Justia Delaware Supreme Court Opinion Summaries

The dispute centers on a Delaware law, House Bill 242 (HB242), which permits New Castle County school districts to set different property tax rates for residential and non-residential properties for the 2025-2026 school year. This legislation was enacted after a county-wide property reassessment revealed a significant shift in the tax base, resulting in higher taxes for residential properties. In response to public concern, HB242 allowed school districts to implement a split-rate system, reducing residential rates and increasing non-residential rates, with the stipulation that non-residential rates could not exceed twice the residential rate and that total projected revenue could not surpass the amount projected under the original tax warrant. Subsequent corrections to property classifications led to a net increase in projected tax revenue.The plaintiffs, four property-related associations, challenged HB242 in the Court of Chancery, arguing that it violated the Uniformity Clause of the Delaware Constitution and a “revenue neutrality” requirement in the statute. The Court of Chancery rejected these claims, finding that the General Assembly has the authority to create reasonable property classifications for tax purposes and that the statute’s use of “projected” rather than “actual” revenue allowed for adjustments due to classification corrections.On appeal, the Supreme Court of Delaware reviewed the constitutionality of HB242 and the statutory interpretation issues de novo. The Court held that the Uniformity Clause does not prohibit reasonable legislative classifications of property for taxation, provided tax rates are uniform within each class. The Court also determined that HB242’s revenue limitation applies to projected, not actual, revenue, and that corrections to property classifications do not violate the statute. The Supreme Court of Delaware affirmed the judgment of the Court of Chancery. View "Newark Property Association v. State" on Justia Law

A confidential informant reported seeing Anthony Miller, known as “Thugsy,” carrying a handgun and selling drugs in Wilmington, Delaware. Police surveilled the area, observed Miller, and attempted to arrest him. Miller fled, resisted arrest, and was subdued. Officers recovered a loaded handgun and drugs, including pills that tested positive for MDMA and cocaine. Miller admitted to selling MDMA and possessing the firearm. He was initially indicted by a New Castle County grand jury for several offenses, including Drug Dealing MDMA (a Class B felony). A subsequent reindictment changed the main drug charge to Drug Dealing Methamphetamine (a Class C felony), reflecting the actual substance involved.Before his suppression motion was heard, Miller entered a plea agreement in the Superior Court of the State of Delaware, pleading guilty to Drug Dealing Methamphetamine, Possession of a Firearm During the Commission of a Felony, and Resisting Arrest. Due to clerical errors, the plea paperwork and colloquy incorrectly identified the drug dealing charge as a Class B felony with a higher sentencing range, even though the court read the correct substance and quantity from the reindictment. Miller was sentenced to a total of seven years of unsuspended prison time. He did not seek to withdraw his plea but appealed, arguing that his constitutional right to be indicted by a grand jury was violated because he pled guilty to an unindicted, more serious offense.The Supreme Court of the State of Delaware reviewed the case for plain error, as Miller had not raised the issue below. The court held that Miller’s substantial rights were not affected because he received significant benefits from the plea, including immediate sentencing and avoidance of a much longer potential sentence. The court found no plain error and affirmed the conviction, but remanded to the Superior Court to consider Miller’s pending motion for sentence reduction. View "Miller v. State" on Justia Law

A man was shot and killed outside a convenience store in Wilmington, Delaware. Surveillance footage captured the masked shooter’s movements before and after the incident, and police identified several witnesses, including Darnella Spady, who was present at the scene. During a police interview, Spady identified the shooter as “Gunner,” later determined to be Kevin Berry, and described her interactions with him. However, at trial, Spady was uncooperative, claimed memory loss due to drug use, and stated she could not recall the shooting or her prior statement to police. The prosecution sought to admit Spady’s out-of-court statement as substantive evidence under 11 Del. C. § 3507.The Superior Court of the State of Delaware conducted a bench trial after Berry waived his right to a jury. The court admitted Spady’s prior statement over Berry’s objection, finding that the State had established the necessary foundation under Section 3507 and that the statement was voluntary. The court found Berry guilty of first-degree murder and related weapons charges, and sentenced him to life plus ten years. Berry appealed, arguing that the trial court erred in admitting Spady’s statement and urging the Delaware Supreme Court to overturn its recent precedent in McCrary v. State, which clarified the foundational requirements for admitting such statements.The Supreme Court of the State of Delaware reviewed the case and affirmed the Superior Court’s decision. The Court held that there was no urgent reason or clear error warranting a departure from McCrary v. State, and that the trial court did not abuse its discretion in admitting Spady’s statement. The Court concluded that the State’s questioning satisfied the statutory requirements, and Berry’s confrontation rights were not violated. The convictions were affirmed. View "Berry v. State" on Justia Law

