Justia Constitutional Law Opinion Summaries

Dai'yann Wharton was found guilty after a bench trial on several charges, led by a count of first-degree murder for the death of Yaseem Powell. Wharton appealed, contending her conviction should have been reversed because the State identified a group of highly incriminating text messages less than two weeks prior to trial, though the messages themselves had been contained in a digital discovery disclosure made by the State to Wharton more than a year earlier. Because of the State’s earlier disclosure, and because the Delaware Supreme Court rejected Wharton’s assertions that the State engaged in any discovery violations or other misconduct, it held the superior court was within its discretion to deny Wharton’s motion to exclude the text messages. Accordingly, Wharton's conviction and judgment of sentence were affirmed. View "Wharton v. Delaware" on Justia Law

As Delaware State Police (“DSP”) Trooper Brian Holl was on patrol in Kent County, he received a call from DSP Detective Thomas Macauley, a member of a “drug task force” in New Castle County. Detective Macauley’s and his brother Detective Michael Macauley’s were involved in a wiretap investigation known as “Operation Cutthroat.” Detective Thomas Macauley told Trooper Holl that the task force had been surveilling a blue Mazda that was, at the time of the call, southbound on Delaware State Route 1 heading towards Kent County. Detective Macauley shared with Detective Holl the reason for the surveillance of the Mazda: the surveilling officers had just “watched a drug transaction” between the occupants of the car and one of Operation Cutthroat’s targets. Because the Macauleys wished to maintain the secrecy of the ongoing wiretap investigation, they enlisted Trooper Holl’s assistance in the apprehension of the blue Mazda’s occupants. Detective Macauley’s instructions to Trooper Holl were: "To keep the integrity of the investigation of the wiretap investigation, I need a traffic stop. That means you need to . . . develop your own probable cause and go from there. Nothing about the wiretap can be revealed, obviously, for the integrity of the investigation." Trooper Holl believed he found one: according to his Affidavit of Probable Cause, the Mazda’s headlights were not activated despite “inclement weather.” Because of the perceived headlight infraction, Trooper Holl initiated a motor vehicle stop by activating his emergency lights. The stop lead to defendant Thomas Gordon's arrest, ultimately on drug trafficking-related charges. The issues this case presented for the Delaware Supreme Court's review centered on the "collective knowledge" doctrine, and whether the trial court’s consideration of the lawfulness of a warrantless detention and arrest was constrained by the facts alleged in a later filed arrest-warrant affidavit. The Supreme Court held that the trial court applied the correct legal standard when it determined that based on the collective knowledge of the officers involved, Trooper Holl had a reasonable suspicion the car in which defendant was traveling contained contraband, and was therefore subject to detention. In making this determination, the court did not err by considering facts extraneous to the subsequently filed arrest-warrant affidavit. View "Gordon v. Delaware" on Justia Law

Appellant-defendant John Trala was convicted by jury of driving under the influence. Trala contended the trial court erred in denying his motion for a mistrial after the State, in its rebuttal argument, asserted that defense counsel’s lack of evidentiary objections to certain witness testimony relating to Trala’s blood chemical analysis suggested that defense counsel had acknowledged the reliability of that incriminating evidence. He also claimed he was denied a fair trial because the prosecutor, in a rebuttal remark, expressed her favorable personal opinion as to the credibility of the arresting officer who was a key witness for the State. The Delaware Supreme Court determined the jury specifically found two independent theories of liability to support the same DUI charge. In light of that dual holding, which the Court found was supported by overwhelming evidence, any error arising from the prosecutor's misconduct was harmless. The Court therefore affirmed appellant's conviction. View "Trala v. Delaware" on Justia Law

Dwayne White faced a lengthy sentence of incarceration at Level V, followed by various levels of probation after a jury convicted him of twenty-one felony charges. On appeal, White challenged his conviction and sentence on a number of grounds that were not raised in the proceedings below. Before the Delaware Supreme Court, White contended: (1) several of the counts of which he was convicted and separately sentenced merged under the Double Jeopardy Clauses of the Delaware and United States Constitutions; (2) the trial court committed plain error by placing the accomplice liability instructions at the end of the instructions for the felony conspiracy offenses; (3) his conviction for conspiracy to commit Drug Dealing Cocaine was invalid because it relied on an indictment containing a numbering error; (4) the trial court erred by failing to bar the State from eliciting testimony from White’s attorney regarding the scope of the attorney’s representation of members of the criminal enterprise; and (5) the trial court abused its discretion by failing to specify adequately its reasons for imposing a sentence in excess of the SENTAC guidelines and by relying upon certain factual predicates which he challenges on various grounds. Finding no reversible error, the Supreme Court affirmed White's conviction. View "White v. Delaware" on Justia Law

