Justia Delaware Supreme Court Opinion Summaries

Prior to sentencing, defendant Jerry Reed sought to withdraw his guilty plea, but his counsel refused to file a motion to do so, apparently under the belief that no grounds justifying a plea withdrawal were present. The Superior Court refused to consider his pro se motion because he was represented by counsel. As Reed put it, he became stuck in a Catch-22 due to the operation of two Superior Court Criminal Rules. The Delaware Supreme Court held that a criminal defendant’s control of the objectives of the representation prior to sentencing required counsel either obey an instruction to file a motion to withdraw a guilty plea, or seek leave to withdraw so that the defendant could file the motion with other counsel or pro se. Because the factual record in this case was incomplete, and because some of the Superior Court’s factual findings were not supported by the record, the Supreme Court reversed and remanded for additional fact-finding necessary to determine whether Reed’s claims for ineffective assistance of counsel had merit. View "Reed v. Delaware" on Justia Law

In 2019, Jason White was convicted of eight crimes related to possessing and dealing narcotics. White filed a timely direct appeal, arguing that the Superior Court abused its discretion by allowing the State to admit text messages without proper authentication, and that the prosecutor made improper comments during his rebuttal summation by misstating the burden of proof, denigrating the role of defense counsel, and vouching for evidence. Having reviewed the parties’ briefs and record on appeal, and after oral argument, the Delaware Supreme Court affirmed the Superior Court’s judgment: the State provided sufficient evidence to authenticate the text messages, and the prosecutor did not make improper remarks warranting reversal during his rebuttal summation. View "White v. Delaware" on Justia Law

Appellant Joseph Hurley represented Clay Conaway, a former college athlete charged with raping six women. After the case attracted media attention, the Superior Court entered an order prohibiting counsel from making public comments except to the extent permitted under Rule 3.6 of the Delaware Lawyers Rules of Professional Conduct (“DLRPC”). Hurley twice spoke to reporters while the order was in force. The court held that both sets of comments violated the order and found Hurley in civil contempt of court. On appeal, Hurley argued the Superior Court erred by holding that there was a substantial likelihood his comments would materially prejudice pending proceedings. Finding no reversible error, the Delaware Supreme Court upheld the contempt order. View "In re Joseph Hurley, Esq." on Justia Law

Appellant Kili Mayfield was convicted at a bench trial of Rape in the First Degree (two counts), Rape in the Second Degree (four counts), Kidnapping in the First Degree (one count), Strangulation (one count), and Assault in the Third Degree (one count). In pre-trial proceedings, he was initially represented by counsel from the Public Defender Division of the Office of Defense Services. Several months before trial Mayfield filed a motion indicating he wished to waive his right to counsel and proceed pro se. The Superior Court held a hearing and granted the motion. On appeal, Mayfield did not dispute that the Superior Court committed no error in granting his motion to waive counsel and proceed pro se. At a conference held the day before his scheduled trial date, however, Mayfield informed the trial judge for the first time that he had decided that representing himself was not in his best interest. He requested time to retain private counsel. In the alternative, he requested that the Public Defender’s Office be reappointed to represent him at trial. After fully considering Mayfield’s requests, the judge determined that granting either request would necessitate a trial delay. He also determined that the trial should go forward as scheduled the next day, that the continuance that either of Mayfield’s requests would entail should be denied, and that his request for counsel should, therefore, be denied. The trial did commence the next day, with Mayfield representing himself. Mayfield claimed on appeal the trial judge’s denial of his request for reappointment of the Public Defender’s Office to represent him at trial violated his Sixth Amendment right to assistance of counsel. Finding no reversible error, the Delaware Supreme Court rejected Mayfield’s claim and affirmed the Superior Court judgment. View "Mayfield v. Delaware" on Justia Law

Murad Diggs was convicted of possession of a firearm and ammunition by a person prohibited. In his direct appeal to the Delaware Supreme Court, Diggs claimed the Superior Court erred when it denied his motion to suppress the evidence seized from him - the firearm and ammunition - following an investigative detention and frisk that was, in Diggs’s view, unsupported by reasonable suspicion. More specifically, Diggs challenged the court’s conclusion that the tip upon which the police were acting came from a “citizen informant” and therefore was presumptively reliable. Diggs also contended the Superior Court’s suppression-hearing factual determinations were flawed because the court failed to draw a “lost and/or missing evidence” inference as a result of the police’s failure to collect and preserve certain evidence. Although the Supreme Court agreed, in part, with Diggs’s criticism of the Superior Court’s “citizen-informant” analysis, it disagreed with his conclusion that his seizure was not supported by sufficient reasonable suspicion. Likewise, the Court rejected Diggs’s contention that the Superior Court’s failure to draw an adverse inference against the prosecution - an inference that Diggs did not urge the court to draw at trial - was plainly erroneous. Hence, the Court affirmed the Superior Court judgment. View "Diggs v. Delaware" on Justia Law

