Justia Delaware Supreme Court Opinion Summaries

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

This appeal arose from a sexual assault complaint against a Delaware State Police Officer. After the officer, Joshua Giddings, arrested plaintiff-appellant Jane Doe for shoplifting, he threatened to throw her in jail unless she had sex with him. Doe filed suit against Giddings and the State of Delaware. Doe alleged that the superior court erred by: (1) granting the State's motion for summary judgment on sovereign immunity grounds; (2) denying Doe's motion for partial summary judgment on respondeat superior grounds; and (3) granting a motion to dismiss by Giddings' estate. The Supreme Court concluded after review that the State waived sovereign immunity, and therefore, the superior court erred in granting the State's motion for summary judgment. Furthermore, the Supreme Court concluded Doe's two other arguments were without merit. The case was affirmed in part, reversed in part, and the case remanded for further proceedings. View "Sherman 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

Defendant-Below, Appellant, Christopher Spence, appealed a Superior Court Order denying his Motion for a Mistrial. This case arose out of a shooting that occurred during an event at a party venue in Wilmington. During the shooting, Spence shot and killed Kirt Williams, and shot and wounded Kelmar Allen. Because Spence admitted to shooting Williams and Allen, the case centered on: (1) whether the State could prove each element of the indicted charges beyond a reasonable doubt; (2) whether Spence was guilty of lesser included offenses; and (3) whether Spence had a viable justification defense, either self-defense or defense of others. Moments before closing argument, the State provided defense counsel with a black and white copy of the PowerPoint presentation it intended to use during summation. The version of the PowerPoint presentation displayed to the jury was in color. At the end of closing arguments, Spence’s counsel moved for a mistrial based on the alleged instances of prosecutorial misconduct. The trial court reserved ruling on the motion until after trial. In the Motion and the Memorandum, Spence raised, for the first time, objections to: (1) two PowerPoint slides which referred to the victims as “helpless;” (2) PowerPoint slides containing alleged misstatements of the justification defenses; and (3) a PowerPoint slide containing the statement that “[t]he defendant is guilty of all the charges against him[.]” The trial court denied the Motion. After review, the Supreme Court affirmed the ultimate holding of the trial court “based largely upon the well-reasoned Order denying Spence’s Motion.” View "Spence v. Delaware" on Justia Law

Defendant-appellant Kesler Stevens appealed a Superior Court Opinion affirming a Court of Common Pleas bench trial verdict which found him guilty of Driving Under the Influence (“DUI”). On appeal to the Supreme Court, Stevens argued: (1) the trial court erred in denying his motion for judgment of acquittal because there was insufficient evidence to convict him of DUI; and (2) Delaware’s DUI law violated the Equal Protection Clause of the United States Constitution because it provided for a harsher punishment than Delaware’s Reckless Driving–Alcohol Related law even though both laws punish identical conduct. The Supreme Court found no merit to Stevens’ appeal and affirmed. View "Stevens v. Delaware" on Justia Law