Justia Delaware Supreme Court Opinion Summaries

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

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

The State of Delaware ("State") filed an habitual driving offender petition in the Court of Common Pleas against respondent under Chapter 28 of Title 21 of the Delaware Vehicle Code. Hours after declaring respondent an habitual offender, the Court of Common Pleas, sua sponte, vacated its earlier judgment, holding that the State's exercise of prosecutorial discretion in respondent's case was inconsistent with the State's prosecution of other habitual driving offender petitions heard that same day. At issue was whether the Court of Common Pleas erred in vacating its earlier order declaring respondent an habitual driving offender. The court held that the Court of Common Pleas had no legal basis to conclude that respondent was not an habitual driving offender where the statutory requirements for habitual driving offender status had all been established. The court also held that the Court of Common Pleas erred in finding the State's refusal to offer a continuance to respondent constituted a legal "wrong" where the state was not required to request a continuance in each and every habitual driving offender prosecution. The court further held that the Court of Common Pleas erroneously relied on Court of Common Pleas Civil Rules 60(b)(3) and 60(b)(6) as a basis to remedy the State's "misrepresentations." The court finally held that nothing in Court of Common Pleas Civil Rule 11 suggested that the trial court could vacate an earlier order, thereby resulting in a dismissal of the proceeding, as sanction for a party's alleged violation of that rule.

Defendant was convicted of first degree murder and appealed a superior court judge's denial of his second motion for postconviction relief. At issue was whether the sidebar commentary defendant's counsel made to the trial judge during a pretrial hearing created an unlawful "appearance of impropriety," violated defendant's due process rights, and denied his Sixth Amendment right to counsel. The court held that the relevant circumstances did not disclose any "appearance of impropriety" sufficient to reverse the judgment and grant a new penalty phase where the court did not find an unacceptable risk that a reasonable observer would believe that bias influenced the trial judge. The court also held that the superior court judge did not violate defendant's due process rights where there was no evidence proving reliance on counsel's remarks. The court further held that defendant was not denied his Sixth Amendment right to counsel where there was no "complete" failure of counsel and defendant failed to establish actual prejudice sufficient to warrant relief. Accordingly, the judgment of the superior court was affirmed.

Defendant was charged with nineteen counts in a final re-indictment related to charges of attempted murder, reckless endangering, firearm charges related to attempted murder charges, aggravated menacing by a firearm, aggravated intimidation of a witness, criminal solicitation, disregarding a police officer, resisting arrest, and reckless driving. At issue was whether the trial judge abused his discretion when he decided that a single complaint by the jury during trial, that some members had difficulty hearing one videotaped section 3507 statement, justified departure from the general default rule that such statements did not go into the jury during deliberations. The court held that the jury certainly should not be permitted to "work through" the recorded section 3507 statement during their deliberations until it was understandable and the undue emphasis placed upon the section 3507 evidence by its unwarranted admission into the jury's deliberative process was not harmless beyond a reasonable doubt. Therefore, the court reversed the judgment and remanded for a new trial.

Defendant appealed a conviction for driving under the influence of alcohol when she was arrested by police officers and performed field sobriety tests. At issue was whether defendant's motion to suppress intoxilyzer test results was erroneously denied where defendant asserted that her success on the field sobriety tests constituted "overwhelming evidence" that she was not impaired by alcohol. The court held that the motion was properly denied where the Superior Court applied a proper totality of the circumstances analysis in deciding to deny the motion and where the performance results of field sobriety tests could either eliminate or elevate suspicion into probable cause but had insufficient evidentiary weight to eliminate probable cause that was already established by the totality of the circumstances before the tests were performed.

Defendant-Appellant Hubbard appeals the lower courtâs denial of his motion to suppress his custodial statement, arguing that his waiver of Miranda rights was not knowing, intelligent or voluntary. Defendant was convicted on twelve offenses, including attempted murder, carjacking, conspiracy and possession of a deadly weapon. He was sentenced to twelve life terms. Defendant argues that he was not able to âfully comprehend the nature of his Miranda rights and the consequences of abandoning those rightsâ because he was âdrunk and high.â On review of the interrogation transcript, the Court held that Defendant made an express waiver of his Miranda rights by his words and actions, and that Defendantâs motion to suppress was properly denied.