Justia Delaware Supreme Court Opinion Summaries

Milton Taylor appeared before a superior court judge and offered to plead guilty but mentally ill for the July 2016 murder of Whitney White. After his counsel told the court that Taylor was competent to plead guilty, the court conducted a plea colloquy with him but deferred accepting the plea until a later sentencing hearing, when the court would have the presentence investigation. The day after the hearing, Taylor told his counsel to withdraw his plea. His counsel refused. Taylor then made pro se requests to withdraw his plea. The court would not consider them because Taylor had counsel. At the sentencing hearing, Taylor addressed the court and sought again to withdraw his plea. The trial judge refused to consider Taylor’s request because Taylor had counsel. Over Taylor’s objection, the court accepted the guilty but mentally ill plea to manslaughter and possession of a deadly weapon during commission of a felony, and sentenced Taylor to 45 years in prison. Taylor appealed. After review, the Delaware Supreme Court determined: (1) Taylor waived his right to object to the “sole issue” statutory requirement - the State and counsel agreed the plea hearing could be conducted in two parts; (2) Taylor did not cooperate with the presentence investigation; (3) defense counsel’s refusal to withdraw Taylor’s plea violated Taylor’s Sixth Amendment autonomy interest to decide the objective of his defense (having represented to the court that Taylor was competent to plead guilty, defense counsel should have followed Taylor’s demand to withdraw his plea before the court accepted it); (4) under Superior Court Criminal Rule 11, before adjudicating a defendant guilty but mentally ill by plea, the court must address the defendant in open court and be satisfied that the defendant is entering his plea knowingly, intelligently, and voluntarily - before the court accepted Taylor’s plea, he objected, thus, Taylor could not have entered his plea voluntarily. The Supreme Court therefore vacated Taylor’s conviction, and remanded this case back to the superior court for his counsel to review with Taylor whether he should withdraw his plea. If he was competent to make the decision and insisted on withdrawing his guilty but mentally ill plea, the court should allow Taylor to withdraw his plea and proceed to trial. View "Taylor v. Delaware" on Justia Law

Jerry Longford-Myers has had his share of encounters with the law. The portions of those encounters relevant to this case began on August 10, 201: Longford-Myers pleaded guilty to one count of maintaining a dwelling for keeping controlled substances, and the Superior Court sentenced him to two years’ imprisonment suspended for one year of probation. In a case unrelated to the 2011 "Maintaining Case," Longford-Myers pleaded guilty in 2012 to possession of a firearm during the commission of a felony (“PFDCF”) and drug dealing. The Superior Court sentenced Longford-Myers to eight years’ imprisonment suspended after three years for 18 months’ probation for the PFDCF charge and 8 years’ imprisonment suspended for 18 months’ probation for the drug dealing charge. In January 2018, Longford-Myers pleaded guilty to second-degree assault. The conviction that resulted from this plea was a violation of the terms of Longford-Myers’ probation sentences in the 2011 Maintaining Case and the 2012 Firearm/Drug Dealing Case. Because of those probation violations, the Superior Court resentenced Longford-Myers on February 6, 2018. Though the history of this case was "complicated," the issue it presented for the Delaware Supreme Court's review centered on whether, when a Superior Court sentence order contains sentences for multiple convictions, one of which was subject to modification under Superior Court Rule 35(a) because it was illegal, could the court also modify other lawful sentences within the order when it corrected the illegal sentence? The Supreme Court concluded that the Superior Court could not. Accordingly, the Supreme Court reversed the Superior Court judgment and remanded with instructions. View "Longford-Myers v. Delaware" on Justia Law

The State of Delaware appealed a superior court order that affirmed a determination by the Industrial Accident Board (the Board) that Nicholas Gates was working within the course and scope of his employment when he was injured in a motor vehicle collision. At the time of the collision, Gates was employed by the State as a road-maintenance equipment operator for the Department of Transportation (DelDOT). The collision occurred while he was responding to a “call-back” after his normal work hours. He was called back to attend to a roadside accident. Gates sought workers’ compensation benefits from the State for his injury. At the hearing before the Board, the State argued that State of Delaware Merit Rule 4.16 1 and a document titled “Call-Back Pay Guidelines and Recommended Procedure” (the Call-Back Pay Guidelines) were part of Gates’s employment contract. According to these provisions, Gates was not to be paid for a call-back until he arrived at the DelDOT yard. Because Gates’s collision occurred before he arrived at the yard, the State argued, his injury occurred outside the course and scope of his employment and was, therefore, not compensable under Delaware’s Workers’ Compensation Act (the Act).3 The Board looked to the parties’ prior course of conduct to determine the terms of the employment contract and found that Gates’s injury was compensable under the Act because, based on the parties’ prior course of conduct, he “was working within the course and scope of his employment contract when the motor vehicle accident occurred.” The Superior Court affirmed the Board’s decision. The Delaware Supreme Court affirmed the Superior Court, and therefore the Board. Specifically, the Court determined the Board applied the correct legal standard and acted within its discretion in finding, based on Gates’s unrebutted testimony as to the parties’ course of conduct prior to the collision, that the terms of Gates’s employment contract established he was to be paid for a callback from the time he received the call and that, at the time of the collision, he was working within the course and scope of this contract. These factual findings were supported by substantial evidence; the Board did not err in determining that Gates’s injury was compensable under the Act. View "Delaware v. Gates" on Justia Law

