Schaffer v. State

CourtSupreme Court of Delaware
DecidedApril 10, 2018
Docket238, 2017
StatusPublished

This text of Schaffer v. State (Schaffer v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schaffer v. State, (Del. 2018).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

ZACHARY SCHAFFER, § § No. 238, 2017 Respondent Below, § Appellant, § Court Below: Family Court § of the State of Delaware v. § § No. 1605005875 STATE OF DELAWARE, § § Petitioner Below, § Appellee. §

Submitted: January 24, 2017 Decided: April 10, 2018

Before STRINE, Chief Justice; SEITZ and TRAYNOR, Justices.

ORDER

This 10th day of April, 2018, having considered the briefs, the record below,

and the argument of counsel, it appears to the Court that:

(1) In April 2016, a sixteen-year-old high school student died after being

attacked by another student in a school bathroom. She died not of blunt force

trauma from the attack, but from a rare, undiagnosed heart condition that was

aggravated by the emotional and physical stress of the attack. Schaffer,1 the

appellant here, was not the perpetrator, but she was charged in Family Court with

conspiring with the perpetrator and a third student to assault the victim. After a

1 Schaffer is a pseudonym, assigned because she was tried in Family Court as a juvenile. See Del. Sup. Ct. R. 7(d). The names of all other juveniles in this order are also pseudonyms. bench trial, the Family Court adjudicated Schaffer delinquent of conspiracy in the

third degree.

(2) Schaffer challenges her delinquency adjudication on three grounds.

First, she contends that the State violated her due process rights under the United

States and Delaware constitutions by failing to recover an iPad that the school had

issued to the victim, which Schaffer believes may have contained information

favorable to her defense. Second, she contends that the trial judge erred by

allowing the State to introduce two Snapchat videos that the State attributed to her

without adequate authentication. Third, she contends that the evidence as a whole

was insufficient to support the Family Court’s finding that she was delinquent of

conspiracy in the third degree.

(3) We recently examined these events in connection with the charges

against the student who perpetrated the attack, Tracy Cannon.2 We focus here on

Schaffer’s role.

(4) The day before the fatal attack, the victim, Alcee Johnson-Franklin,

left class to meet Schaffer and Cannon in one of the school bathrooms. A feud had

been brewing on social media between Cannon and Johnson-Franklin, and a

faculty member who was near the bathroom reported hearing “a lot of screaming

2 See Cannon v. State, ___ A.3d ___, 2018 WL 1097023 (Del. Mar. 1, 2018). 2 and a lot of verbal talk.”3 At trial, the State offered—and the court admitted—a

short video of the confrontation, which Schaffer had allegedly recorded and posted

on Snapchat. The video had a caption, which read, “[Cannon] bouta fight her.” The

State also offered a second video that Schaffer allegedly posted, which consisted of

her, Cannon, and a third student walking down a hallway, during which could be

heard, “We gonna get her. She’s scared.”

(5) That night, Johnson-Franklin talked with a friend about the incident

by both text message and a video call. The next morning, Schaffer, Cannon, and

the third student from the video were all seen together in the school cafeteria prior

to class. At trial, another student testified that, as she was on her way to school that

morning, she received a call from that third student from the video, who asked her

if she had arrived at school yet, and if she knew where to find Johnson-Franklin.

(6) When Johnson-Franklin arrived at school, she passed by Schaffer,

Cannon, and the third student before walking into the same bathroom as the day

before. The three girls followed her. After an exchange of words between her and

Cannon, Cannon attacked her. A video taken by another student captured the

attack, which lasted only about a minute. Cannon “pulled [her] to the ground,

threw a quick succession of awkward punches, pulled her by her hair, and then

3 App. to Opening Br. A-6. 3 jumped on top of her. By the end, the two of them were on the floor, grappling and

kicking at each other until other students pulled them apart.”4

(7) Soon after, Johnson-Franklin went into cardiac arrest, and less than

two hours later, she was pronounced dead. Her autopsy revealed that she had

suffered from a rare heart condition, which she had not known that she had. “The

cause of her death was found to be ‘sudden cardiac death due to [a] large atrial

septal defect and pulmonary hypertension,’ with the emotional and physical stress

from the assault acting as a ‘contributing’ cause.”5

(8) The State filed delinquency petitions against Cannon, Schaffer, and

the third student. All three were charged with conspiracy in the third degree, and

Cannon—the perpetrator of the attack—was further charged with criminally

negligent homicide. The Family Court adjudicated Schaffer and Cannon delinquent

of conspiracy and further adjudicated Cannon delinquent of criminally negligent

homicide. The third student was found not delinquent.

(9) During the investigation into Johnson-Franklin’s death, investigators

learned that the school had issued iPads to all of its students. But while they were

able to locate the iPads of Cannon, Schaffer, and the third student, they were

unable to locate Johnson-Franklin’s. According to one of the detectives who

investigated her death, they would have “love[d] to have [it],” but they never

4 Cannon, 2018 WL 1097023, at *7. 5 Id. at *3. 4 recovered it.6 They asked Johnson-Franklin’s family if they knew where to find it,

but they did not. A detective on the investigation team asked the school whether

they had the capability to remotely track the location of the school-issued iPads,

but the detective who testified at trial did not know what came of that discussion.

The detective did mention, based on his knowledge of the tracking technology—in

this case, Apple’s “Find My iPhone” feature—that it would work only if the iPad’s

battery was charged and the device was powered on. A faculty member who

testified at trial confirmed that the school did have that ability to remotely track the

students’ iPads, but she too did not know whether any attempts had been made to

use that technology to locate the missing iPad. She also suggested that the school

may have had some ability to remotely monitor how the students were using their

iPads, but said that they could not “necessarily go into their iPad.”7

(10) At trial, Schaffer argued that the State’s failure to locate and turn over

the iPad violated her rights under Brady v. Maryland,8 which requires the State to

turn over evidence favorable to the accused that is within the State’s possession or

control, and our decisions in Deberry v. State9 and Lolly v. State,10 which, as a

matter of the due process guarantee of the Delaware Constitution, require the State

6 App. to Answering Br. B-79. 7 App. B-105. 8 373 U.S. 83 (1963). 9 457 A.2d 744 (Del. 1983). 10 611 A.2d 956 (Del. 1992). 5 to “gather [and] preserve” such evidence.11 Schaffer speculated that the iPad may

have contained evidence—in the form of text or video conversations—showing

that Johnson-Franklin was just as willing to fight Cannon as Cannon was to fight

her, which, Schaffer reasons, would disprove that she and Cannon had conspired to

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