Jean-Baptiste v. State

Summary

The Delaware Supreme Court affirmed Jean-Baptiste's first-degree murder conviction and statutorily mandated life sentence. Reviewing the denial of his motion for judgment of acquittal de novo, it held that the jailhouse-informant testimony about his admission that he drove the shooter's rental car, if credited and considered with corroborating rental-car, motive, and surveillance evidence, would permit a rational jury to find guilt beyond a reasonable doubt, and it declined to adopt a per se rule presuming jailhouse-informant testimony unreliable because the U.S. Supreme Court precedent he invoked established no such presumption. It also held that the trial court did not plainly err in responding to spectators wearing T-shirts depicting the victim by ordering the shirts removed rather than declaring a mistrial or conducting voir dire, because defense counsel proposed that remedy and the defendant failed to show prejudice to substantial rights.