Justia Delaware Supreme Court Opinion Summaries

Defendant-appellant Gerald Masarone appealed a Superior Court order denying his motion for postconviction relief. He raised two issues as grounds for appeal: (1) that his trial counsel was ineffective by not advising him that he had a right to wear street clothes, rather than a prison uniform, at his trial, and by failing to provide him with street clothes; and (2) the Superior Court erred by failing to hold an evidentiary hearing on his first claim. On this record, the Delaware Supreme Court could not conclude that Masarone was compelled to go to trial in a prison uniform. In addition, given the nature of the evidence against Masarone, no arguable error on this point or on the lack of an evidentiary hearing caused Masarone harm or prejudice. The Superior Court's order was affirmed. View "Masarone v. Delaware" on Justia Law

Earl Bradley petitioned the Supreme Court for postconviction relief. He was convicted on fourteen counts of first-degree rape, five counts of second-degree assault and five counts of sexual exploitation of a child. Bradley was sentenced to fourteen mandatory life sentences and 164 years at Level V imprisonment. In a 2012 direct appeal, Bradley argued that the search warrant for his former medical practice, BayBees Pediatrics, P.A., was defective because the affidavit in support of the search warrant application did not allege facts establishing probable cause that the medical files of certain patients would be found in a white outbuilding on the BayBees Pediatrics property, would be contained in digital format, or would relate to the crimes described in the search warrant application. Bradley also asserted that the police exceeded the scope of the search warrant by proceeding with a general search to locate and seize evidence without probable cause. The Delaware Supreme Court rejected those claims. Bradley raised three issues in this appeal: (1) the Superior Court erred when it denied his request for an evidentiary hearing and held that State action did not deprive him of his right to choice of counsel; (2) the Superior Court erred when it held that his trial and appellate counsel were not ineffective when they failed to object to the presentation of evidence outside of the four corners of the search warrant; and (3) the Superior Court erred in finding that his trial and appellate counsel litigated, in an effective and professionally reasonable manner, the claim that the police had performed an unrestricted search of his property in violation of the federal and state Constitutions. Finding no reversible error, the Supreme Court affirmed the Superior Court's denial of postconviction relief. View "Bradley v. Delaware" on Justia Law

Defendant Christopher Wheeler petitioned the Delaware Supreme Court to overturn his conviction of Dealing in Child Pornography. He raised two issues: (1) he challenged a 2014 Superior Court denial of his Amended and Superseding Motion to Suppress, arguing that the nature of “general warrants” were overly broad in scope, and the execution of which violated his federal and State Constitutional rights; and (2) he challenged a second Superior Court denial of his motion for Judgment of Acquittal, arguing insufficient evidence to convict him because the State could not establish that he was aware of the existence of the offending images on his computer, stored in his “newsgroup cache.” Wheeler was sentenced to 50 years at Level V. Throughout these proceedings, Wheeler asserted that the State used charges of witness tampering stemming from his admission in 2013 that he had molested two brothers in Pennsylvania in the 1980’s as a pretext to search broadly for child pornography. The challenged warrants in this case were the witness tampering warrants: not the later-obtained child pornography warrant. The State admitted that the challenged witness tampering warrants were virtual copies of an off-the-shelf warrant for child pornography. Because the Supreme Court agreed that the challenged witness tampering warrants were in the nature of “general warrants” in violation of the United States and Delaware Constitutions, it reversed the judgments of the Superior Court and remanded this matter for further proceedings. View "Wheeler v. Delaware" on Justia Law

The issue in this case was whether defendant-appellant William Morrison’s waiver of his right to trial counsel was “knowing, intelligent and voluntary.” Morrison was arrested on suspicion of trespassing or burglary. At the conclusion of a hearing, Morrison stated he wished to terminate his representation by appointed counsel. The trial judge conducted an inquiry and declined the request. The trial judge informed Morrison that he could either continue to be represented by the appointed defense counsel, or proceed pro se. After reviewing the “incomplete” colloquy between the the trial judge and Morrison, the Supreme Court concluded that Defendant did not waive his right to counsel “knowingly.” Morrison’s conviction was reversed and the matter remanded for a new trial. View "Morrison v. Delaware" on Justia Law