Appellant Laura Allen appealed a Family Court Ancillary Order determining the division of property following her divorce from Appellee Charlene Scott. Allen claimed the trial court abused its discretion in designating funds used to purchase real property in Colorado as “marital” because the parties’ Ancillary Pretrial Stipulation described the funds as “premarital.” Allen further contended the Family Court abused its discretion in dividing certain pieces of marital property in the marital estate 60/40 in Scott’s favor contending that the court’s decision was not based on a logical or orderly process and was tainted by the court’s error on the first issue. After review, the Delaware Supreme Court held: (1) because both parties stated in the Ancillary Pretrial Stipulation that the funds used to purchase the Colorado property were premarital in character, and because neither party moved to amend the stipulation to revise that characterization until after the evidentiary record had closed, there was no triable issue on that question; and (2) there was no abuse of discretion in the Family Court’s distribution of the remaining marital property. Judgment was reversed and the matter remanded for consideration of Scott’s alternative contention that the down payment for the Colorado property was a gift unto the marriage. The Family Court retains the discretion to adjust that distribution to the extent its decision on remand regarding the Colorado down payment funds affects the other 11 Del. C. 1315 factors. View "Allen v. Scott" on Justia Law

Appellant Kili Mayfield was convicted at a bench trial for two counts of first-degree rape, four counts of second-degree rape, one count of first-degree kidnapping, one count of strangulation, and one counts of third-degree assault. In pre-trial proceedings, he was initially represented by counsel from the Public Defender Division of the Office of Defense Services. Several months before trial, Mayfield filed a motion indicating he wished to waive his right to counsel and proceed pro se. The Superior Court held a hearing and granted the motion. On appeal, Mayfield did not dispute that the Superior Court did not err in granting his motion to waive counsel and proceed pro se. At a conference held the day before his scheduled trial date, however, Mayfield informed the trial judge for the first time that he had decided that representing himself was not in his best interest. He requested time to retain private counsel. In the alternative, he requested that the Public Defender’s Office be reappointed to represent him at trial. After fully considering Mayfield’s requests, the judge determined that trial should go forward as scheduled the next day, that a continuance should be denied, and that his request for counsel should, therefore, be denied. The judge noted that Mayfield had been "vigorous" in his own defense, his filings showing he had "gone through all the discovery materials and prepared himself." The court concluded, “Mayfield’s request and the basis for his request are not outweighed by the other prejudice that would be visited by a continuance.” Mayfield’s bench trial began as scheduled the next day and resulted in the aforementioned convictions. The Delaware Supreme Court affirmed, finding the Superior Court acted within its discretion when it denied Mayfield’s request for counsel and a continuance. View "Mayfield v. Delaware" on Justia Law

The two equal stockholders of UIP Companies, Inc. were deadlocked and could not elect new directors. One of the stockholders, Marion Coster, filed suit in the Court of Chancery and requested appointment of a custodian for UIP. In response, the three-person UIP board of directors — composed of the other equal stockholder and board chairman, Steven Schwat, and the two other directors aligned with him— voted to issue a one-third interest in UIP stock to their fellow director, Peter Bonnell, who was also a friend of Schwat and long-time UIP employee (the “Stock Sale”). Coster filed a second action in the Court of Chancery, claiming that the board breached its fiduciary duties by approving the Stock Sale. She asked the court to cancel the Stock Sale. After consolidating the two actions, the Court of Chancery found what was apparent given the timing of the Stock Sale: the conflicted UIP board issued stock to Bonnell to dilute Coster’s UIP interest below 50%, break the stockholder deadlock for electing directors, and end the Custodian Action. Ultimately, however, the court decided not to cancel the Stock Sale. The Delaware Supreme Court reversed the Court of Chancery on the conclusive effect of its entire fairness review and remanded for the court to consider the board’s motivations and purpose for the Stock Sale. "If the board approved the Stock Sale for inequitable reasons, the Court of Chancery should have cancelled the Stock Sale. And if the board, acting in good faith, approved the Stock Sale for the 'primary purpose of thwarting' Coster’s vote to elect directors or reduce her leverage as an equal stockholder, it must 'demonstrat[e] a compelling justification for such action' to withstand judicial scrutiny." View "Coster v. UIP Companies, Inc." on Justia Law

