Justia Constitutional Law Opinion Summaries

The issue on appeal before the Supreme Court in this case was the denial of a postconviction relief motion. Specifically, the issue was whether defense counsel were ineffective during a defendant's first-degree murder trial. Upon review, the Court held that the attorneys' alleged failure to consult with a forensic pathologist or toxicologist, to present more evidence regarding the victim's dominant hand, to investigate ballistics issues, appeal certain issues, and to object to the dismissal of jurors who indicated that they could not impose the death penalty did not prejudice the defendant during his trial's guilt phase. During the penalty phase, however, the postconviction hearing judge failed to reweigh the aggravating evidence against the total mix of mitigating evidence in determining whether the attorneys' failure to present additional evidence during the penalty phase prejudiced the defendant. Accordingly, the Court affirmed in part, and remanded in part so that the postconviction judge could supplement his opinion for further review. View "Ploof v. Delaware" on Justia Law

On August 26, 1992, Jermaine Wright was convicted of first degree murder and other crimes arising from a 1991 robbery at the Hi-Way Inn bar and liquor store. Following a penalty hearing, Wright was sentenced to death. The issue on appeal before the Supreme Court in this case was whether Wright's murder conviction should have been overturned. The trial court granted Wright's fourth motion for postconviction relief, finding that his confession should have been excluded from evidence, and that the State improperly withheld evidence of a similar crime that the police determined he did not commit. The trial court then granted bail. Upon review, the Supreme Court held that the trial court erred in reviewing the admissibility of the confession sua sponte, and in concluding that there was a so-called Brady violation. The trial court also erred in deciding that Wright could be granted bail. Therefore the trial court's judgment was reversed and the matter remanded for further proceedings. View "Delaware v. Wright" on Justia Law

Defendant-appellant Jason Gallaway appealed his conviction for Murder by Abuse or Neglect in the First Degree, in connection to the death of his daughter. Defendant raised one claim of error in this direct appeal: the Superior Court abused its discretion by permitting the State to admit into evidence a YouTube video of Defendant performing a prank as part of a radio contest, several months after his daughter’s death. Upon review, the Supreme Court concluded that the YouTube video was properly admitted as rebuttal evidence. View "Gallaway v. Delaware" on Justia Law

Defendant Omari Clark was convicted for manslaughter. The issue before the Supreme Court was whether a trial judge improperly commented on the evidence when he instructed the jury and whether a defendant was entitled to a justification jury instruction for a crime that requires a reckless mental state. Upon review, the Court reaffirmed that jury instructions must be construed as a whole to determine whether a trial judge commented on the evidence and conclude that the trial judge's statements were proper. Furthermore, the Court held that 11 Del. C. sec. 470(a) does not bar a justification instruction for crimes requiring a reckless mental state and that judges should give a justification instruction, where appropriate, for those charges. Therefore the Court reversed the Superior Court's judgment and remanded the case for a new trial. View "Clark v. Delaware" on Justia Law

Defendant-appellant Steven Schwan directly appealed his conviction to the Supreme Court after a jury convicted him of two counts of Unlawful Sexual Contact in the Second Degree, and a bench trial resulted in an additional conviction for Unlawful Sexual Conduct by a Sex Offender Against a Child. Defendant argued that the trial judge committed reversible error by not excluding, for cause, a juror who was acquainted with a prosecutor, although that same prosecutor was not involved in Defendant's case. Upon review, the Supreme Court concluded that the trial judge erred by failing to exclude the juror, in the absence of a determination that the juror could render a fair and impartial verdict. The Court reversed and remanded the case for a new trial. View "Schwan v. Delaware" on Justia Law

