Justia Constitutional Law Opinion Summaries

In response to the COVID-19 pandemic, the Governor of Delaware issued a series of emergency orders that included restrictions on religious services. These restrictions, which were lifted by June 2020, limited in-person worship to ten people and imposed various other mandates. Over 18 months later, two religious leaders filed suit in the Court of Chancery seeking injunctive relief against these restrictions, which were no longer in effect. The Court of Chancery dismissed the case for lack of subject matter jurisdiction, concluding that the plaintiffs could not demonstrate a reasonable apprehension of future harm.The plaintiffs then transferred their action to the Superior Court, seeking declaratory judgment and damages for alleged violations of their constitutional rights. The Superior Court dismissed the claims, ruling that the requests for declaratory relief were not justiciable because the restrictions had been lifted and there was no ongoing controversy. Additionally, the court found that the Governor was immune from the damages claims under the State Tort Claims Act and the doctrine of qualified immunity.On appeal, the Delaware Supreme Court affirmed the lower courts' decisions. The Court agreed that the plaintiffs failed to show a reasonable apprehension of future harm, which is necessary for injunctive relief. The Court also held that the plaintiffs' claims for declaratory judgment were not justiciable because there was no ongoing controversy and the alleged harm could not be redressed by a declaratory judgment. Finally, the Court upheld the Superior Court's finding that the Governor was immune from damages claims, as his actions were discretionary and taken in good faith during an unprecedented public health crisis. View "In re Covid-Related Restrictions on Religious Services" on Justia Law

In December 2017, Antoine Terry was found dead from multiple gunshot wounds in New Castle, Delaware. The police arrested Terry’s friend, Shaheed Matthews, for the murder. In 2019, Matthews was tried for murder and possession of a firearm during the commission of a felony. The State's case relied on circumstantial evidence, including evidence from Matthews’s cellphone, witness testimony, video camera footage, and gunshot residue found on Matthews’s jacket. Matthews was convicted and sentenced to life plus three years in prison.Matthews appealed his conviction, arguing that his trial counsel was ineffective for failing to move to suppress evidence obtained from his cellphone. The Superior Court denied Matthews’s motion, concluding that Matthews had provided valid consent for the search of his cellphone and that the cellphone evidence had no bearing on the outcome of the case. Matthews appealed this decision to the Supreme Court of the State of Delaware.The Supreme Court of the State of Delaware reversed the Superior Court's decision. The court found that Matthews did not provide valid consent for the search of his cellphone and that the warrant obtained by police to search Matthews’s cellphone was an unconstitutional general warrant. The court also found that the cellphone evidence was material and significant to the State's case. Therefore, the court concluded that Matthews’s trial counsel’s failure to move to suppress the evidence obtained from his cellphone constituted deficient performance and prejudiced Matthews. The court vacated Matthews’s convictions and remanded the case to the Superior Court for a new trial. View "Matthews v. State" on Justia Law

In 2019, Jose Terreros was left in charge of his girlfriend's children. Upon returning home, his girlfriend was informed by her four-year-old daughter that Terreros had sexually abused her. The girlfriend immediately asked Terreros to leave and called the police. She later discovered concerning web searches on Terreros's phone, which he had left behind, including queries about how long saliva and fingerprints remain on bodies and clothes, and whether police can detect if a child has been raped. Based on this, investigators obtained a warrant to search Terreros's phone. They searched his messages, messaging apps, photos, videos, internet search history, GPS coordinates, and incoming and outgoing calls without any date restrictions. On trial, Terreros was found guilty of Sexual Abuse of a Child and Dangerous Crime Against a Child, but not guilty of Rape First Degree. Terreros appealed his conviction, arguing that the warrant was overbroad and that the verdicts were inconsistent. The Supreme Court of the State of Delaware agreed with Terreros regarding the warrant, finding it to be a general warrant and thus unconstitutional. The court held that all evidence obtained from the phone should have been suppressed. The court also remanded the inconsistent verdicts issue back to the lower court for further consideration, as it had not been fully addressed by the State. The court reversed Terreros's convictions and remanded the case for further proceedings. View "Terreros v. State" on Justia Law

In the Supreme Court of the State of Delaware, defendant Kwesi Hudson, who was convicted of first-degree kidnapping, first-degree robbery, second-degree rape, and other crimes, appealed on two grounds. First, he challenged the Superior Court's decision to deny his pre-trial motion to exclude the State’s expert testimony on DNA mixture interpretation and technology. He argued that the STRmix software used to process the DNA was not scientifically reliable. Second, he contended that the Superior Court erred in denying his motion to suppress cell-site location information collected from cell tower dumps via ten search warrants. He claimed that these warrants violated his rights under the Fourth Amendment to the United States Constitution, Article I, Section 6 of the Delaware Constitution, and Delaware statutory law. The Supreme Court of the State of Delaware found Hudson’s challenges to be without merit and affirmed his convictions and the decisions of the Superior Court. The court ruled that the DNA evidence was reliable and admissible, and that a Daubert hearing to test its admissibility was not necessary. Additionally, the court concluded that the cell tower warrants were constitutional under the Fourth Amendment, as they were sufficiently particular and based on probable cause. View "Hudson v. State" on Justia Law

