Justia Constitutional Law Opinion Summaries

In a direct appeal, defendant raised one claim of error. In defendant's view, although he was charged with and convicted of felony Promoting Prison Contraband, the record reflected there was a rational basis for the jury to find him guilty of the lesser-included offense of misdemeanor Promoting Prison Contraband. Defendant argued the trial judge's failure to give that lesser-included instruction was reversible error. Upon review, the Supreme Court concluded that defendant's argument was meritless. View "Mays v. Delaware" on Justia Law

The Supreme Court previously rejected defendant Gary Ploof's claims arising from his trial's guilt phase, but remanded the penalty phase claims for the post-conviction judge to reweigh aggravating circumstances against the mitigating circumstances established at trial and in the post-conviction proceedings. Defendant contended his attorneys were ineffective because they failed to uncover evidence that the defendant's father sexually abused foster children staying with defendant's family and also physically abused defendant himself. Upon careful review, the Supreme Court held that defendant's attorneys should have investigated certain "red flags" indicating that defendant's childhood home was not as benign as initially portrayed. However, the Court concluded that the attorneys' failures did not prejudice defendant. Therefore, the Court affirmed the trial judge's denial of defendant's post-conviction relief petition. View "Ploof v. Delaware" on Justia Law

A Superior Court jury convicted the defendant in this case of Failing to Stop at the Command of a Police Officer, Reckless Driving, and several other offenses. At issue in this appeal was the State's obligation to produce relevant material in response to a defendant's discovery appeal. The State failed to produce a recording of the officers' communications with the dispatcher in response to the defendant's discovery request. The recording contained evidence that the officers’ siren had not been activated, contrary to the officers’ testimony. Upon review, the Supreme Court concluded that the dispatch recording fell within the scope of the defendant’s discovery request and Superior Court Criminal Rule 16, and that failure to produce this evidence prejudiced the defendant because the siren’s was material to the State’s case and impeached the credibility of its key witnesses. Accordingly, we the Court reversed the Superior Court's judgment and remanded for a new trial. View "Valentin v. Delaware" on Justia Law

Appellant John Nichols appealed a final Superior Court judgment affirming the order of the State Coastal Zone Industrial Board granting motions to dismiss filed by appellees Diamond State Generation Partners LLC and the Delaware Department of Natural Resources and Environmental Control in response to Nichols' appeal of the grant of a Coastal Zone industrial permit application. Nichols raised two claims on appeal: (1) the Board's vote on whether Nichols had standing to pursue the appeal failed due to the lack of a five-vote majority; and (2) that he possessed standing under the "any person aggrieved" standard of title 7, section 7007(b) of the Delaware Code, or, in the alternative, as a matter of common law. Upon review, the Supreme Court concluded both of Nichols' arguments lacked merit and therefore affirmed the Superior Court. View "Nichols v. State Coastal Zone Industrial Control Board, et al." on Justia Law

A group of Texas plaintiffs alleged that a corporation exposed two employees to chemicals that caused two of the employees' children to suffer from birth defects. The Superior Court judge excluded expert testimony as irrelevant under Delaware law because it would have been insufficient as a matter of Texas law. The judge did not reach the testimony's reliability under Delaware law. Because the plaintiffs waived their argument that California or Delaware substantive law applied, the Supreme Court affirmed the Superior Court judge's ruling that Texas substantive law applies. But before the Court could address whether a judge may consider substantive sufficiency when analyzing procedural admissibility, the case was remanded for the Superior Court judge to determine in the first instance whether the testimony at issue is excludable on reliability grounds. View "Tumlinson, et al. v. Advanced Micro Devices, Inc." on Justia Law