Appellant, Concerned Citizens of the Estates of Fairway Village, was an unincorporated association composed of people who own property in Fairway Village (the “Community”), a planned residential community located in Ocean View, Delaware. Appellants Julius and Peggy Solomon, Edward Leary, Kenneth and Denise Smith, and Terry and Carmela Thornes (collectively, the “Homeowners”) owned properties in the Community and were members of Concerned Citizens of the Estates of Fairway Village. Appellee Fairway Cap, LLC was the Community's developer. Demand for vacant townhomes in the Community was weaker than the developers expected. In the winter of 2016, Fairway Cap, LLC hired a real estate consultant who recommended converting unsold townhome lots into a rental community. Fairway Cap, LLC accepted the advice, secured funding, and began working on the rental properties. Appellee Fairway Village Construction, Inc. was an entity involved in the construction. The Homeowners discovered the plan after seeing an advertisement for “The Reserve at Fairway Village,” a forthcoming rental community. The Homeowners raised various objections to the rental community, including that the proposed units did not conform with existing dwellings and would lower property values. The Town of Ocean View and Fairway Cap, LLC rejected all the objections, concluding that the planned construction complied with the housing code and was allowed under the Community’s governing documents. This appeal presented two questions for the Delaware Supreme Court's review: (1) whether the Court of Chancery erred by holding that the Community’s governing documents allowed the developer to build rental properties; and (2) whether the Court of Chancery erred by awarding damages for a wrongful injunction after releasing the bond posted with the court. Finding no reversible error, the Supreme Court affirmed the Court of Chancery's judgment. View "Concerned Citizens of the Estates of Fairway Village v. Fairway Cap" on Justia Law

In January 2006, two armed assailants fatally shot Tameka Giles in the back after a botched robbery attempt while she was walking with her husband. After multiple police interrogations in the two years following the murder, Ronald Harris repeatedly told police he knew nothing about the crime and had not been involved. But on the eve of trial and after jury selection, Harris was offered and accepted a plea deal in exchange for testimony against Mark Purnell. Purnell’s court-appointed trial attorney was the same advocate who represented Dawan Harris in a weapons prosecution earlier in the murder investigation. The trial judge did not permit him to withdraw when he brought the conflict to the State’s and court’s attention. Trial counsel failed to investigate evidentiary leads implicating Dawan Harris, did not call him as a witness, and failed to present even then-known or obvious evidence and argument to the jury that would have inculpated his former client. The jury convicted Purnell of Second Degree Murder and all other charges after more than a day of deliberation, and he was sentenced to forty-five years of unsuspended Level V incarceration. In 2009, based on narrow issues presented to the Delaware Supreme Court (which did not include the conflict), his conviction and sentence were upheld. Following the denial of his direct appeal, Purnell filed a pro se Rule 61 motion raising ten grounds for relief, of which the first was an objection to his trial counsel’s conflict of interest. Postconviction counsel filed an amended motion asserting only three grounds, and did not include the conflict claim. The Superior Court denied Purnell’s motion and, again without having the conflict brought to the Supreme Court's attention, the Supreme Court affirmed that denial in 2014. Because postconviction counsel died a few weeks prior to oral argument before the Supreme Court in 2014, it was unknown why the conflict issue was not included in the amended motion. Due to that omission, the conflict claim went before the Supreme Court as one of Purnell’s grounds in an untimely, successive Rule 61 motion. "Ordinarily, having clarified the standards for newness and persuasiveness necessary for relief, we would remand the matter to the Superior Court for an evidentiary hearing and a decision guided by those rulings. But because Purnell has spent more than fourteen years in prison for murder based on a manifestly unfair trial and conviction, and based on his new evidence, viewed as a part of the entire evidentiary record, we are convinced that in this extraordinary case remand for an evidentiary hearing would serve no useful purpose. Instead, we reverse and remand for a new trial." View "Purnell v. Delaware" on Justia Law