Defendant-appellant Larry Martin appealed the sentence he received after pleading guilty to one count of Stalking and two counts of Non-Compliance with Bond (“NCB”). The trial court entered its first sentencing order on August 12, 2022, followed by three corrected sentencing orders, entered on September 8, September 21, and October 17, 2022, respectively. It was undisputed that the trial court’s first sentencing order was illegal because it imposed a sentence that exceeded the maximum lawful sentence for Stalking, which was three years at Level V supervision. In an email dated August 29, 2022, Martin’s trial counsel informed the trial court of the illegality of the sentence, and that the State recommended that the trial court fix its error by redistributing Martin’s five-year prison sentence across the Stalking conviction and the two NCB convictions. In a corrected sentencing order, issued on September 8, 2022, the trial court reduced Martin’s sentence for Stalking to three years of incarceration at Level V supervision, to bring it in line with the lawful maximum sentence. The trial court then added one year of incarceration at Level V supervision, suspended for probation, to the suspended fines for each NCB conviction. It was undisputed that if this had been the original sentence, Martin’s sentence would have been lawful. Martin appealed the trial court’s sentencing order insofar as it modified his sentence for the NCB convictions, arguing that by increasing his sentence for the NCB convictions, the trial court effectively resentenced him for those convictions despite the fact that he had already served them. This was because those sentences consisted solely of fines that were suspended when imposed and as such, were completed as of the date of the sentence. According to Martin, he completed his sentence for both NCB convictions on August 12, 2022, and any subsequent resentencing was barred by principles of double jeopardy. The Delaware Supreme Court was not persuaded by this argument and affirmed the sentence imposed by the trial court in its September 8, 2022 sentencing order, as modified by the September 21, 2022 and October 17, 2022 sentencing orders. View "Martin v. Delaware" on Justia Law

After arresting Aaron Garnett in whose care were three young children, the police promptly sought to locate the children’s parent or guardian. This search, initiated before sunrise on a cold and rainy day, led the police to a house where they were told the children’s mother lived and was sleeping. Once there, the police knocked, then banged, on the front door and loudly announced their presence. When no one answered, one of the officers went to the rear of the house where, after another round of knocking and announcing, the officer noticed the back door was unlocked. He pushed open the unlocked door and, peering into the interior of the residence with the benefit of a flashlight, saw a motionless body under a blanket at the foot of a stairway. Joined now by fellow officers, he entered the residence and found the lifeless body of Naquita Hill, the mother of one of the children whose welfare had motivated the police’s visit. Seven or so hours later, Garnett confessed that, during a heated argument, he had choked Hill until she slumped to the floor and beat her with his fist after that. After a jury trial, Garnett was convicted of Naquita Hill’s murder. He appealed, but the Delaware Supreme Court found no reversible error and affirmed Garnett's conviction. View "Garnett v. Delaware" on Justia Law

Defendant-appellant Shamayah Thomas (“Thomas”) was convicted after a bench trial of Stalking and related acts of intimidation and harassment. Before his bench trial, Thomas filed a pro se Motion to Dismiss Current Counsel and/or to Appoint New Counsel on grounds that his then-current counsel was not following his instructions regarding his pretrial defense (the “First Motion to Dismiss Current Counsel”). Also before trial, Thomas’ counsel filed a motion to suppress digital evidence (the “Motion to Suppress”) collected from Thomas’s pink iPhone (“Pink iPhone”), alleging that law enforcement seized the phone without a warrant and, alternatively, that the search warrant issued following the seizure of the Pink iPhone (“Search Warrant”) was constitutionally defective. The trial court denied Thomas’ motion for new counsel pursuant to Superior Court Rule 47; the court granted in part, and denied in part, the Motion to Suppress, ultimately admitting certain evidence extracted from the Pink iPhone. After trial, but before his sentencing, Thomas filed a second motion to dismiss current counsel and/or appoint new counsel. Although the Superior Court prothonotary’s office failed to direct the second motion to dismiss counsel to defense counsel or to the trial judge, the trial court addressed the motion at Thomas’ sentencing hearing. Given the option of either delaying sentencing and proceeding pro se, or proceeding with his then-current counsel, Thomas chose to proceed with sentencing as scheduled, represented by his then-current counsel. On appeal, Thomas argued the Superior Court: (1) erred when it categorized the Pink iPhone Search Warrant as an overbroad warrant as opposed to an unconstitutional general warrant; and (2) failed to adequately address Thomas’ Motions to Dismiss Counsel. Thomas asked the Delaware Supreme Court to reverse his convictions and remand for a new trial. Finding no reversible error, the Supreme Court affirmed the trial court. View "Thomas v. Delaware" on Justia Law