A masked assailant entered a jewelry store in Delaware, assaulted the owner with a gun and hammer, smashed display cases, and stole jewelry before fleeing. The owner, Chang Yen Suh, suffered significant injuries requiring hospitalization and months of rehabilitation. Calvin Ushery was indicted for multiple offenses, including first-degree robbery, first-degree assault of a person over 62, possession of a deadly weapon during the commission of a felony, and other related charges. After a mistrial in the first jury trial, a second jury trial resulted in Ushery’s conviction on three counts. The State dismissed several other charges, and Ushery was sentenced as a habitual offender to substantial prison terms.The Superior Court of the State of Delaware presided over both trials and sentencing. Ushery appealed, arguing that the trial court failed to properly admonish the jury against pre-deliberation discussions and exposure to extrajudicial information, and that the court erred by not investigating or excusing an alternate juror who submitted a note raising questions about the evidence and his own hearing difficulties. Ushery claimed these failures violated his constitutional right to a fair trial by an impartial jury and requested the adoption of a presumption of juror misconduct when admonishments are lacking.The Supreme Court of the State of Delaware reviewed the case for plain error, as Ushery’s claims were not raised at trial. The Court held that, although daily admonishments are recommended, the instructions given were sufficient and did not constitute plain error. The Court also found no evidence of juror misconduct or bias, and that the trial court acted within its discretion regarding the alternate juror. The Supreme Court affirmed the Superior Court’s judgment of conviction. View "Ushery v. State" on Justia Law

A father appealed a Family Court order terminating his parental rights. The Department of Services for Children, Youth and their Families (DFS) took custody of the father's son shortly after birth due to the father's mental health issues, substance abuse, unstable housing, employment status, previous involvement with DFS, history of domestic violence, and failure to plan for the child. DFS moved to be excused from case planning with the father under 13 Del. C. § 1103(d), arguing that grounds for termination existed under 13 Del. C. § 1103(a)(7) because the father's parental rights to another child had been involuntarily terminated in an earlier proceeding. The Family Court granted the motion and later terminated the father's parental rights after finding clear and convincing evidence that termination was in the best interests of the child.The father argued on appeal that Section 1103(d) is unconstitutional. The Supreme Court of Delaware reviewed the case and concluded that Section 1103(d) is not unconstitutional as applied to the father. The court found that the Family Court's analysis under Sections 1103(a)(7) and 1103(d) was supported by the record and that termination of the father's parental rights was in the best interests of the child. The court also rejected the father's argument that the "least restrictive means" standard should be applied, instead following the due process framework established by the U.S. Supreme Court in Mathews v. Eldridge.The Supreme Court of Delaware affirmed the Family Court's judgment, holding that the statutory grounds for termination were met and that the termination was in the best interests of the child. The court found that the father received sufficient process before the termination of his parental rights and that the Family Court's findings were supported by clear and convincing evidence. View "Schnell v. Department of Services for Children, Youth and their Families" on Justia Law

The defendant, while under the influence of illegal drugs, killed a police officer and assaulted several others. He claimed that his behavior was due to someone substituting bath salts for his methamphetamine, and sought to use a statutory involuntary intoxication defense. The Superior Court granted a motion in limine, preventing the presentation of this defense and deemed the defendant’s evidence inadmissible.The Superior Court of Delaware reviewed the case. The court examined whether a person who knowingly introduces an unlawful intoxicating substance into their body can present an involuntary intoxication defense if the substance or its effects differ from what was anticipated. The court concluded that under Title 11, Section 423 of the Delaware Code, a person who knowingly introduces an unlawful intoxicating substance into their body is precluded from presenting an involuntary intoxication defense unless certain statutory exceptions apply.The Delaware Supreme Court affirmed the Superior Court’s decision. The court held that the statutory language was unambiguous and that a person who knowingly introduces an unlawful intoxicating substance into their body cannot claim involuntary intoxication unless specific statutory exceptions are met. The court did not address the admissibility of the defendant’s evidence under Rule 702 and 11 Del. C. § 303, as the defense was unavailable as a matter of law. The court also found that precluding the defense did not violate the defendant’s constitutional right to present a complete defense. View "Wilkerson v. State" on Justia Law

