Allen v. State

In Allen v. State, 644 A.2d 982, 988 (Del. 1994), the Court held that evidence of an act that occurred twelve years prior to the charged incident was inadmissible because it was too remote in time. 644 A.2d at 988. In Allen, the court looked to the amount of time that had passed between the date of the prior incident and the current incident. Id. The court did not look to the date of release, although there was an indication that the defendant served time which would have rendered the evidence admissible within the D.R.E. 609(b) time limit. Id. at FN. 5.