Appellant-defendant Steven Baynum and Manisha Baynum married in 2009. In 2012, the couple experimented with having an “open marriage” and shared an intimate experience with Dakota Holdren (“Dakota”). Thereafter, Manisha was romantically involved with Dakota. In 2013, Manisha filed for divorce. Manisha was granted a Family Court Order affording her exclusive use a property owned by Steven's grandparents. The Order prohibited Baynum from accessing the residence and, as a result, he often stayed with his grandparents at another residence, located on the same property the house now occupied by Manisha. In the early hours of October 24, Dakota and Manisha were at Manisha's home. Interested in “check[ing] out the place,” Baynum communicated with Manisha via text messages and phone calls regarding whether he could come. After being dissuaded by Manisha, Baynum temporarily refrained from going to the house, although he “decided to put a ladder at the base of [28 Harvest Lane’s] driveway . . . .” Later that evening, Manisha was awakened by noises emanating from the bathroom, later discovering Baynum, who jumped on the bed, pulled a blanket off of Dakota, and started punching him. After convincing Baynum to join her in the kitchen, Manisha dialed 9-1-1, but was unable to speak with an operator because Baynum “took the phone out of [her] hands” and “took the battery out of the phone.” Thereafter, Baynum “dragged” Manisha back to the bedroom, where he proceeded to “tie up” Dakota utilizing an ethernet cord. Baynum then pushed Manisha onto her stomach and attempted to tie her hands together using an iPhone charging cord. Manisha testified that she bit Baynum on his arm during the struggle. Baynum responded by punching her in the face and holding a knife to her throat. New Castle County police officers were dispatched to Manisha's house. The next day, Baynum appeared at his grandparents’ residence, explaining to his grandmother that “he had beat the crap out of the man that was living -- sleeping with his wife. And [Baynum] said [he] was just trying to defend [his] -- [his] wedding vows, reaffirming his marriage.” After Baynum left, his grandmother informed the police. The Superior Court denied Baynum’s Motion in Limine prior to his trial on charges stemming from the incident at Manisha's house. The ruling was issued following an evidentiary hearing conducted in connection with Baynum’s Motion, which sought dismissal of his case before trial or, in the alternative, a "Lolly" jury instruction, on the theory that the State failed to collect or preserve potentially material evidence. Baynum appealed his convictions and argued that the Superior Court erred in denying his Motion. Finding no reversible error, the Supreme Court affirmed the Superior Court. View "Baynum v. Delaware" on Justia Law

Manuel Morales was found not guilty of Offensive Touching, but guilty of Robbery First Degree, relating to a 2013 incident at a cell phone store in Elsmere. Morales jumped over the counter and demanded money, indicating that, if the store's clerk did not comply, he would kill her. When the clerk opened the register, Morales took money out of it. As he ran out of the store, Morales collided with another woman who was entering the store through the front door. He was sentenced to ten years of incarceration at Level V, suspended after three years for decreasing levels of supervision. Seeking reversal of his conviction and sentence, Morales argued for the first time on appeal that the prosecutor’s statement to the jury during summation that he was “clearly guilty” denied him a fair trial. The Supreme Court concluded the prosecutor’s improper comment did not amount to plain or repetitive error requiring reversal, and therefore, affirmed Morales’s conviction and sentence. View "Morales v. Delaware" on Justia Law

In 1992 Jermaine Wright was convicted of first degree murder, first degree robbery, and related weapons offenses for his involvement in what was known as the "Hi-Way Inn murder/robbery." The Superior Court imposed the death penalty for his murder conviction. Prior to trial, Wright moved to suppress a statement he had given to police. He alleged that his waiver of Miranda rights was invalid and his statement was involuntary because he was high on heroin at the time. The Superior Court denied the motion, finding that Wright had been given the Miranda rights three times, by three different police officers, and that the State had “met its burden of proof by a preponderance of the evidence that the Defendant’s waiver of his Miranda rights was voluntary, knowing and intelligent, and that his confession was voluntarily made.” Wright then filed a second pretrial motion to suppress his confession on other grounds. In its opinion denying that motion, the Superior Court again found that Wright had been given his Miranda rights three times. The confession was admitted into evidence at trial. On direct appeal, Wright’s convictions and sentences were affirmed. Between then and 2009, Wright filed four motions for post conviction relief. In the second postconviction proceeding, the Superior Court again rejected Wright’s contention that his waiver of Miranda rights was not valid. In 2014, in the fourth postconviction proceeding, the Delaware Supreme Court reversed Wright’s convictions on the ground that the State violated his rights under "Brady v. Maryland." The case was remanded to the Superior Court for a new trial. By the time the fourth motion for postconviction relief was filed, the original trial judge had retired and the case had been assigned to her successor. In the new trial proceedings, the successor judge granted a motion to suppress Wright’s confession on the ground that the Miranda rights he was given were inadequate, and that his waiver was, therefore, not valid. The last ruling was presented for the Delaware Supreme Court's review. The Court concluded that the original Superior Court judge’s determination that Wright’s waiver of his Miranda rights was voluntary, knowing, and intelligent necessarily included an implied determination that the warnings were adequately given. Those determinations are the law of the case. For this reason, the successor judge erred in reviewing the admissibility of Wright’s confession. The State also appeals the successor judge’s denial of a motion that he recuse himself. At oral argument, the State conceded that the Supreme Court did not have jurisdiction under 10 Del. C. 9902 to review that order. Therefore, the Court did not address the Superior Court’s ruling on recusal or express any opinion on recusal. View "Delaware v. Wright" on Justia Law