Employee-appellant, Gary Andreason appealed a Superior Court judgment affirming two Industrial Accident Board decisions. The first decision awarded compensation to Andreason for his work-related knee and right shoulder injuries, but denied compensation for a separate and unrelated lower back injury. The second decision denied Andreason's reargument motion challenging the Board's denial of compensation for his lower back injury. Andreason argued on appeal to the Supreme Court: (1) the Board erred as a matter of law when it determined that there was no implied agreement to compensate him for his lower back injury; (2) that title 19, section 2322(h) does not apply when compensation is paid as the result of a unilateral mistake. The Court concluded all of Andreason's arguments were without merit. View "Andreason v. Royal Pest Control" on Justia Law

Defendant Ramazn Sahin appealed the denial of his application for post-conviction relief. He claimed he received ineffective assistance of counsel at trial. Finding no merit to defendant's claims, the Supreme Court affirmed the denial. View "Sahin v. Delaware" on Justia Law

The Supreme Court held that a trial court judge erred in finding that a state agency complied with the state's Real Property Acquisition Act before it moved to condemn petitioners' property. Accordingly, the trial court's judgment was reversed, the orders vacated and the case remanded with instructions to dismiss the condemnation action without prejudice. View "Lawson v. Department of Transportation" on Justia Law

A vice principal of an elementary school asked a Delaware State Trooper to come to the school give a talk about bullying to four or five fifth grade students who were under “in-school suspension.” The next day, the principal was told that there had been a bullying incident involving an autistic student whose money had been taken from him on the school bus by "AB." The principal told AB’s mother about the incident, and asked her permission to have the officer talk to AB. AB’s mother consented. The officer arrived and was told what happened. The principal and officer went to a room where AB was waiting. The principal was called away, leaving the officer alone with AB. The officer got AB to admit that he had the money (one dollar), but AB claimed that another student had taken the money. AB said that he did not know that other student’s name, but that the student was seated with AB on the school bus. Without discussing the matter with the principal, the officer followed up on AB’s claim despite being virtually certain that AB was the perpetrator. The officer obtained the bus seating chart, found AB's seat-mate, brought the two students together and questioned that student in the same manner as AB. According to the other child, the officer used a mean voice and told him 11 or 12 times that he had the authority to arrest the children and place them in jail if they did not tell the truth. AB finally admitted to taking the money from the autistic student. When he got home from school, the seat-mate told his mother what had happened. The child withdrew from school and was home schooled for the rest of that school year. The mother filed suit on her son’s behalf, as well as individually, against the Cape Henlopen School District, the Board of Education of Cape Henlopen School District, the principal, the State, the Department of Safety and Homeland Security, the Division of the Delaware State Police, and the officer, Trooper Pritchett (collectively, Pritchett). Charges against all but the officer were eventually settled or dismissed; Pritchett successfully moved for summary judgment, and this appeal followed. Viewing the record in the light most favorable to the child, the Supreme Court held that there was sufficient evidence to raise issues of material fact on all claims against the officer except a battery claim. Accordingly, the Court affirmed in part and reversed in part. View "Hunt v. Delaware" on Justia Law

In 2011, the Board of Cosmetology and Barbering suspended Petitioner Randall Richardson's license due to his leasing work space to his wife who Petitioner knew did not have a valid license. A Hearing Officer recommended a fine and a 90-day suspension of Petitioner's license. The Board voted to adopt the Hearing Officer’s recommendations. The Superior Court affirmed the Board’s decision. On appeal, Petitioner argued: (1) the Board failed to create a complete record for the Supreme Court to review on appeal; (2) the Board failed to properly appoint the Hearing Officer to his case; (3) the Board failed to consider exceptions to the Hearing Officer’s recommendation; (4) the Board erred in suspending Petitioner's license because he only violated the requirements of his Shop License; and (5) the Hearing Officer lacked statutory authority to conduct hearings involving potential license suspensions. Upon review, the Supreme Court concluded that the Hearing Officer had the authority to act and that the Board had the authority to suspend Petitioner's License. However, the Court agreed that the Board created an insufficient record for appellate review. Accordingly, the Superior Court's judgment was vacated and the matter remanded for further proceedings. View "Richardson v. Board of Cosmetology & Barbering" on Justia Law