Justia Delaware Supreme Court Opinion Summaries

Defendant was convicted of several crimes arising from the death of his fiancee and defendant was sentenced to death. Defendant subsequently appealed his convictions and death sentence. The court held that the trial court properly applied this court's holding in Cooke v. State to the circumstances of this case and did not deprive defendant of his Sixth Amendment right to the effective assistance of counsel. The court also held that there was sufficient evidence for a rational jury to find defendant guilty of Abuse of a Corpse beyond a reasonable doubt. The court further held that the judge in this case imposed the death sentence after adequately careful and deliberate consideration. The court finally held that defendant's death sentence, on the facts of this case, was not unlawfully disproportionate compared to the sentences imposed in similar cases. Accordingly, the court affirmed the judgment. View "Taylor v. State" on Justia Law

The police arrested defendant at a private party and based on evidence seized on the night of defendant's arrest, a magistrate issued a warrant to search his home. While executing the warrant, police discovered drugs and firearms in defendant's residence. Defendant was subsequently convicted of drug crimes committed on the evening of the arrest and defendant was later convicted of drug and firearm offenses related to the items seized at his home. Defendant appealed both his convictions, contending that the Superior Court judge erred by denying his motions to suppress. The court held that because the police illegally seized defendant when they obtained the drugs leading to his initial arrest, the evidence against him, including evidence seized from defendant's home, constituted inadmissible fruit of the poisonous tree. Accordingly, the court reversed. View "Jones v. State" on Justia Law

Defendant was convicted of crimes related to the attempted murder of the victim on January 26, 2006, and the subsequent murder of the victim on April 2, 2007. On appeal, defendant contended that the trial court abused its discretion by denying defendant's motion to sever the trial of the attempted murder case from the murder case; that his right to a fair trial before an impartial jury was violated when the evidence presented at trial did not clearly and convincingly establish the State's proffered "other crime" evidence of motive, due to the unwillingness of a State witness to testify; and his due process rights were violated when the trial judge denied his motions to suppress two separate pretrial eyewitness identifications. The court held that defendant's arguments were without merit and therefore, affirmed the judgments of the Superior Court. View "Monroe v. State" on Justia Law

Linda Thompson appealed from a Superior Court judgment reversing the determination of the Unemployment Appeals Board (UIAB) that good cause existed for Thompson's voluntary resignation and granting her unemployment benefits. Thompson contended that good cause existed for voluntarily terminating her employment, that she exhausted her administrative remedies, and that substantial evidence in the record supported the UIAB's decision. The court affirmed the judgment of the Superior Court and held that substantial evidence did not support the UIAB's decision and the UIAB erred as a matter of law by concluding that Thompson was entitled to benefits pursuant to 19 Del. C. 3314(1). View "Thompson & UIAB v. Christiana Care Health System" on Justia Law

Defendant appealed from a Family Court order finding him delinquent of, and sentencing him for, the offenses of Assault in the First Degree, Reckless Endangering in the First Degree, and Offensive Touching. On appeal, defendant challenged two of the Family Court's evidentiary rulings and claimed that there was insufficient evidence to support the court's adjudication of delinquency on all three charges. The court held that there was no plain error and that there was sufficient evidence to support the Family Court's finding of delinquency on all three charges. The court also held that the trial judge properly exercised his discretion in not excluding the state's rebuttal evidence. The court further held that the Family Court did not abuse its discretion in denying defendant's request to admit evidence of the victim's two convictions because there was no basis to admit that evidence as probative of defendant's claim of self-defense. Therefore, the judgments of the Family Court were affirmed. View "Wright v. State" on Justia Law

Defendant was convicted of two counts of rape in the first degree for raping his nine-year-old niece. On appeal, defendant contended, among other things, that the trial judge committed reversible error in denying his mistrial motion after prejudicial testimony was given regarding his prior conviction for a similar sexual offense against defendant's other niece. The court held that when the jury heard that defendant had committed a similar sexual offense against his other niece, this gave rise to an impermissible inference that he had committed the offense for which he was being tried. Therefore, a mistrial was required in the circumstances and the judgments of the Superior Court were reversed and the matter remanded for a new trial. To provide guidance at that new trial and in other cases, the court also commented on additional arguments made by defendant. View "Gomez v. State" on Justia Law