A masked gunman went into a Wilmington barbershop, shot his intended victim, and also shot and killed a five-year-old boy. The police arrested Chauncey Starling one month after the shooting, when the State’s key witness, Alfred Gaines, identified Starling as the shooter. In 2003, the State tried Starling for first degree murder, conspiracy, and related weapons charges. No physical evidence linked Starling to the crime. Instead, the State relied primarily on Gaines’ testimony and statements made to police by Starling’s brother and girlfriend. The State also relied on testimony from the victim’s girlfriend, who identified Starling as the shooter based on his eyes. A Superior Court jury convicted Starling of all charges, and the judge sentenced him to death. On direct appeal, the Delaware Supreme Court affirmed the conviction but remanded the case for resentencing. After remand, the Superior Court again sentenced Starling to death. The Supreme Court again affirmed the death sentences. Starling then moved for postconviction relief, claiming that his trial counsel was ineffective, that the State failed to disclose exculpatory evidence and that the prosecution engaged in misconduct at trial. Following years of discovery, evidentiary hearings, and briefing, the Superior Court denied Starling’s motion and this appeal followed. Starling renewed the same constitutional arguments on appeal. The Delaware Supreme Court's review of the record lead it to conclude that mistakes were made that "undermine[d] confidence in the fairness of the trial." The cumulative effect of these errors lead the Court to conclude that there was a reasonable probability that the outcome of the trial would have been different without the errors. Therefore Starling’s conviction was reversed and his case remanded for a new trial. View "Starling v. Delaware" on Justia Law

Ramon Ruffin was charged in an eleven-count indictment: one count of Attempted Robbery First Degree; three counts of Possession of a Firearm During Commission of a Felony (“PFDCF”); one count of Assault First Degree; one count of Aggravated Menacing; two counts of Possession of a Firearm by a Person Prohibited (“PFBPP”); one count of Receiving a Stolen Firearm; one count of Disregarding a Police Officer’s Signal and one count of Resisting Arrest. A jury found Ruffin guilty of Assault Second Degree, the lesser included offense of Assault First Degree. He was convicted him, as charged, of all other counts. Ruffin was declared a habitual offender and sentenced to be incarcerated for a minimum of 113 years. Ruffin raised four claims on appeal: (1) the trial court erred in admitting the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”) trace report into evidence because it was inadmissible hearsay; (2) he was denied a fair trial due to improper, suggestive eyewitness identification; (3) the trial court erred in denying his request for a "Lolly" instruction regarding the State’s failure to test allegedly exculpatory evidence; and (4) he was prejudiced by cumulative error. The Supreme Court found, after review, no merit to any of Ruffin's claims, and affirmed his convictions and sentence. View "Ruffin v. Delaware" on Justia Law

Defendant-appellant Carlton Gibbs was the target of the Capital Area Regional Fugitive Task Force. He had been wanted for a year prior to the Task Force's eventual arrest of Gibbs in April 2014. Gibbs was arrested for multiple charges, most of which stemmed from the car chase that ensued with members of the Task Force leading to Gibbs' arrest. Gibbs appealed the denial of his motion for judgment of acquittal on his eventual conviction on those multiple charges; Gibbs maintained: (1) he could not be found guilty of failing to stop at the command of a police officer because deputy United States Marshals did not qualify as police officers; and (2) he could not be found guilty of Title 21 offenses because he was on private property when they were alleged to have occurred. Finding no error, the Delaware Supreme Court affirmed Gibbs' convictions. View "Gibbs v. Delaware" on Justia Law