In late 2013, Steven Baynum broke into his estranged wife’s residence and physically accosted her and her new romantic partner. Approximately one year later, a Superior Court jury found Baynum guilty of first-degree burglary, third-degree assault, offensive touching, and a host of other crimes. After Baynum was sentenced as a habitual offender to 17 years, he appealed and the Delaware Supreme Court affirmed his convictions. Baynum then moved for postconviction relief under Superior Court Criminal Rule 61 claiming, among other things, that his trial counsel provided ineffective assistance of counsel in violation of his rights under the Delaware and United States Constitutions. The Superior Court denied Baynum’s motion, and he once again appealed to the Supreme Court. On appeal, Baynum argued: (1) his lawyers should have asked the trial court to instruct the jury to consider the charge of offensive touching as a lesser-included offense of third-degree assault in connection with his attack on the romantic partner, which would have had the possibility of a lighter sentence, and the corresponding acquittal of the more serious third-degree assault charge would have undermined the State’s prosecution of the first-degree burglary charges, which also had a physical-injury component; and (2) his counsel during his direct appeal made a prejudicial mistake by not appealing the trial court’s refusal to grant a mistrial following the State’s introduction of improper opinion testimony from one of the lead detectives. The Superior Court rejected both of Baynum’s claims. The Delaware Supreme Court agreed with Baynum on his first claim, and reversed the denial of postconviction relief as to the third-degree assault and first-degree burglary convictions. However, the Court disagreed with Baynum on his ineffective-assistance claim against his appellate counsel: the Court saw no reasonable probability that it would have reversed Baynum’s convictions on the ground that the Superior Court should have ordered a mistrial in the wake of the detective’s testimony, which was offered in response to similar testimony elicited by Baynum and was the subject of a curative instruction. The Court therefore affirmed the denial of postconviction relief as to the balance of Baynum’s convictions. View "Baynum v. Delaware" on Justia Law

In 2015, Jacquez Robinson was indicted for his alleged involvement in separate shootings on November 25 and 26, 2014, which left two people injured and one person dead. The issue his appeal presented for the Delaware Supreme Court's review centered on whether the State violated Robinson’s Sixth Amendment right to the effective assistance of counsel, and if yes, whether the trial court erred in dismissing his indictment for first degree murder. The Supreme Court affirmed the trial court’s conclusion that the State violated Robinson’s Sixth Amendment right to counsel as a result of its wrongful and unjustified intrusion into his attorney-client privileged materials. "But based upon our assessment of the record, and on our interpretation of 'Morrison’s' requirement that the remedy must be tailored to the harm, we reverse the Superior Court’s dismissal of the indictment. Although the Superior Court has discretion to sanction litigants, it failed to tailor its remedy to the violation and actual prejudice that it found." The trial court’s dismissal of the indictment failed to adequately "preserv[e] society’s interest in the administration of criminal justice." The matter was remanded for further proceedings. View "Delaware v. Robinson" on Justia Law

Based upon an informant’s tip and some “largely unproductive surveillance activity,” two Wilmington police detectives applied for a warrant to search Lamont Valentine’s apartment and automobile for evidence that Valentine, a convicted violent felon, was in possession of a firearm or ammunition. A magistrate issued the warrant, and when the officers conducted the search, they found marijuana, drug paraphernalia, and ammunition in the apartment and a firearm in the vehicle. These discoveries and other information provided by another resident of the apartment building resulted in numerous criminal charges against Valentine, including possession of a firearm by a person prohibited, drug dealing, aggravated possession of marijuana, terroristic threatening, and conspiracy. Valentine moved to suppress the fruits of the search on the grounds that the warrant affidavit and application did not establish probable cause that he had committed or was committing the offense of unlawfully possessing a firearm or that evidence of that crime was likely to be found in his apartment or car. The Superior Court denied the motion, and Valentine was eventually convicted of drug dealing, aggravated possession of marijuana, possession of drug paraphernalia, and endangering the welfare of a child. He appealed to challenge the Superior Court’s denial of his suppression motion. After review, the Delaware Supreme Court agreed with Valentine that the warrant application was insufficient to support a finding of probable cause that he had committed or was committing the crime identified in the warrant, or that a firearm was in his apartment or car. Accordingly, Valentine’s convictions were reversed. View "Valentine v. Delaware" on Justia Law

