Patterson v. Delaware
Annotate this CaseIn a bench trial, a Delaware superior court found Appellant Tajiir Patterson guilty of invasion of privacy for filming a sexual encounter with D.L. and distributing the video over social media without her consent. The court sentenced Patterson to two years at Level V incarceration, suspended for twelve months at Level III probation. As part of the investigation, the Police extracted data, including over 9,000 photos, from D.L.’s cell phone. Patterson’s counsel was permitted to inspect these photos. The encounter occurred in late 2017, and nearly three years passed between the time of the recording and the trial. Because D.L.’s appearance had changed significantly during that time, the State sought to introduce “Photo 1” into evidence to show her appearance at the time of the recording. Patterson’s counsel objected because Photo 1 was not disclosed in discovery. The trial judge sustained the objection, ruling that photos not disclosed in discovery would be inadmissible, but photos contained within the cell phone extraction would be admissible. The State then sought to introduce “Photo 2” into evidence, which was of D.L. from 2017 and was included in the cell phone extraction. Patterson’s counsel objected. Photo 2 was admitted into evidence. Patterson seeks reversal of his conviction, contending that the State violated its discovery obligations by not flagging the importance of the 2017 photos of D.L. and by not providing a copy of all the photos in D.L.’s phone. Patterson argued the trial court abused its discretion by allowing Photo 2 into the record given the State’s alleged discovery violation. Finding the State did not violate its discovery obligation, the Delaware Supreme Court concluded the trial court did not abuse its discretion in admitting Photo 2 into evidence.
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