Justia Delaware Supreme Court Opinion Summaries

Eric Lloyd was convicted by jury of six felonies stemming from his involvement in a Wilmington drug dealing enterprise. The Superior Court sentenced Lloyd to an aggregate of thirty years of incarceration without the possibility of early release. On appeal, Lloyd challenged his convictions and sentence, contending: (1) the trial court erred when it denied his motion to sever his case from that of co-defendant Dwayne White; (2) the trial court erred when it denied his motion for a mistrial after an eyewitness to a shooting misidentified Lloyd as the gunman; (3) the trial court should not have admitted gun evidence seized from a co-defendant’s apartment and rap music videos created by other enterprise members; (4) the trial court erred by allowing testimony from Lloyd’s former attorney’s secretary about a drug transaction. Finally, Lloyd argued the trial court violated his rights under the Eighth Amendment by imposing consecutive sentences, resulting in thirty years of incarceration, without the option for early release. Finding no merit to these claims, the Delaware Supreme Court affirmed Lloyd's convictions. View "Lloyd v. Delaware" on Justia Law

In 1994, the Delaware General Assembly enacted a statute, applicable to both criminal and civil proceedings, that eased the evidentiary burden on the proponent of controlled-substance-testing evidence. The statute, "Subchapter III," allowed for the admission of, and a favorable presumption relating to, written reports from a forensic toxicologist or forensic chemist, without the necessity of their appearance in court, so long as the report complied with certain requirements. After Stephen Hairston was indicted on several criminal offenses, including serious drug offenses, he served a written demand on the State, which, by the unambiguous terms of the statute, required the presence at trial of, among other individuals, the officer who seized and packaged the substances that formed the basis of Hairston’s drug offenses. Upon the State’s pretrial motion in limine, however, the Superior Court, believing that the seizing and packaging officer was unavailable, relieved the State of its obligation to produce him and permitted another officer who was present at the scene of Hairston’s apprehension to appear in the seizing and packaging officer’s stead. The Superior Court’s ruling, according to Hairston, erroneously relieved the State of a mandatory statutory duty and violated Hairston’s rights under the Confrontation Clause of the Sixth Amendment of the United States Constitution. The Delaware Supreme Court held the Superior Court’s interpretation of the statute in question was erroneous as a matter of law and that, absent the appearance of the witness identified in Hairston’s demand, it was error for the court to admit the forensic chemist’s report and testimony. Judgment was reversed and the matter remanded for further proceedings. View "Hairston v. Delaware" on Justia Law

Walter Hines appealed his conviction and sentence for second-degree assault, possession of a deadly weapon during the commission of a felony (“PDWDCF”), and two counts of endangering the welfare of a child (“EWC”). Hines’s issue on appeal related to an incident that occurred on September 27, 2018. At that time, Hines lived with Valeah Lewis, her mother Juliann Congo, and Lewis’s children D.L. and T.L. Michael Gibbs was Lewis’s ex-boyfriend and was D.L.’s father. As Lewis and Hines were leaving for work, Gibbs and his girlfriend, Putrice Barnes, arrived at the Lewis residence to pick up D.L. After a verbal exchange, Hines and Lewis drove a short way down the street then stopped. Barnes testified that she “flipped the bird” as Lewis drove past. Hines, Lewis, Barnes, and Gibbs all agree that an altercation ensued shortly thereafter, but their accounts differ regarding the key details. Lewis asserted that Gibbs swung a tire iron at Hines, while Hines asserted Gibbs did not take the tire iron from Barnes but instead tried to punch him. Both Hines and Lewis agreed Hines retrieved a baseball bat from the back seat and used it defensively against Gibbs in response to Barnes’s and Gibbs’s aggression. On appeal, Hines claimed the Superior Court committed plain error when it permitted the State’s final cross-examination question about his prior convictions for Possession with Intent to Deliver a Controlled Substance (“PWID”) and Possession of a Firearm by a Person Prohibited (“PFBPP”). Finding no reversible error, the Delaware Supreme Court affirmed Hines' convictions. View "Hines v. Delaware" on Justia Law

