Williams v. DelawareAnnotate this Case
In this direct appeal, the issue before the Delaware Supreme Court implicated the constitutional boundaries of a trial court’s discretion to limit the scope of a criminal defendant’s cross-examination of the witnesses against him. Wayne Williams was indicted on two counts of Drug Dealing plus aggravating factors, one count of Tampering with Physical Evidence, one count of Resisting Arrest, and two counts of Possession of Drug Paraphernalia. The principal question presented on appeal was the extent to which Williams should have been permitted at trial to cross-examine witnesses concerning misconduct at the Office of the Chief Medical Examiner (“OCME”) and elicit testimony that presented an alternative explanation for the weight discrepancy involving the drug evidence in his case. The Court concluded there was no unconstitutional restriction of Williams’ confrontation rights and that the Superior Court imposed reasonable limits when exercising its discretion to limit the scope of cross-examination. In view of the overwhelming evidence unrelated to the misconduct at the OCME, the Court held that, even if the trial court had erred, the error would have been harmless beyond a reasonable doubt. Accordingly, but for the Tampering with Physical Evidence conviction which the State conceded had to be reversed, the Supreme Court affirmed Williams’ convictions.