Justia Constitutional Law Opinion Summaries

Tracey West was pulled over by police officer Thomas Gaul when her car was drifting back and forth in the lane. The officer saw the car swerve sharply to avoid hitting a concrete island. When he approached the car, Gaul smelled alcohol. West "staggered out of the car" and failed field sobriety tests. She was charged with an illegal lane change and driving under the influence. Before trial, West moved to suppress the evidence that she was intoxicated. She claimed that Officer Gaul lacked the reasonable suspicion required by the Fourth Amendment to make an investigative stop of her car. Thus, any evidence of her intoxication gathered after the stop should have been suppressed. After hearing testimony from the officer and reviewing the video from the police car camera, the trial judge dismissed the lane change charge, but denied the motion to suppress. The State then introduced at trial the evidence of her intoxicated state, and a jury convicted West of drunk driving. West appealed her conviction to the Superior Court, which affirmed the trial court’s ruling on the community caretaker doctrine, and also found that Officer Gaul had reasonable suspicion to stop West for driving while intoxicated. West then appealed to the Delaware Supreme Court, arguing the community caretaker doctrine did not apply, and Officer Gaul lacked reasonable suspicion as required by the Fourth Amendment for an investigatory stop of her car. Finding no reversible error, the Supreme Court affirmed. View "West v. Delaware" on Justia Law

Defendant-appellee Isaiah McCoy was a pretrial detainee awaiting trial on capital murder and related charges. In May 2010, McCoy was arrested and charged with the murder of James Munford in Dover. He was convicted and sentenced to death at his first trial in June 2012. In January 2015, the Supreme Court reversed his conviction and remanded the case for a new trial. Using a points-based, objective risk assessment tool, the Department of Correction classified him to be held in the maximum security Secured Housing Unit (“SHU”) at James T. Vaughn Correctional Center (“JTVCC”). McCoy filed a motion in the criminal case requesting that he be transferred from the SHU to the prison’s general population on the ground that detention at the SHU was interfering with his Sixth Amendment right to assistance of counsel. The Superior Court, over the State’s objection, granted McCoy’s motion, and McCoy was, in fact, transferred to general population. While McCoy had some complaints about the adequacy of the attorney visitation rooms in the SHU and access to the library, the Superior Court based its order in significant part upon its perception of “the emotional and physical impact that prolonged, solitary placement has had on [McCoy’s] Sixth Amendment right to assistance of counsel . . . .” The Superior Court found there that it had such jurisdiction under 10 Del. C. sec. 542, 11 Del. C. sec. 6504, and several other cases, to order the transfer of a detainee from maximum security to the general population. The State renewed its jurisdictional argument in this case. After review, the Delaware Supreme Court concluded that neither the Sixth Amendment right to assistance of counsel nor the statutes and cases relied upon by the Superior Court granted it the authority to transfer a detainee from one housing unit to another in a criminal case. The order of the Superior Court was, therefore, vacated. View "Delaware v. McCoy" on Justia Law

Milton Taylor was sentenced to death in 2001. He petitioned the Delaware Supreme Court for a writ of mandamus to direct the Superior Court to docket his second motion for post-conviction relief under Superior Court Criminal Rule 61. The State conceded that the writ should be issued. After careful consideration, the Court held that the Superior Court erroneously concluded that it lacked jurisdiction to act in Taylor’s case because of a stay of execution order entered by the United States District Court for the District of Delaware. The Delaware Supreme Court issued the writ. View "Matter of Taylor" on Justia Law

In this direct appeal, the issue before the Delaware Supreme Court implicated the constitutional boundaries of a trial court’s discretion to limit the scope of a criminal defendant’s cross-examination of the witnesses against him. Wayne Williams was indicted on two counts of Drug Dealing plus aggravating factors, one count of Tampering with Physical Evidence, one count of Resisting Arrest, and two counts of Possession of Drug Paraphernalia. The principal question presented on appeal was the extent to which Williams should have been permitted at trial to cross-examine witnesses concerning misconduct at the Office of the Chief Medical Examiner (“OCME”) and elicit testimony that presented an alternative explanation for the weight discrepancy involving the drug evidence in his case. The Court concluded there was no unconstitutional restriction of Williams’ confrontation rights and that the Superior Court imposed reasonable limits when exercising its discretion to limit the scope of cross-examination. In view of the overwhelming evidence unrelated to the misconduct at the OCME, the Court held that, even if the trial court had erred, the error would have been harmless beyond a reasonable doubt. Accordingly, but for the Tampering with Physical Evidence conviction which the State conceded had to be reversed, the Supreme Court affirmed Williams’ convictions. View "Williams v. Delaware" on Justia Law

Defendant-appellant Martin Fountain appealed a superior court judgment denying his motion for resentencing on grounds that the Amended Sentencing Act did not apply retroactively. With the help of amicus curiae, he argued that the Act vested a judge with the discretion to modify a consecutive sentence entered before the Act was effective July 9, 2014, and to reimpose concurrent prison terms. The State argued the judicial discretion provided for in the Act operated prospectively only, because there was no express statement in the amendment that made it retroactive. After review, the Supreme Court agreed with the State that the Act applied prospectively. Therefore, the superior court's judgment was affirmed. View "Fountain v. Delaware" on Justia Law

