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Ricketts v. State

Citations: 488 A.2d 856; 1985 Del. LEXIS 425

Court: Supreme Court of Delaware; January 29, 1985; Delaware; State Supreme Court

Narrative Opinion Summary

An appeal was made regarding the conviction of Darrell Ricketts for first degree rape of a five-year-old girl. The primary issue was whether the trial court erred in allowing the six-year-old victim to testify due to concerns about her competency as a witness. The court found that the trial court acted within its discretion under Delaware Rules of Evidence 601 and 603, determining that the child was competent to testify. During a voir dire examination, the child demonstrated an understanding of truth and lies, affirming her intent to testify truthfully. The court concluded that this understanding was sufficient to establish her competency under the applicable rules. The decision of the lower court was therefore affirmed, noting that the guidelines for determining the competency of a child witness established in Kelluem v. State are no longer necessary, as all witnesses are generally considered competent under the current rules.

Legal Issues Addressed

Abolition of Previous Guidelines for Child Witness Competency

Application: The court affirmed that previous guidelines for assessing child witness competency, such as those from Kelluem v. State, are obsolete under the current evidence rules.

Reasoning: The decision of the lower court was therefore affirmed, noting that the guidelines for determining the competency of a child witness established in Kelluem v. State are no longer necessary, as all witnesses are generally considered competent under the current rules.

Competency of Child Witnesses under Delaware Rules of Evidence 601 and 603

Application: The court applied Delaware Rules of Evidence 601 and 603 to determine the competency of a six-year-old witness, concluding that the child's understanding of truth and lies was adequate for her to testify.

Reasoning: The court found that the trial court acted within its discretion under Delaware Rules of Evidence 601 and 603, determining that the child was competent to testify.

Discretion of Trial Court in Determining Witness Competency

Application: The trial court's decision to allow the child to testify was upheld, as the court exercised appropriate discretion based on the child's demonstrated understanding during voir dire.

Reasoning: During a voir dire examination, the child demonstrated an understanding of truth and lies, affirming her intent to testify truthfully.