In 1996, two masked and camouflaged men crashed through the glass patio door of Kenneth Warren’s home. Warren was fatally shot in front of his wife and child during the subsequent struggle. Tina Warren, Kenneth’s wife, observed one assailant appeared to have been shot in the shoulder. The investigation went cold until Bridget Phillips, ex-wife of co-defendant Adam Norcross, contacted Delaware State Police in 1999. She explained that Norcross and appellant Ralph Swan had planned to rob a house, but found it occupied. Phillips added that the victim fired a shot and died because he tried to play hero. Police arrested Norcross and Swan in 2000. Both were indicted on three counts of first degree murder; one count of first degree robbery; one count of first degree burlgary; one count of second degree conspiracy; and multiple counts of possession of a deadly weapon during the commission of a felony. Swan was ultimately convicted on all charges, for which he was sentenced to death. Swan obtained new counsel and first filed for postconviction relief under Superior Court Criminal Rule 61 in 2006. He lodged several additional post-conviction motions, including applying for habeas relief. Final memoranda were filed in 2020; on February 21, 2020, the Superior Court denied Swan's motion for postconviction relief. The Delaware Supreme Court concluded, after review of the procedural history of this case, that the Superior Court did not abuse its discretion by denying Swan's motion for postconviction relief, nor did it err in denying a motion for the Superior Court judge to recuse. Thus, the Court affirmed the Superior Court's judgment. View "Swan v. Delaware" on Justia Law

After Harold Daniels pled guilty to driving under the influence of alcohol, the Superior Court sentenced him to a mandatory term of imprisonment as a third-time offender. The court based its finding that Daniels had committed two prior offenses, in part on its determination that Daniels had been convicted in New Jersey in 2012 under a statute that was “similar” to Delaware’s driving-under-the-influence statute. On appeal to the Delaware Supreme Court, Daniels argued that, because the New Jersey statute under which he was convicted prohibited conduct that was not against the law in Delaware — permitting another person to operate a vehicle while under the influence — the Superior Court erred by counting the New Jersey conviction against him. To this, the Supreme Court agreed with Daniels and vacated his sentence. View "Daniels v. Delaware" on Justia Law

Dai'yann Wharton was found guilty after a bench trial on several charges, led by a count of first-degree murder for the death of Yaseem Powell. Wharton appealed, contending her conviction should have been reversed because the State identified a group of highly incriminating text messages less than two weeks prior to trial, though the messages themselves had been contained in a digital discovery disclosure made by the State to Wharton more than a year earlier. Because of the State’s earlier disclosure, and because the Delaware Supreme Court rejected Wharton’s assertions that the State engaged in any discovery violations or other misconduct, it held the superior court was within its discretion to deny Wharton’s motion to exclude the text messages. Accordingly, Wharton's conviction and judgment of sentence were affirmed. View "Wharton v. Delaware" on Justia Law