Defendant-appellant Jhavon Goode was convicted by jury of first degree assault, possession of a firearm during the commission of a felony, and carrying a concealed deadly weapon. The jury determined that Goode shot Jason Terry in the course of a drug sale in Milford. The court sentenced Goode to a total of eighteen years at Level V incarceration with credit for time previously served. Goode appealed, raising a number of arguments. The Supreme Court found no merit to any of these arguments. With respect to Goode’s primary argument, that Terry’s identification of Goode should have been suppressed as unduly suggestive because Terry identified Goode only after Terry’s cousin, Raye Boone, showed him a photograph of Goode, the Court held that a state actor must play a role in an identification before due process concerns arise. "If no state actor is involved in the identification, as was the case here, then the normal rules of evidence and procedure provide sufficient protection to the rights of the accused to challenge the identification." Accordingly, the Court affirmed the trial court's judgment. View "Goode v. Delaware" on Justia Law

After being out of prison for two days and while on probation, defendant Phillip Rossi was spotted at a department store with a woman who was believed to have stolen almost $200 of merchandise. Rossi was the suspected lookout. The alleged scheme culminated in Rossi supposedly returning the stolen items to a different store for store credit later that same day. Criminal charges followed soon after the incident. And although the State entered a nolle prosequi on all charges against Rossi subject to certain conditions, it nonetheless sought to revoke Rossi's probation, and the Superior Court found that Rossi had violated terms of his probation by shoplifting. On appeal, Rossi argued that the Superior Court could not find that he violated probation by shoplifting because the evidence was insufficient to support the violation. "The State's burden to prove a violation of probation is much lighter than it is to convict a defendant of a crime. All that the State must do is prove by a preponderance of the evidence that the 'conduct of the probationer has not been as good as required by the conditions of probation.'" The only piece of competent evidence the State produced showed that Rossi was at the store on the key date in question. But, the State did not introduce any competent evidence that showed a crime had been committed there. Finding that was insufficient to support revocation of Rossi's probation, the Supreme Court reversed. View "Rossi v. Delaware" on Justia Law

Defendant-appellant Gerald Masarone appealed a Superior Court order denying his motion for postconviction relief. He raised two issues as grounds for appeal: (1) that his trial counsel was ineffective by not advising him that he had a right to wear street clothes, rather than a prison uniform, at his trial, and by failing to provide him with street clothes; and (2) the Superior Court erred by failing to hold an evidentiary hearing on his first claim. On this record, the Delaware Supreme Court could not conclude that Masarone was compelled to go to trial in a prison uniform. In addition, given the nature of the evidence against Masarone, no arguable error on this point or on the lack of an evidentiary hearing caused Masarone harm or prejudice. The Superior Court's order was affirmed. View "Masarone v. Delaware" on Justia Law

Earl Bradley petitioned the Supreme Court for postconviction relief. He was convicted on fourteen counts of first-degree rape, five counts of second-degree assault and five counts of sexual exploitation of a child. Bradley was sentenced to fourteen mandatory life sentences and 164 years at Level V imprisonment. In a 2012 direct appeal, Bradley argued that the search warrant for his former medical practice, BayBees Pediatrics, P.A., was defective because the affidavit in support of the search warrant application did not allege facts establishing probable cause that the medical files of certain patients would be found in a white outbuilding on the BayBees Pediatrics property, would be contained in digital format, or would relate to the crimes described in the search warrant application. Bradley also asserted that the police exceeded the scope of the search warrant by proceeding with a general search to locate and seize evidence without probable cause. The Delaware Supreme Court rejected those claims. Bradley raised three issues in this appeal: (1) the Superior Court erred when it denied his request for an evidentiary hearing and held that State action did not deprive him of his right to choice of counsel; (2) the Superior Court erred when it held that his trial and appellate counsel were not ineffective when they failed to object to the presentation of evidence outside of the four corners of the search warrant; and (3) the Superior Court erred in finding that his trial and appellate counsel litigated, in an effective and professionally reasonable manner, the claim that the police had performed an unrestricted search of his property in violation of the federal and state Constitutions. Finding no reversible error, the Supreme Court affirmed the Superior Court's denial of postconviction relief. View "Bradley v. Delaware" on Justia Law

Defendant Christopher Wheeler petitioned the Delaware Supreme Court to overturn his conviction of Dealing in Child Pornography. He raised two issues: (1) he challenged a 2014 Superior Court denial of his Amended and Superseding Motion to Suppress, arguing that the nature of “general warrants” were overly broad in scope, and the execution of which violated his federal and State Constitutional rights; and (2) he challenged a second Superior Court denial of his motion for Judgment of Acquittal, arguing insufficient evidence to convict him because the State could not establish that he was aware of the existence of the offending images on his computer, stored in his “newsgroup cache.” Wheeler was sentenced to 50 years at Level V. Throughout these proceedings, Wheeler asserted that the State used charges of witness tampering stemming from his admission in 2013 that he had molested two brothers in Pennsylvania in the 1980’s as a pretext to search broadly for child pornography. The challenged warrants in this case were the witness tampering warrants: not the later-obtained child pornography warrant. The State admitted that the challenged witness tampering warrants were virtual copies of an off-the-shelf warrant for child pornography. Because the Supreme Court agreed that the challenged witness tampering warrants were in the nature of “general warrants” in violation of the United States and Delaware Constitutions, it reversed the judgments of the Superior Court and remanded this matter for further proceedings. View "Wheeler v. Delaware" on Justia Law