Justia Delaware Supreme Court Opinion Summaries

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Following an accident where a motorcycle ran into the rear-end of an SUV, police called to the scene detected a faint odor of alcohol emanating from the the rider of the motorcycle while he was being treated by paramedics. Defendant-appellant Bradford Lambert, III admitted he ran into the rear end of the SUV with his motorcycle. A jury later convicted Lambert of driving a vehicle while under the influence of alcohol (DUI). On appeal, he argued that the trial court erred by denying his motion to suppress blood alcohol concentration evidence because the search warrant affidavit failed to set forth facts sufficient to show probable cause. Finding no merit to this contention, the Supreme Court affirmed Lambert's conviction. View "Lambert v. Delaware" on Justia Law

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Appellant Ambrose Sykes appealed the Superior Court’s denial of his Motion for Post-conviction Relief. In 2006 Sykes was convicted by a jury of two counts of Murder in the First Degree, two counts of Rape in the First Degree, one count of Kidnapping in the First Degree, two counts of Burglary in the Second Degree, and other offenses. After a penalty phase hearing, the trial judge imposed the death penalty. On direct appeal, Sykes’ conviction and sentence were affirmed. In this appeal, Sykes raised five issues: (1) he received ineffective assistance of trial counsel in investigating, preparing and presenting mitigating evidence during his penalty-phase hearing; (2) trial counsel was ineffective by failing to argue that an erroneous comment which the trial judge made about allocution during the guilt phase of the trial violated his Sixth Amendment right to a fair trial by an impartial jury; (3) the trial judge committed error when he failed to remove Juror No. 9 from the jury after her impartiality was called into question during the guilt phase of the trial; (4) the State failed to prove Burglary, Rape and Kidnapping beyond a reasonable doubt; and (5) trial counsel was ineffective for failing to move for a judgment of acquittal on the kidnapping charge on the grounds that the restraint of the victim was incidental to, and not independent of, restraint pertaining to the underlying rape charge. After review, the Supreme Court found no merit to any of these claims and affirmed the judgment of the Superior Court. View "Sykes v. Delaware" on Justia Law

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Defendant-appellant Robert Williams was convicted of two counts of robbery in the first degree, two counts of possession of a firearm during the commission of a felony, one count of conspiracy in the second degree, and one count of assault in the third degree. He was sentenced to twenty-two years at Level V incarceration, followed by probation. He appealed a Superior Court order that denied his motion for postconviction relief, arguing: (1) the trial court should have found that his trial counsel was ineffective because he failed to file a motion to suppress a statement that Williams made to the police approximately fifteen hours after he was taken into custody; and (2) the trial court should have determined that his trial counsel was ineffective because he failed to investigate and present readily available mitigating evidence at Williams’ sentencing hearing. The Supreme Court affirmed the Superior Court, but took the opportunity to discuss its decision with regard to Williams second "novel" contention regarding a mitigation investigator in a non-capital case. "Given the seriousness of Williams’ criminal record, the chances he had to get on the right track, and the pre-sentence report that detailed his difficult childhood and the fact that his parents were poor role models, there is not a basis to conclude that there was a reasonable probability that Williams’ twenty-two year sentence, which was well below the 103 years he could have received, would have been lesser had the evidence Williams now points to been presented." Furthermore, the Court found that Williams' argument that a mitigation specialist should have been retained in a serious non-capital case as an invariable requirement of effective representation was without legal basis. View "Williams v. Delaware" on Justia Law

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A jury found appellant Victor Rodriguez guilty of Reckless Burning, Burglary in the Third Degree, two counts of Criminal Trespass in the Third Degree, and three counts of Arson in the Second Degree. After finding that he was an habitual offender, the Superior Court sentenced Rodriguez to life in prison for each of his arson convictions. The Delaware Supreme Court affirmed Rodriguez's convictions on direct appeal. Filing a pro se motion for postconviction relief, Rodriguez argued he received ineffective assistance of trial counsel. The Superior Court ultimately denied the motion, and Rodriguez appealed. Finding no reversible error, the Supreme Court affirmed the denial. View "Rodriguez v. Delaware" on Justia Law

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Defendant-appellant Freddie Flonnory appealed his conviction for felony Driving Under the Influence of Alcohol (DUI). Specifically, Flonnory challenged the Superior Court's denial of his motion to suppress the results of a blood draw, arguing: (1) that the trial court erred in holding that Delaware's implied consent statute exempted the blood draw from the Fourth Amendment's warrant requirement; and (2) that there was no voluntary consent, and that the trial court erred when it did not perform a Fourth Amendment totality of the circumstances analysis to determine whether Flonnory had in fact consented to the blood draw. The Supreme Court found that a totality of the circumstances analysis applied. Such analysis was not applied in this case by the Superior Court. Accordingly, the Court remanded this matter for further proceedings. View "Flonnory v. Delaware" on Justia Law

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Defendant-appellant William S. Sells, III appealed a Superior Court judgment where the jury found Sells guilty of Robbery in the First Degree, Possession of a Firearm During the Commission of a Felony, Possession of a Firearm by a Person Prohibited, Wearing a Disguise During the Commission of a Felony, six counts of Aggravated Menacing, and five counts of Reckless Endangering in the Second Degree. Sells raised two arguments on appeal: (1) the Superior Court erred when it denied his motion to sever his trial from his co-defendant's, Russell Grimes; and (2) the Superior Court erred in finding one of his peremptory challenges of a white juror violated the United States Constitution, and that it erred in upholding the State's Batson challenge. After review, the Supreme Court agreed with Sells' as to his second claim and, therefore, did not reach the first claim. Accordingly, Sells' conviction was reversed and the matter remanded for further proceedings. View "Sells v. Delaware" on Justia Law