In 2013, defendant-appellant Darnell Martin received an unconditional gubernatorial pardon for his previous criminal convictions, which included several felony convictions. Several years later, Martin was arrested and charged with new offenses. After his convictions for those charges were affirmed on direct appeal, he filed a motion for postconviction relief, arguing that his trial counsel was ineffective. More than two years passed as the parties briefed Martin’s motion and the trial court considered it. During that time, Martin served his prison sentence and his term of probation. He was discharged from probation while the postconviction motion was under advisement with the Superior Court. After Martin’s probation was discharged, the Superior Court dismissed his postconviction motion as moot, concluding that he no longer was “in custody” as required by Rule 61(a) and, given his extensive criminal history, he would not suffer any collateral consequences as a result of the convictions he was challenging. When the Superior Court dismissed the motion, it was not aware that Martin’s previous convictions had been pardoned. Martin appealed, and the Delaware Supreme Court remanded to the Superior Court to further consider the effect of Martin’s pardon, including whether a pardoned defendant suffers collateral consequences in the same manner as a first-time felon and therefore should not have his postconviction motion mooted if he is released from custody before the motion is resolved. The Superior Court concluded the collateral consequences doctrine, which the Supreme Court adopted more than 50 years ago based on United States Supreme Court precedent, has no continuing application in postconviction proceedings in Delaware. Martin’s appeal then returned to the Supreme Court, where he again challenged dismissal of his motion and the Superior Court’s application of the mootness doctrine. Having carefully considered the Superior Court’s decision and the parties’ submissions, the Delaware Supreme Court concluded the Superior Court erred in dismissing Martin’s postconviction motion as moot. View "Martin v. Delaware" on Justia Law

In 2019, Tyrese Burroughs was convicted of felony drug dealing. As one consequence of that conviction, Burroughs was, from then on, prohibited from possessing a firearm or ammunition. According to an affidavit of probable cause, on November 25, 2020, police caught Burroughs engaging in a hand-to-hand drug transaction while in possession of a “Smith and Wesson Walther .380 firearm loaded with seven live rounds.” Burroughs was arrested and charged with six felonies, relevant here: possession of a firearm during the commission of a felony, possession of a firearm by a person prohibited, possession of ammunition by a person prohibited, two counts of drug dealing, carrying a concealed deadly weapon. Together, these charges carried a minimum-mandatory of eight years and a statutory maximum of 77 years in prison. Burroughs filed a “Motion for Modification of Bail,” in which he requested, “[d]ue to his inability to post bail, . . . that his bail be converted to an unsecured or lower secured amount.” The State argued his financial conditions of release should be maintained because, in its view, there was strong evidence supporting his conviction and ample facts demonstrating that he posed a serious safety risk to the public. Burroughs filed a “Motion for Review of Commissioner’s Order,” arguing that the Commissioner erred by failing to test his motion under the strict-scrutiny standard of review on the grounds that he either fell into a suspect class by virtue of his indigency or that his pretrial detention deprived him of his fundamental liberty right under substantive-due-process principles. If the Commissioner had properly conducted a strict-scrutiny review, Burroughs contended, then the State would have had to prove by clear and convincing evidence that “no other non-monetary conditions of release [could] accomplish” its “compelling interest in preventing crime.” The Delaware Supreme Court was asked to decide whether, in light of Delaware's constitutional right to bail, it was permissible to attach unaffordable financial conditions to a dangerous defendant’s pretrial release on bail and, if it was, what procedural protections had to be observed when such bail is considered. The Court responded: (1) strict scrutiny, answering in the affirmative; and (2) the determination to set cash bail had to be supported by clear and convincing evidence that: the defendant is a flight risk or poses a substantial risk to the community and nonmonetary conditions of release would not alleviate that risk. Because these answers were consistent with, and yielded the same result as, the Superior Court’s decision on appeal, the Supreme Court affirmed. View "Burroughs v. Delaware" on Justia Law

The issue in this appeal was the prosecution’s use of Khalif Watson’s prior felony convictions during cross-examination and in closing argument. The admissibility of the convictions was not at issue. Instead, Watson contended his conviction on weapons and resisting-arrest charges could not stand because the prosecutor asked him questions about his prior convictions that he had already answered on direct examination and then argued those convictions showed his propensity to possess weapons. Both of those tactics, appellant argued, were not only objectionable (though the appellant did not object in real time), but also amounted to prosecutorial misconduct so clearly prejudicial to his substantial rights that the Delaware Supreme Court should reverse his convictions. After review, the Supreme Court affirmed. “The questions the prosecutor asked on cross-examination, while arguably objectionable as cumulative, did not amount to prosecutorial misconduct. And even if we were to accept Watson’s characterization of the prosecution’s use of his prior convictions, he has failed to persuade us that the ensuing error was so clearly prejudicial of his rights as to compromise the fairness and integrity of his trial.” View "Watson v. Delaware" on Justia Law