law