Appellant Reginald Waters appealed his convictions for various offenses relating to the death of Clifton Thompson. According to Waters,the Superior Court erred in three ways: (1) in applying an incorrect legal standard when considering his motion for a new trial and improperly denied the motion; (2) in denying his motion to exclude certain prison phone calls that were obtained in violation of his Fourth Amendment rights; and (3) in denying a continuance of his trial to allow his counsel time to review certain evidence, which compromised his right to a fair trial. The Delaware Supreme Court found the Superior Court did not abuse its discretion by denying Waters’ motion for a new trial. Nor did the court err in allowing the prison phone calls to be used at trial. Lastly, the Supreme Court determined the trial court did not abuse its discretion by denying Waters’ continuance of trial. Therefore, judgment was affirmed. View "Waters v. Delaware" on Justia Law

In January 2019, 15-year old Heather Juliano was a passenger in a sport-utility vehicle driven by Shakyla Soto in the vicinity of the Capital Green development in Dover, Delaware. Corporal Robert Barrett of the Dover Police Department was patrolling the area, accompanied by Probation Officer Rick Porter, as part of the Department’s Safe Streets program. Corporal Barrett spotted Soto’s SUV exiting Capital Green and noticed that the occupant of the front passenger seat was not wearing a seat belt. Corporal Barrett decided to pull the vehicle over. Almost immediately after Barrett initiated contact with the driver, he heard Porter say “1015 which means take . . . everybody into custody.” Three other Dover Police Department officers arrived on the scene in very short order. All four occupants of the SUV were removed from the vehicle and handcuffed in response to Porter’s order. The SUV was then searched, but no contraband was found. One officer searched backseat passenger Keenan Teat and found a knotted bag containing crack cocaine in one of his pants pockets. Another officer searched passenger Zion Saunders and found both marijuana and heroin in his jacket pockets. But when Officer Johnson searched Juliano, he found no contraband, but $245.00 in cash. Juliano was later taken to the police station, and strip-searched. Officers found marijuana and a bag of cocaine in her pants. Juliano was charged with Tier 1 possession of narcotics plus an aggravating factor (aggravated possession of cocaine), drug dealing, and possession of marijuana. The Delaware Supreme Court determined there was nothing unreasonable in a motor vehicle stop based on an officer's reasonable suspicion the operator or occupant of the vehicle committed a violation of the law - here, traffic laws. "Equally so, we are not prepared to say that, once a vehicle is lawfully stopped, the police must ignore evidence of other criminal activity when that evidence itself is lawfully uncovered." Rejecting Juliano's appellate claims with regard to the initial traffic stop and the suppression od evidence, the Supreme Court felt compelled to address "certain conspicuous irregularities" in the trial court's order denying Juliano's motion to suppress: (1) the trial court did not articulate a basis for finding a reasonable suspicion sufficient to justify the extension of the traffic stop to investigate the vehicle's occupants; and (2) the court's order did not explain the basis upon which the custodial arrest and threatened strip search were justified. The matter was remanded to the trial court for more complete statements of the factual and legal bases with respect to Juliano's search and subsequent arrest. View "Juliano v. Delaware" on Justia Law

Appellant Luis Sierra was convicted on two counts of Murder in the First Degree, three counts of Possession of a Firearm During the Commission of a Felony, Robbery in the First Degree, and Conspiracy in the Second Degree. His convictions were affirmed on direct appeal. His motion for postconviction relief was denied by the Superior Court. On appeal, Sierra claimed the Superior Court erred in rejecting his contention that he received ineffective assistance of counsel at trial because his counsel: (1) failed to call available fact and expert witnesses; (2) failed to object to prejudicial testimony offered by the State; and (3) failed to object to prosecutorial misconduct during closing arguments. He also claimed the Superior Court’s denial of his motion was inconsistent with Fowler v. Delaware, 194 A.3d 16 (Del. 2018). Finding no reversible error in the Superior Court's judgment, the Delaware Supreme Court affirmed. View "Sierra v. Delaware" on Justia Law