In response to the COVID-19 pandemic, the Governor of Delaware issued a series of emergency orders that included restrictions on religious services. These restrictions, which were lifted by June 2020, limited in-person worship to ten people and imposed various other mandates. Over 18 months later, two religious leaders filed suit in the Court of Chancery seeking injunctive relief against these restrictions, which were no longer in effect. The Court of Chancery dismissed the case for lack of subject matter jurisdiction, concluding that the plaintiffs could not demonstrate a reasonable apprehension of future harm.The plaintiffs then transferred their action to the Superior Court, seeking declaratory judgment and damages for alleged violations of their constitutional rights. The Superior Court dismissed the claims, ruling that the requests for declaratory relief were not justiciable because the restrictions had been lifted and there was no ongoing controversy. Additionally, the court found that the Governor was immune from the damages claims under the State Tort Claims Act and the doctrine of qualified immunity.On appeal, the Delaware Supreme Court affirmed the lower courts' decisions. The Court agreed that the plaintiffs failed to show a reasonable apprehension of future harm, which is necessary for injunctive relief. The Court also held that the plaintiffs' claims for declaratory judgment were not justiciable because there was no ongoing controversy and the alleged harm could not be redressed by a declaratory judgment. Finally, the Court upheld the Superior Court's finding that the Governor was immune from damages claims, as his actions were discretionary and taken in good faith during an unprecedented public health crisis. View "In re Covid-Related Restrictions on Religious Services" on Justia Law

In December 2017, Antoine Terry was found dead from multiple gunshot wounds in New Castle, Delaware. The police arrested Terry’s friend, Shaheed Matthews, for the murder. In 2019, Matthews was tried for murder and possession of a firearm during the commission of a felony. The State's case relied on circumstantial evidence, including evidence from Matthews’s cellphone, witness testimony, video camera footage, and gunshot residue found on Matthews’s jacket. Matthews was convicted and sentenced to life plus three years in prison.Matthews appealed his conviction, arguing that his trial counsel was ineffective for failing to move to suppress evidence obtained from his cellphone. The Superior Court denied Matthews’s motion, concluding that Matthews had provided valid consent for the search of his cellphone and that the cellphone evidence had no bearing on the outcome of the case. Matthews appealed this decision to the Supreme Court of the State of Delaware.The Supreme Court of the State of Delaware reversed the Superior Court's decision. The court found that Matthews did not provide valid consent for the search of his cellphone and that the warrant obtained by police to search Matthews’s cellphone was an unconstitutional general warrant. The court also found that the cellphone evidence was material and significant to the State's case. Therefore, the court concluded that Matthews’s trial counsel’s failure to move to suppress the evidence obtained from his cellphone constituted deficient performance and prejudiced Matthews. The court vacated Matthews’s convictions and remanded the case to the Superior Court for a new trial. View "Matthews v. State" on Justia Law

In 2019, Jose Terreros was left in charge of his girlfriend's children. Upon returning home, his girlfriend was informed by her four-year-old daughter that Terreros had sexually abused her. The girlfriend immediately asked Terreros to leave and called the police. She later discovered concerning web searches on Terreros's phone, which he had left behind, including queries about how long saliva and fingerprints remain on bodies and clothes, and whether police can detect if a child has been raped. Based on this, investigators obtained a warrant to search Terreros's phone. They searched his messages, messaging apps, photos, videos, internet search history, GPS coordinates, and incoming and outgoing calls without any date restrictions. On trial, Terreros was found guilty of Sexual Abuse of a Child and Dangerous Crime Against a Child, but not guilty of Rape First Degree. Terreros appealed his conviction, arguing that the warrant was overbroad and that the verdicts were inconsistent. The Supreme Court of the State of Delaware agreed with Terreros regarding the warrant, finding it to be a general warrant and thus unconstitutional. The court held that all evidence obtained from the phone should have been suppressed. The court also remanded the inconsistent verdicts issue back to the lower court for further consideration, as it had not been fully addressed by the State. The court reversed Terreros's convictions and remanded the case for further proceedings. View "Terreros v. State" on Justia Law

In the Supreme Court of the State of Delaware, defendant Kwesi Hudson, who was convicted of first-degree kidnapping, first-degree robbery, second-degree rape, and other crimes, appealed on two grounds. First, he challenged the Superior Court's decision to deny his pre-trial motion to exclude the State’s expert testimony on DNA mixture interpretation and technology. He argued that the STRmix software used to process the DNA was not scientifically reliable. Second, he contended that the Superior Court erred in denying his motion to suppress cell-site location information collected from cell tower dumps via ten search warrants. He claimed that these warrants violated his rights under the Fourth Amendment to the United States Constitution, Article I, Section 6 of the Delaware Constitution, and Delaware statutory law. The Supreme Court of the State of Delaware found Hudson’s challenges to be without merit and affirmed his convictions and the decisions of the Superior Court. The court ruled that the DNA evidence was reliable and admissible, and that a Daubert hearing to test its admissibility was not necessary. Additionally, the court concluded that the cell tower warrants were constitutional under the Fourth Amendment, as they were sufficiently particular and based on probable cause. View "Hudson v. State" on Justia Law