Justia Constitutional Law Opinion Summaries

Articles Posted in Delaware Supreme Court
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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

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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

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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

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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

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Following a bench trial, A.J. McMullen was convicted of Murder in the First Degree and Possession of a Firearm During the Commission of a Felony (“PFDCF”). McMullen appealed his convictions, arguing the superior court improperly admitted cumulative statements from witnesses pursuant to 11 Del. C. 3507, and that the superior court’s verdict was supported by insufficient evidence identifying McMullen as the shooter who took the victim’s life. After review of the record, the Delaware Supreme Court found no merit in either of McMullen’s claims of error. Accordingly, the Court affirmed the superior court’s decisions and judgment of conviction. View "McMullen v. Delaware" on Justia Law

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Appellant Jarreau Ayers was convicted on one count of Riot, two counts of Assault First Degree, four counts of Kidnapping First Degree, and one count of Conspiracy Second Degree for his participation in the February 1-2, 2017 inmate takeover of C Building at the James T. Vaughn Correctional Center (JTVCC). Ayers was found guilty of these offenses following a sixteen-day jury trial. On appeal, he contended the trial judge erred by not curing prosecutorial misconduct which occurred during the State’s rebuttal argument. At trial, Ayers claimed he was not a participant in the planning and execution of the takeover and was outside of C Building in the recreational yard when the takeover took place. The alleged improper argument came when the prosecutor said to the jury, “[y]ou spent the better part of the last month with Jarreau Ayers. What about Mr. Ayers suggests that . . . he’s not going to do exactly what he wants to do, which is to go inside and join in what’s happening there.” Ayers contended this part of the rebuttal argument was improper because it asked the jury to consider Ayers’ character in the courtroom as observed by the jury during the trial. Ayers objected to the prosecutor’s statement, but his objection was overruled. After review, the Delaware Supreme Court concluded that the trial judge’s failure to take steps to cure any alleged prejudice caused by the prosecutor's comment, if error, was harmless error. Accordingly, judgment was affirmed. View "Ayers v. Delaware" on Justia Law

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Darth Heald was convicted by jury of unlawful sexual contact with a nine-year-old child and related charges. The alleged contact occurred when Heald brushed the back of his hand over the child’s clothed “private parts” during a “tag”-like game in which the player who is “it” chased the other players, who, if caught, are tickled rather than tagged. The prosecution’s case was centered more on what the child had reported to others than what she said on the witness stand. By contrast, the defense focused on testimony from other children who were present or nearby at the time of the alleged offense: accounts that contradicted the complainant’s version of important facts, and Heald’s testimony denying the essential elements of the charged offenses. This appeal addressed the Superior Court’s admission of evidence throughout the trial, sometimes over Heald’s objections and sometimes in the absence of any objection. The Delaware Supreme Court found no reversible error in the court’s evidentiary rulings. But the Court addressed Heald’s claim that improper comments in the prosecution’s opening statement and again in its closing argument cast doubt on the fairness and integrity of his trial. The Supreme Court found that because none of the challenged comments drew an objection from the defense, it was limited to reviewing them for plain error. The Court found several of the prosecutor's comments were indeed improper, and their cumulative effect compromised the fairness of Heald's trial. Consequently, judgment was reversed and the matter remanded for a new trial. View "Heald v. Delaware" on Justia Law

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Appellant Jarreau Ayers was convicted on: one count of Riot; two counts of Assault First Degree; four counts of Kidnapping First Degree; and one count of Conspiracy Second Degree. These charges arose from his participation in the February 1-2, 2017 inmate takeover of C Building at the James T. Vaughn Correctional Center (JTVCC). Ayers was found guilty of these offenses following a sixteen-day jury trial. On appeal, he contended the trial judge erred by not curing prosecutorial misconduct which occurred during the State’s rebuttal argument. At trial, Ayers claimed that he was not a participant in the planning and execution of the takeover and was outside of C Building in the recreational yard when the takeover took place. The alleged improper argument came when the prosecutor said to the jury, “[y]ou spent the better part of the last month with Jarreau Ayers. What about Mr. Ayres suggests that . . . he’s not going to do exactly what he wants to do, which is to go inside and join in what’s happening there.” Ayers contended that this part of the rebuttal argument was improper because it asked the jury to consider Ayres’ character in the courtroom as observed by the jury during the trial. Ayers objected to the prosecutor’s statement, but his objection was overruled. After consideration of the record and the parties’ arguments, the Delaware Supreme Court concluded the trial judge’s failure to take steps to cure any alleged prejudice caused by the prosecutor’s comment, if error, was harmless error. Accordingly, judgment was affirmed. View "Ayers v. Delaware" on Justia Law

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Defendant Naifece Houston was charged with drug offenses following a traffic stop, and moved to suppress evidence on various grounds, including that the arresting officers impermissibly extended the stop to allow time for a drug-sniffing dog to arrive. In his motion to suppress, defendant asked the superior court to hold a Daubert hearing so that he could contest the admissibility of testimony from one of the arresting officers that he could detect an odor at the scene emanating from the defendant’s car - a “chemically smell” that the officer associated with large amounts of cocaine. Because the officer’s testimony was based on his training and experience as a police officer, according to defendant, it was “expert in nature,” triggering the trial court’s gatekeeping function under Daubert and its progeny. The superior court disagreed, concluding that the officer’s testimony was not based on scientific, technical, or other specialized knowledge, but, rather, was lay opinion testimony admissible under Delaware Rule of Evidence 701. On that rationale, defendant appealed, arguing the superior court erred. And had defendant’s motion been granted, he contended the State would have been left with no evidence that he was guilty of the drug offenses with which he was charged. The Delaware Supreme Court concluded that both defendant and the State, and ultimately the Superior Court, mistakenly framed the issue in the proceedings below as hinging upon the admissibility of the officer’s testimony under the rules of evidence governing opinion testimony. "Thus, the true question before the superior court was whether the challenged testimony was sufficiently reliable to justify the officer’s suspicion that there was cocaine in the defendant’s car." The Supreme Court concluded the trial court’s admission of the officer’s testimony was not an abuse of discretion. Thus, judgment was affirmed. View "Houston v. Delaware" on Justia Law

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McArthur Risper was convicted by jury of first-degree murder, first degree conspiracy, and possession of a firearm during the commission of a felony for his role in the May 2018 shooting death of Corey Bailey. The superior court sentenced Risper to life plus 30 years in prison. The theory of the prosecution was that Risper intentionally killed Bailey as revenge for Bailey’s theft of drugs and a firearm belonging to Risper. Risper claimed that the evidence of Bailey’s theft and Risper’s subsequent efforts to recover the stolen drugs and firearm was prior-misconduct evidence, and therefore inadmissible under Delaware rules of evidence. Furthermore, Risper claimed he did not receive a fair trial because the State did not disclose in a timely manner evidence that was favorable to the defense as required under Brady v. Maryland and its progeny. According to Risper, the State’s belated disclosures (one on the day before trial was to begin and the other on the fourth day of trial) fundamentally undermined the fairness of his trial. The Delaware Supreme Court agreed with Risper as to his second contention, concluding that the State’s failure to produce, until the afternoon before Risper’s trial was to begin, a recorded interview of an individual who told the chief investigating officer that another person had confessed to her that he had killed Bailey and showed her the gun used in the shooting was a violation of the State’s obligations under Brady. "And because that violation undermines our confidence in the outcome of Risper’s trial, we reverse and remand to the Superior Court for a new trial." View "Risper v. Delaware" on Justia Law