Todd Green appealed the Superior Court’s denial of his motion for postconviction relief under Superior Court Criminal Rule 61. Green was arrested during the first week of June 2014 after his girlfriend’s thirteen-year old daughter reported to her sister, a sexual abuse nurse examiner and a Child Advocacy Center forensic interviewer, that Green had raped her on the evening of May 28, 2014 and that “it wasn’t the first time.” A grand jury returned a twenty-two count indictment against Green, and after a five-day trial, he was convicted by jury on three of those counts: attempted rape in the second degree, attempted sexual abuse of a child, and unlawful sexual contact in the second degree. After a pre-sentence investigation, the Superior Court sentenced Green to a cumulative period of Level V incarceration of 50 years and nine months. To the Delaware Supreme Court, Green appealed his convictions. arguing that the jury’s exposure to several instances of inadmissible testimony had a “cumulative prejudicial effect” and deprived him of a fair trial. The Supreme Court rejected that argument and affirmed the Superior Court’s judgment, concluding that “[a]ny prejudicial effect of the testimony relied upon by Green [was] . . . far outweighed by the overwhelming evidence of his guilt.” Green then filed a pro se motion for postconviction relief, alleging his trial counsel was ineffective throughout the trial in violation of his Sixth, Eighth, and Fourth Amendment rights under the United States Constitution and under Article I, sections 4, 7, and 11 of the Delaware Constitution. Several of the issues at the heart of Green’s ineffective-assistance claims were touched upon in the Supreme Court's earlier order denying Green’s direct appeal, but a few were not. So Green also alleged in his motion that his counsel on direct appeal was ineffective for not raising those issues. A Superior Court Commissioner “recommend[ed] that Green’s motion be denied as procedurally barred by Rule 61(i)(3) and (4) for failure to prove cause and prejudice and as previously adjudicated.” The trial judge, without addressing the commissioner’s procedural-bar analysis, adopted the Commissioner’s Report and Recommendation and denied Green’s motion. In this appeal, Green dropped his claim that his appellate counsel was ineffective, but challenged the Superior Court’s determination that his claims were procedurally barred and that his trial counsel rendered constitutionally effective representation. Although the Supreme Court agreed with Green that his claims were not procedurally barred under Rule 61(i)(3) and (4), the Supreme Court concluded nonetheless that Green’s trial counsel’s performance, viewed as a whole, did not fall below an objective standard of reasonableness. Therefore, the Court affirmed. View "Green v. Delaware" on Justia Law

Appellant Dakai Chavis appealed his conviction of first-degree criminal trespass. He raised one issue on appeal to the Delaware Supreme Court: the Superior Court erred during his jury trial by admitting evidence of two prior convictions under Delaware Rule of Evidence 404(b). After review of the trial court record, the Supreme Court determined the evidence of Appellant's prior convictions should not have been admitted, and thus reversed the superior court order. The matter was remanded for further proceedings. View "Chavis v. Delaware" on Justia Law

The Division of Family Services ("DFS") investigated allegations that the minor, Appellant Daniel Spintz, sexually assaulted his younger sister. After its investigation, DFS determined to substantiate and place Spintz on the Child Protection Registry. This appeal concerned whether DFS provided adequate notice of its intent to substantiate and place Spintz on the Child Protection Registry. On November 27, 2017, DFS sent Spintz and his guardian the Notice through certified and regular mail. The certified mail was not successfully delivered and returned to DFS. On April 10, 2018, after the conclusion of parallel delinquency proceedings, DFS filed the Petition with the Family Court. DFS also sent Spintz and his guardian the Petition with a copy of the Notice attached for reference. Spintz claimed he did not receive the November 2017 notice, and only became aware of the substantiation proceedings in April 2018 when he received the Notice attached to the Petition. The Family Court commissioner concluded the Notice sent with the Petition in April 2018 satisfied all statutory and constitutional notice requirements. On review, the Family Court affirmed the commissioner's order. After considering the parties’ arguments and the record on appeal, the Delaware Supreme Court found that Delaware law required DFS to send the Notice of Intent to Substantiate before DFS files the Petition for Substantiation. Therefore, DFS did not meet its notice requirement by sending the Notice with the already-filed Petition. That, however, did not change the ultimate outcome of this appeal because DFS introduced evidence showing that it sent the Notice by certified mail on November 27, 2017, long before it filed the Petition. DFS also sent the Notice by regular mail at that time; and it sent the Notice a second time on April 10, 2018, which Spintz received. Based on this evidence, the Supreme Court concluded that DFS provided adequate notice that satisfied statutory and constitutional requirements. View "Spintz v. DFS" on Justia Law