DE: Def made a sufficient offer of proof to get a Franks hearing in a DUI blood warrant over omissions in how the FST was done

Delaware refers to affidavit material omissions as a reverse-Franks issue, and here he made a sufficient offer of proof to get a hearing on a search warrant for blood in an DUI case about how the field sobriety test was unreasonably and inadequately conducted. State v. Hackendorn, 2016 Del. Super. LEXIS 22 (Jan. 13, 2016):

In a reverse-Franks situation, if the “defendant establishes by a preponderance of the evidence that the police knowingly and intentionally, or with reckless disregard for the truth, omitted information material to a finding of probable cause, the reviewing court will add the omitted information to the affidavit and examine the affidavit with the newly added information to determine whether the affidavit still gives rise to probable cause.”