Brown v. State

Summary

Case Description: Steven Cleveland was shot and killed in Wilmington in March 2005. On the night of the shooting, Steven and Dion Gibbs walked back to Steven's house after visiting some friends. When they turned the corner at Kirkwood Street, three men attacked Steven and Dion. One of the attackers held a gun to Dion's head and rummaged through his clothing, looking for valuables. The attacker demanded that Dion remove his clothes and ordered him to run away, leaving Steven behind. As Dion ran away, he heard gun shots. The attacker shot Steven four times. Steven died from massive internal bleeding.
The Wilmington Police (WPD) investigated the homicide. They eventually determined that Andrew Brown killed Steven. A Grand Jury indicted Brown on first degree murder and eight other related charges. However, the police could not find Brown.
The search for Brown continued for several months. Eventually a joint task force of Federal Marshals and the NYPD found and arrested 17 year-old Brown in Brooklyn, New York. After the officers arrested Brown, they contacted the WPD, and the chief investigating officer for the case, Detective Donna DiClemente, went to New York.
DiClemente and Detective Bower, also a Wilmington police officer, interrogated Brown at the police station in Brooklyn without any involvement from and outside the presence of NYPD officers. After the WPD interrogation, Brown made an incriminating statement to NYPD officers as they transported him from the interrogation to the central booking station in New York. Brown told NYPD officers:
She [DiClemente] stated that the reason I shot Steven Cleveland was because he wouldn't do what I wanted him to do. She doesn't know what she is talking about. That's not why I shot him. If you were there and looked at his body, you would have seen he was doing exactly what I wanted him to do, taking off his clothes, as you can see his pants were down to his knees when they found him. I shot him because he wasn't doing it fast enough.

Proceedings Description: Brown argues that the trial judge made two additional reversible errors at trial. Brown contends, first, that the trial judge improperly admitted two videotaped statements and second, that the trial judge should have ordered a mistrial after the State failed to release a transcript of an interview with one of the State's witnesses until after that witness testified.

Outcome: The Supreme Court of Delaware upheld the lower court’s ruling.

http://caselaw.findlaw.com/de-supreme-court/1072606.html