Justia Delaware Supreme Court Opinion Summaries

Defendant was found guilty of Conspiracy to Commit First-Degree Murder, but acquitted of First-Degree Murder and Possession of a Firearm During the Commission of a Felony. Defendant appealed from the Conspiracy conviction, claiming that the Superior Court erred by denying his motion for a judgment of acquittal because the evidence was legally insufficient. The court held that a rational juror could infer from the evidence that defendant wanted a co-conspirator to retaliate, that he knew the co-conspirator intended to use a deadly weapon to accomplish that retaliation, and that the shooter (whether defendant or the co-conspirator) carried out the plan exactly as intended. Given those reasonable inferences from the evidence introduced at trial, a rational juror could have also concluded beyond a reasonable doubt that defendant conspired to commit First-Degree Murder. Accordingly, the judgment was affirmed. View "Lemons v. State" on Justia Law

Defendant appealed from his convictions for Reckless Burning, Burglary in the Third Degree, two counts of Criminal Trespass in the Third Degree, and three counts of Arson in the Second Degree. At issue was the trial judge's decision allowing a latent fingerprint examiner, who had also been trained in tire track and shoeprint analyses, to testify as an expert that boot and tire tracks at arson scenes were consistent with defendant's boot and tire on his mountain bike. The trial judge found the examiner to be qualified by his knowledge, skill, training, experience or education under Rule 702 of the Delaware Rules of Evidence. The court found no abuse of discretion and affirmed the judgment. View "Rodriguez v. State" on Justia Law

Defendant was convicted of First Degree Murder, sentenced to death, and subsequently appealed from the denial of his motion for postconviction relief under Superior Court Rule 61. On appeal, defendant raised eight claims of error. The eighth claim was that the trial court erred by refusing to grant defendant's motion to issue a material witness warrant. The court held that because many of defendant's claims were procedurally barred and the balance lacked substantive merit, the court affirmed the judgment. View "Taylor v. State" on Justia Law

Defendant was convicted of three counts of issuing a bad check greater than $1,000. On appeal, defendant contended that the trial judge erred by failing to grant a motion for a new trial after discovering that Juror No. 8 was a victim in a pending criminal case and by failing to conduct a sufficient post trial inquiry. The court held that when a juror serving on a criminal trial was an alleged victim of a crime and was contemporaneously represented by the Attorney General's office in the prosecution of the alleged perpetrator of the crime against the juror "victim," a mere inquiry by deposition into whether the jury knew the prosecutor or anyone in his office insufficiently probed the ability of that "juror/victim" to render a fair and objective verdict as a matter of law. Therefore, the court reversed and remanded. View "Knox v. State" on Justia Law

A jury found that defendant and a co-defendant had crashed through patio doors of the Warren family, shot and killed Kenneth Warren in front of his wife and their nineteen-month-old-son. For that crime, defendant was sentenced to death. On appeal, defendant contended that the trial judge erred in admitting the out-of-court statements of his co-defendant; defense counsel was ineffective in failing to investigate DNA issues; certain evidence demonstrated that defendant was innocent, or alternatively, that a new trial was required; defense counsel was ineffective in failing to rehabilitate prospective jurors or to object to the trial judge's dismissal of them; his death sentence was unconstitutional; and defense counsel was ineffective in failing to conduct an adequate mitigation investigation and to present that mitigation evidence to the trial judge and jury. The court held that defendant was not entitled to postconviction relief or a new trial where defendant's first claim was procedurally barred; defendant's second claim failed because he had not shown prejudice; defendant's third claim failed for the same reason; defendant's fourth claim failed because he had not shown that defense counsel's performance was deficient; defendant's fifth claim was procedurally barred; and defendant's sixth claim failed because he had not shown prejudice. Accordingly, the court affirmed the judgment. View "Swan v. State" on Justia Law

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

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