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Plaintiff-appellant Tricia Moses was involved in a rear-end motor vehicle collision where defendant-appellee Aaron Drake's vehicle struck Moses' vehicle. Drake pled guilty to a citation for following a motor vehicle too closely. At the time of the incident, Moses was 26 weeks pregnant. Due to her past medical history, Moses was in a program for high-risk pregnancies. After the collision, Moses delivered her child prematurely at 31 weeks. While Moses' complaint contained allegations of trauma-induced premature birth and trauma-induced mental and physical difficulties relating to the child, Moses did not oppose dismissal of all claims pertaining to the child. Due to the severe nature of the claimed injuries in Moses' complaint, it appeared initially that Drake needed multiple experts to address the various claims. Drake's counsel requested at least six months to prepare expert reports after Moses' expert reports were due. After Moses failed to meet a deadline, Drake filed a motion to dismiss. In response, Moses' counsel contacted Drake's counsel, and the parties agreed to a stipulation modifying the scheduling order and extending the expert disclosure deadlines. The stipulation was then approved by the Superior Court. When a new deadline was set, Moses produced a one-paragraph opinion from her treating physician, Dr. Stephen Ogden. Drake filed a motion to dismiss on the basis that Dr. Ogden's opinion was legally insufficient because he used the word "feasible." Drake argued that "feasible" did not meet the standard for reasonable medical probability because the dictionary definition is synonymous with "possible." On appeal of the district court's grant of summary judgment to Drake, Moses argued: (1) Dr. Odgen's medical opinion was sufficient to deny Drake's motion for summary judgment on the claim that the medical opinion was legally deficient; and (2) in the alternative, that the denial of her motion to reargue was improper given Dr. Ogden's "clarifications" of his opinion. Finding no reversible error, the Supreme Court affirmed the grant of summary judgment. View "Moses v. Drake" on Justia Law

By Justia Inc
Textron, Inc. appealed a Superior Court judgment which held that the company was not entitled to reimbursement from its former fastening manufacturing business, now known as Acument Global Technologies, Inc. for paying certain pre-closing contingent liabilities in the United States. The Superior Court's opinion centered on the meaning of a "tax benefit offset" provision in the parties' Purchase Agreement under which Acument was required to reimburse Textron if Acument received a "tax benefit" related to the contingent liabilities. Textron argued that even if the tax benefit had to be actual rather than merely hypothetical, the Superior Court erred by not finding that Acument actually enjoyed the right to tax benefits. Textron contended that its payment of the pre-closing liabilities constituted a tax benefit because the payments automatically increase Acument's tax basis under U.S. tax law. The Supreme Court disagreed after its review of the appeal: the Agreement, taken as a whole, guaranteed that Acument would not receive a net tax benefit simply because Textron made a required indemnification payment. Accordingly, Textron's argument that Acument has received a tax benefit triggering Textron's right to reimbursement was without merit, as the total effect of Textron's payments is tax-neutral. Similarly, Textron's second and related claim that the Superior Court erred in "redefining" the required tax benefit to mean only a "deduction" rather than any "reduction" was meritless. The therefore affirmed the Superior Court's judgment. View "Textron v. Acument Global Technologies, Inc." on Justia Law

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Defendant-appellant Ira Brown appealed a Superior Court order denying his first motion for post-conviction relief under Superior Court Criminal Rule 61. Brown raised two issues on appeal: (1) he was entitled to a new trial based on newly discovered evidence of misconduct at the Office of the Chief Medical Examiner (although Brown did not raise this claim in his Rule 61 motion because problems at the Examiner's Office did not come to light until almost a year after Brown filed his Rule 61 motion), the Delaware Supreme Court nonetheless considered this issue on appeal in the interests of justice); and (2) Brown argued the Superior Court erred in its 2012 denial of both his oral motion and his written motion to withdraw his guilty plea. The Supreme Court found that Brown's first claim had no merit. Further, Brown could have raised his second argument in his Rule 61 motion (or in a timely direct appeal) but did not. That argument was therefore waived and procedurally barred. The Court therefore affirmed the Superior Court's denial of post-conviction relief. View "Brown v. Delaware" on Justia Law

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Isaiah McCoy was tried by jury and ultimately sentenced to death. Seven counts were submitted for the jury to decide; McCoy was found guilty as to all but Count 7. Following his convictions for first degree murder, the trial court held a capital murder penalty hearing, after which, the jury found several aggravating circumstances. On appeal, McCoy raised five grounds on which his convictions should have been reversed. After review of all five, the Supreme Court concluded: (1) the trial court committed reversible error when it improperly denied McCoy's right to exercise a peremptory challenge to strike a potential juror; (2) it was reversible error when the prosecutor improperly vouched for the credibility of a key witness for the State; and (3) the pervasive unprofessional conduct of the prosecutor that permeated the proceedings compromised McCoy's right of self-representation. The Court found the other two issues McCoy raised on appeal were without merit. The case was reversed and the matter remanded for a new trial. View "McCoy v. Delaware" on Justia Law