As Delaware State Police (“DSP”) Trooper Brian Holl was on patrol in Kent County, he received a call from DSP Detective Thomas Macauley, a member of a “drug task force” in New Castle County. Detective Macauley’s and his brother Detective Michael Macauley’s were involved in a wiretap investigation known as “Operation Cutthroat.” Detective Thomas Macauley told Trooper Holl that the task force had been surveilling a blue Mazda that was, at the time of the call, southbound on Delaware State Route 1 heading towards Kent County. Detective Macauley shared with Detective Holl the reason for the surveillance of the Mazda: the surveilling officers had just “watched a drug transaction” between the occupants of the car and one of Operation Cutthroat’s targets. Because the Macauleys wished to maintain the secrecy of the ongoing wiretap investigation, they enlisted Trooper Holl’s assistance in the apprehension of the blue Mazda’s occupants. Detective Macauley’s instructions to Trooper Holl were: "To keep the integrity of the investigation of the wiretap investigation, I need a traffic stop. That means you need to . . . develop your own probable cause and go from there. Nothing about the wiretap can be revealed, obviously, for the integrity of the investigation." Trooper Holl believed he found one: according to his Affidavit of Probable Cause, the Mazda’s headlights were not activated despite “inclement weather.” Because of the perceived headlight infraction, Trooper Holl initiated a motor vehicle stop by activating his emergency lights. The stop lead to defendant Thomas Gordon's arrest, ultimately on drug trafficking-related charges. The issues this case presented for the Delaware Supreme Court's review centered on the "collective knowledge" doctrine, and whether the trial court’s consideration of the lawfulness of a warrantless detention and arrest was constrained by the facts alleged in a later filed arrest-warrant affidavit. The Supreme Court held that the trial court applied the correct legal standard when it determined that based on the collective knowledge of the officers involved, Trooper Holl had a reasonable suspicion the car in which defendant was traveling contained contraband, and was therefore subject to detention. In making this determination, the court did not err by considering facts extraneous to the subsequently filed arrest-warrant affidavit. View "Gordon v. Delaware" on Justia Law

Appellant-defendant John Trala was convicted by jury of driving under the influence. Trala contended the trial court erred in denying his motion for a mistrial after the State, in its rebuttal argument, asserted that defense counsel’s lack of evidentiary objections to certain witness testimony relating to Trala’s blood chemical analysis suggested that defense counsel had acknowledged the reliability of that incriminating evidence. He also claimed he was denied a fair trial because the prosecutor, in a rebuttal remark, expressed her favorable personal opinion as to the credibility of the arresting officer who was a key witness for the State. The Delaware Supreme Court determined the jury specifically found two independent theories of liability to support the same DUI charge. In light of that dual holding, which the Court found was supported by overwhelming evidence, any error arising from the prosecutor's misconduct was harmless. The Court therefore affirmed appellant's conviction. View "Trala v. Delaware" on Justia Law

Dwayne White faced a lengthy sentence of incarceration at Level V, followed by various levels of probation after a jury convicted him of twenty-one felony charges. On appeal, White challenged his conviction and sentence on a number of grounds that were not raised in the proceedings below. Before the Delaware Supreme Court, White contended: (1) several of the counts of which he was convicted and separately sentenced merged under the Double Jeopardy Clauses of the Delaware and United States Constitutions; (2) the trial court committed plain error by placing the accomplice liability instructions at the end of the instructions for the felony conspiracy offenses; (3) his conviction for conspiracy to commit Drug Dealing Cocaine was invalid because it relied on an indictment containing a numbering error; (4) the trial court erred by failing to bar the State from eliciting testimony from White’s attorney regarding the scope of the attorney’s representation of members of the criminal enterprise; and (5) the trial court abused its discretion by failing to specify adequately its reasons for imposing a sentence in excess of the SENTAC guidelines and by relying upon certain factual predicates which he challenges on various grounds. Finding no reversible error, the Supreme Court affirmed White's conviction. View "White v. Delaware" on Justia Law

Appellant Reginald Waters appealed his convictions for various offenses relating to the death of Clifton Thompson. According to Waters,the Superior Court erred in three ways: (1) in applying an incorrect legal standard when considering his motion for a new trial and improperly denied the motion; (2) in denying his motion to exclude certain prison phone calls that were obtained in violation of his Fourth Amendment rights; and (3) in denying a continuance of his trial to allow his counsel time to review certain evidence, which compromised his right to a fair trial. The Delaware Supreme Court found the Superior Court did not abuse its discretion by denying Waters’ motion for a new trial. Nor did the court err in allowing the prison phone calls to be used at trial. Lastly, the Supreme Court determined the trial court did not abuse its discretion by denying Waters’ continuance of trial. Therefore, judgment was affirmed. View "Waters v. Delaware" on Justia Law