Justia Constitutional Law Opinion Summaries

The police arrested defendant at a private party and based on evidence seized on the night of defendant's arrest, a magistrate issued a warrant to search his home. While executing the warrant, police discovered drugs and firearms in defendant's residence. Defendant was subsequently convicted of drug crimes committed on the evening of the arrest and defendant was later convicted of drug and firearm offenses related to the items seized at his home. Defendant appealed both his convictions, contending that the Superior Court judge erred by denying his motions to suppress. The court held that because the police illegally seized defendant when they obtained the drugs leading to his initial arrest, the evidence against him, including evidence seized from defendant's home, constituted inadmissible fruit of the poisonous tree. Accordingly, the court reversed.

Defendant was convicted of crimes related to the attempted murder of the victim on January 26, 2006, and the subsequent murder of the victim on April 2, 2007. On appeal, defendant contended that the trial court abused its discretion by denying defendant's motion to sever the trial of the attempted murder case from the murder case; that his right to a fair trial before an impartial jury was violated when the evidence presented at trial did not clearly and convincingly establish the State's proffered "other crime" evidence of motive, due to the unwillingness of a State witness to testify; and his due process rights were violated when the trial judge denied his motions to suppress two separate pretrial eyewitness identifications. The court held that defendant's arguments were without merit and therefore, affirmed the judgments of the Superior Court.

Linda Thompson appealed from a Superior Court judgment reversing the determination of the Unemployment Appeals Board (UIAB) that good cause existed for Thompson's voluntary resignation and granting her unemployment benefits. Thompson contended that good cause existed for voluntarily terminating her employment, that she exhausted her administrative remedies, and that substantial evidence in the record supported the UIAB's decision. The court affirmed the judgment of the Superior Court and held that substantial evidence did not support the UIAB's decision and the UIAB erred as a matter of law by concluding that Thompson was entitled to benefits pursuant to 19 Del. C. 3314(1).

Defendant was convicted of robbery first degree and possession of a firearm during the commission of a felony (PFDCF) for robbing Barbara Santana at gunpoint. At defendant's jury trial, defendant's counsel proffered evidence of a different bank robbery (Artisans' Robbery) that recently had occurred across the street from the bank were Santana was robbed. Counsel called the man who had pled guilty to that crime, Joseph Blevins, as a witness in defendant's trial in an attempt to create a reasonable doubt that defendant had robbed Santana. At issue was whether the trial judge abused his discretion by precluding defendant's proffer of exculpatory evidence to establish a reasonable doubt that someone else could have committed the crime charged. The court held that the exculpatory evidence could have been admitted where defense counsel could have presented the jury with the facts of the Artisans' Robbery and photographs of Blevins or where defense counsel could have presented the jury with the facts of the Artisans' Robbery and then have Blevins identified in court as an exhibit to avoid the concern that Blevins might invoke his Fifth Amendment right not to incriminate himself. The court held that if the trial judge had employed either of those methods, the probative value of the relevant evidence would not have been substantially outweighed by the dangers of confusion of the issues or misleading the jury. Accordingly, the court held that the evidence was admissible and reversed and remanded for a new trial.

Defendant appealed his sentence from convictions of two counts of assault in the second degree, two counts of possession of a firearm during the commission of a felony (PFDCF), and one count of reckless endangering in the first degree. At issue was whether the trial court erred by imposing a more severe sentence than recommended under the relevant Sentencing Accountability Commission (SENTAC) Benchbook guidelines. The court held that the record reflected that defendant was fully aware that the Superior Court was not bound by the state's sentence recommendations, and that he had been twice advised that by pleading guilty, he faced a maximum sentence of seventy-one years of incarceration. The court also held that, where the sentencing judge imposed a harsher sentence than those recommended by the SENTAC Benchbook guidelines, the sentences were neither illegal or an abuse of discretion. Therefore, the court affirmed the judgment of the Superior Court.

Appellant appealed a termination decision by appellees (collectively, "Panel") after the Panel unanimously voted at a public hearing to terminate appellant's employment as Chief of Police. At issue was whether the Superior Court erred in holding that the votes of the remaining Panel members could cure the Panel's unlawful failure to recuse a biased member; whether the Superior Court erred in affirming the Panel's failure to provide appellant with the protections of Chapter 48 of the Police Department's rules and Regulations; and whether the Superior Court erred in concluding that the Panel provided appellant with sufficient notice of the grounds for the charges against him at the public hearing. The court held that appellant's testimony established a prima facie case of bias by a Councilman and the Panel's failure to recuse him could not be cured by votes of the remaining Panel members. Therefore, appellant's due process rights were violated. The court also held that because this ground for reversal was independently sufficient, the court declined to address appellant's other arguments. Accordingly, the judgment of the Superior Court was reversed and the case remanded for further proceedings.

Defendant was convicted of conspiracy in the second degree where the jury found that defendant and his co-conspirator committed an overt act in pursuance of the conspiracy. At issue was whether the trial judge committed plain error by not, sua sponte, giving a specific unanimity instruction requiring the jury to determine unanimously which particular overt act was committed. The court held that, in light of conflicting authorities on the issue, defendant had not shown that the trial judge committed plain error in failing to give the instruction because the error complained of was not so clearly prejudicial to his substantial rights as to jeopardize the fairness and integrity of the trial process. Accordingly, the judgment was affirmed.

Defendant was convicted of first degree murder and appealed a superior court judge's denial of his second motion for postconviction relief. At issue was whether the sidebar commentary defendant's counsel made to the trial judge during a pretrial hearing created an unlawful "appearance of impropriety," violated defendant's due process rights, and denied his Sixth Amendment right to counsel. The court held that the relevant circumstances did not disclose any "appearance of impropriety" sufficient to reverse the judgment and grant a new penalty phase where the court did not find an unacceptable risk that a reasonable observer would believe that bias influenced the trial judge. The court also held that the superior court judge did not violate defendant's due process rights where there was no evidence proving reliance on counsel's remarks. The court further held that defendant was not denied his Sixth Amendment right to counsel where there was no "complete" failure of counsel and defendant failed to establish actual prejudice sufficient to warrant relief. Accordingly, the judgment of the superior court was affirmed.

Defendant was charged with nineteen counts in a final re-indictment related to charges of attempted murder, reckless endangering, firearm charges related to attempted murder charges, aggravated menacing by a firearm, aggravated intimidation of a witness, criminal solicitation, disregarding a police officer, resisting arrest, and reckless driving. At issue was whether the trial judge abused his discretion when he decided that a single complaint by the jury during trial, that some members had difficulty hearing one videotaped section 3507 statement, justified departure from the general default rule that such statements did not go into the jury during deliberations. The court held that the jury certainly should not be permitted to "work through" the recorded section 3507 statement during their deliberations until it was understandable and the undue emphasis placed upon the section 3507 evidence by its unwarranted admission into the jury's deliberative process was not harmless beyond a reasonable doubt. Therefore, the court reversed the judgment and remanded for a new trial.