Defendant Raymond Blake was tried before a jury for Trafficking in Cocaine, Possession with Intent to Deliver ("PWID") Cocaine, PWID Heroin, and Maintaining a Vehicle for Keeping Controlled Substances. The jury found Defendant guilty of the lesser-included offenses of Possession of Cocaine and Possession of Heroin, not guilty of Maintaining a Vehicle, and could not agree unanimously on the trafficking charge. Prosecutors sought and obtained another indictment of Defendant, charging him with Trafficking in Cocaine and Trafficking in Heroin, based upon his possession of the same contraband he was convicted of possessing in the first trial. Defendant's motion to dismiss was denied and at the second trial he was convicted as charged. Defendant appealed, claiming the protection against Double Jeopardy under the Fifth Amendment of the United States Constitution barred the State from trying him on trafficking in a controlled substance charges when he had already been convicted of the lesser included offense of Possession based on the same conduct. Upon review, the Supreme Court agreed and accordingly reversed and remanded the case with instruction to vacate Defendant's trafficking convictions. View "Blake v. Delaware" on Justia Law

Claimants Cecil Palomino, Salvador Avila-Hernandez and Julio Munoz were each injured in different work-related accidents. It was not disputed that their injuries were compensable under the Worker's Compensation Act and that payments of some worker's compensation have been made. After their doctors recommended certain treatments, their employers requested determinations of whether the treatment plans fell outside of the Health Care Practice ("HCAP") Guidelines through a utilization review ("UR"). The UR panel determined that portions of their treatments were not approved for coverage. Claimants petitioned the Industrial Accident Board for review of the UR determination after the 45 day time window prescribed by Department of Labor Regulation 5.5.1. The Board dismissed the petitions as untimely. Claimants appealed to the Superior Court, which determined that the 45 day limit of Regulation 5.5.1 was invalid because it conflicted with 19 Del. C. sec 2361. The employers appealed from the Superior Court's judgment. Finding no merit to the appeal, the Supreme Court affirmed. View "Christiana Care Health Services v. Palomino" on Justia Law

The issue before the Supreme Court in this matter was whether the Chancery Court was required to dismiss a Delaware derivative complaint after a California federal court entered final judgment dismissing the same complaint brought by different stockholders. The Chancery Court determined it was not required to give preclusive effect to the California judgment. Upon review, the Supreme Court held that the Chancery Court erred in its determination: (1) the lower court held as a matter of Delaware law that the stockholder plaintiffs in the two jurisdictions were not in privity with one another; (2) that the California stockholders were not adequate representatives of the defendant corporation; (3) California law controlled the issue, and derivative stockholders were in privity with one another because they acted on behalf of the corporation; and (4) the Chancery Court adopted a presumption of inadequacy without the record to support it. Accordingly, the Supreme Court reversed and remanded. View "Pyott v. Louisiana Municipal Police Employees' Retirement System" on Justia Law

Defendant-Appellant Thomas Sammons appealed several final superior court judgments after he was convicted by jury of second-degree burglary, second-degree robbery and criminal mischief. Defendant raised two issues on appeal to the Supreme Court: (1) that the trial judge erred in declaring Defendant an habitual offender pursuant to title 11, section 4214(b) of the Delaware Code based on a prior conviction in the State of Florida for burglary; and (2) that the trial judge erred in declaring Defendant an habitual offender, where the issue of rehabilitation, in light of his "organic dysfunctions," was not addressed. Upon review, the Supreme Court that both of Defendant's arguments were without merit. View "Sammons v. Delaware" on Justia Law

Defendant-Appellant Ewelina Kulowiec appealed her conviction for third-degree assault. Defendant elected to have a non-jury trial, after which she was acquitted of Aggravated Menacing, a firearm offense, and Terroristic Threatening, but was convicted of assault. Defendant was sentenced to one year of imprisonment at Level 5, suspended for one year of probation at Level 2. On appeal, Defendant argued that the State did not prove beyond a reasonable doubt that she inflicted "physical injury" upon her then-husband. Upon review, the Supreme Court concluded that the record did not support Defendant's argument. Therefore, the superior court's judgment was affirmed. View "Kulowiec v. Delaware" on Justia Law