Defendant was convicted of robbery first degree and possession of a firearm during the commission of a felony (PFDCF) for robbing Barbara Santana at gunpoint. At defendant's jury trial, defendant's counsel proffered evidence of a different bank robbery (Artisans' Robbery) that recently had occurred across the street from the bank were Santana was robbed. Counsel called the man who had pled guilty to that crime, Joseph Blevins, as a witness in defendant's trial in an attempt to create a reasonable doubt that defendant had robbed Santana. At issue was whether the trial judge abused his discretion by precluding defendant's proffer of exculpatory evidence to establish a reasonable doubt that someone else could have committed the crime charged. The court held that the exculpatory evidence could have been admitted where defense counsel could have presented the jury with the facts of the Artisans' Robbery and photographs of Blevins or where defense counsel could have presented the jury with the facts of the Artisans' Robbery and then have Blevins identified in court as an exhibit to avoid the concern that Blevins might invoke his Fifth Amendment right not to incriminate himself. The court held that if the trial judge had employed either of those methods, the probative value of the relevant evidence would not have been substantially outweighed by the dangers of confusion of the issues or misleading the jury. Accordingly, the court held that the evidence was admissible and reversed and remanded for a new trial. View "Watkins v. State" on Justia Law

Defendant appealed his sentence from convictions of two counts of assault in the second degree, two counts of possession of a firearm during the commission of a felony (PFDCF), and one count of reckless endangering in the first degree. At issue was whether the trial court erred by imposing a more severe sentence than recommended under the relevant Sentencing Accountability Commission (SENTAC) Benchbook guidelines. The court held that the record reflected that defendant was fully aware that the Superior Court was not bound by the state's sentence recommendations, and that he had been twice advised that by pleading guilty, he faced a maximum sentence of seventy-one years of incarceration. The court also held that, where the sentencing judge imposed a harsher sentence than those recommended by the SENTAC Benchbook guidelines, the sentences were neither illegal or an abuse of discretion. Therefore, the court affirmed the judgment of the Superior Court. View "Wynn v. State" on Justia Law

Appellant appealed a termination decision by appellees (collectively, "Panel") after the Panel unanimously voted at a public hearing to terminate appellant's employment as Chief of Police. At issue was whether the Superior Court erred in holding that the votes of the remaining Panel members could cure the Panel's unlawful failure to recuse a biased member; whether the Superior Court erred in affirming the Panel's failure to provide appellant with the protections of Chapter 48 of the Police Department's rules and Regulations; and whether the Superior Court erred in concluding that the Panel provided appellant with sufficient notice of the grounds for the charges against him at the public hearing. The court held that appellant's testimony established a prima facie case of bias by a Councilman and the Panel's failure to recuse him could not be cured by votes of the remaining Panel members. Therefore, appellant's due process rights were violated. The court also held that because this ground for reversal was independently sufficient, the court declined to address appellant's other arguments. Accordingly, the judgment of the Superior Court was reversed and the case remanded for further proceedings. View "Sullivan v. Mayor & Council of The Town of Elsmere" on Justia Law

Defendant was convicted of conspiracy in the second degree where the jury found that defendant and his co-conspirator committed an overt act in pursuance of the conspiracy. At issue was whether the trial judge committed plain error by not, sua sponte, giving a specific unanimity instruction requiring the jury to determine unanimously which particular overt act was committed. The court held that, in light of conflicting authorities on the issue, defendant had not shown that the trial judge committed plain error in failing to give the instruction because the error complained of was not so clearly prejudicial to his substantial rights as to jeopardize the fairness and integrity of the trial process. Accordingly, the judgment was affirmed. View "Dougherty v. State" on Justia Law