Appellant Justin Burrell, who was three months shy of his eighteenth birthday at the time the crimes were committed, was convicted by jury of first-degree murder, manslaughter, first-degree robbery, second-degree burglary, second-degree conspiracy, and four counts of possession of a firearm during the commission of a felony (“PFDCF”). He was sentenced to life imprisonment without the possibility of probation or parole for the first-degree-murder charge plus 50 years’ imprisonment for the remaining charges. In 2012, the United States Supreme Court decided Miller v. Alabama, which declared unconstitutional mandatory life imprisonment without the possibility of parole for juvenile offenders. In response to this ruling, the Delaware General Assembly enacted legislation modifying the juvenile sentencing scheme. At his resentencing, Burrell did not contest the applicability of the new 11 Del. C. Section 4209A’s 25- year minimum mandatory sentence to his first-degree-murder conviction, but argued that the court should not impose any additional statutory minimum mandatory incarceration for his five other convictions (first-degree robbery, second-degree burglary, and the three counts of PFDCF) on the grounds that such additional sentences would run afoul of Miller. The Superior Court disagreed and resentenced Burrell to the minimum mandatory 25 years’ imprisonment for the first-degree-murder charge plus an additional minimum mandatory 12 years’ incarceration for the other offenses. Burrell broadens his challenge to the Delaware Supreme Court, arguing the Superior Court erred when it imposed the 25-year minimum mandatory sentence for the first-degree-murder charge and the additional 12 years for the companion offenses. Further, he claimed the sentencing statutes were unconstitutionally “overbroad.” Finding no abuse of discretion or other reversible error, the Supreme Court affirmed Burrell's convictions and sentences. View "Burrell v. Delaware" on Justia Law

Appellant Aaron Thompson appealed after a jury found him guilty of two counts of first degree murder, two counts of possession of a firearm during the commission of a felony, and first degree conspiracy. The charges arose from the double homicide of Joseph and Olga Connell, who were shot to death in 2013. The State’s theory of the case at trial was that Mr. Connell’s business partner, Chris Rivers, paid to have the Connells killed so he could collect on an insurance policy listing Mr. Connell as the insured and Rivers as the beneficiary. The theory was that Rivers paid Joshua Bey, who in turn hired Dominique Benson and Thompson to carry out the murders. The success of the State’s theory at Thompson’s trial largely depended on the testimony and credibility of Bey. Thompson contended throughout the trial that Bey was lying and made up the connection with Thompson to get himself a favorable plea deal. On appeal to the Delaware Supreme Court, Thompson argued: (1) two statements by the State during its rebuttal argument constituted prosecutorial misconduct that undermined the fairness of the trial; and (2) the trial court abused its discretion in allowing Bey’s recorded statement to the police to be played for the jury following his testimony, arguing that this was inadmissible hearsay not subject to an exception. The Supreme Court found no reversible error and affirmed Thompson's convictions. View "Thompson v. Delaware" on Justia Law

Appellant Kevin Walker appealed a Superior Court order finding that he violated the terms of his probation. Walker began probation on May 10, 2017, as a result of a felony driving- under-the-influence conviction. On June 1, the State received a tip from a past-proven reliable informant that Walker had heroin in his home that he planned to distribute. On June 5, Delaware probation officers conducted an administrative search of Walker’s residence pursuant to an administrative warrant. During the search, probation officers discovered 252 bags of heroin, drug paraphernalia, and a locked safe. When the safe was taken to the Delaware State Police, they found a loaded handgun, five doses of Suboxone, and five grams of marijuana. Walker was thereafter arrested and taken to the Sussex Correctional Institution; at the SCI facility, offers found 86 bags of heroin and nine grams of crack cocaine inside Walker's rectum. Walker moved to suppress all the evidence found as the result of the administrative search. The Superior Court determined the search was not conducted in accordance with 11 Del. C. 4321(d) and Procedure 7.19. In particular, it found there was a lack of detail concerning the informant’s tip and that no effort was made at all to corroborate the tip or consider the reason why the informant was supplying information. The State did not appeal the suppression order, instead, dismissing the criminal action against Walker, but continued to pursue a violation of probation. The Delaware Supreme Court found that probation officers are not required to “satisfy each technical requirement of the search and seizure regulations of the Department of Correction” for a search to be reasonable. The Court concluded that the "proper and orderly administration of justice called for suppression, and reversed the Superior Court. View "Walker v. Delaware" on Justia Law

In July 2015, police officers stopped Javier Ayala for driving a vehicle with a suspended license. During a search of his vehicle and a subsequent search of his home under a previously issued warrant, officers found a .22-caliber pistol and 1,286 bags of heroin. The net weight of the bags’ contents was approximately 15 grams. In separate trials, two juries convicted Ayala of multiple charges relating to the contraband police found in Ayala’s home and vehicle. Because Ayala had been previously convicted of four other felonies, the Superior Court declared Ayala to be a habitual offender and sentenced him to a mandatory minimum prison term of seven years and six months. On appeal, Ayala challenged his convictions and sentence, contending: (1) the Superior Court abused its discretion when it admitted evidence regarding the identity and weight of the substance in the bags seized from his home and vehicle because the chemist who tested the suspected heroin bags did not lay a proper foundation for the admission of her hypergeometric-testing results; and (2) as a matter of law, he should not have been adjudged a habitual offender because the offenses forming the basis of three of his predicate felony convictions were no longer felonies when he was sentenced in this case. Finding no abuse of discretion, and that the habitual offender sentence enhancement was properly applied, the Delaware Supreme Court affirmed Ayala's conviction and sentence. View "Ayala v. Delaware" on Justia Law