Justia Criminal Law Opinion Summaries

The defendant, while under the influence of illegal drugs, killed a police officer and assaulted several others. He claimed that his behavior was due to someone substituting bath salts for his methamphetamine, and sought to use a statutory involuntary intoxication defense. The Superior Court granted a motion in limine, preventing the presentation of this defense and deemed the defendant’s evidence inadmissible.The Superior Court of Delaware reviewed the case. The court examined whether a person who knowingly introduces an unlawful intoxicating substance into their body can present an involuntary intoxication defense if the substance or its effects differ from what was anticipated. The court concluded that under Title 11, Section 423 of the Delaware Code, a person who knowingly introduces an unlawful intoxicating substance into their body is precluded from presenting an involuntary intoxication defense unless certain statutory exceptions apply.The Delaware Supreme Court affirmed the Superior Court’s decision. The court held that the statutory language was unambiguous and that a person who knowingly introduces an unlawful intoxicating substance into their body cannot claim involuntary intoxication unless specific statutory exceptions are met. The court did not address the admissibility of the defendant’s evidence under Rule 702 and 11 Del. C. § 303, as the defense was unavailable as a matter of law. The court also found that precluding the defense did not violate the defendant’s constitutional right to present a complete defense. View "Wilkerson v. State" on Justia Law

In 2005, James E. Cooke, Jr. was convicted of the rape and murder of Lindsey Bonistall, a University of Delaware student. Cooke's first conviction was overturned in 2009 due to his defense counsel's strategy, which conflicted with Cooke's plea of not guilty. Cooke was retried in 2012, where he represented himself initially but was later replaced by standby counsel due to his disruptive behavior. He was again convicted and sentenced to death, which was affirmed by the Delaware Supreme Court in 2014.Cooke filed a motion for postconviction relief in 2015, claiming ineffective assistance of counsel and other errors. The Superior Court denied his motion, leading to this appeal. Cooke argued that his second-trial counsel failed to explore his competency to stand trial, did not adequately investigate the case, and failed to object to the State's peremptory challenges during jury selection. He also claimed cumulative errors and procedural issues with the court's denial of his continuance requests and discovery limitations.The Delaware Supreme Court reviewed the claims and found that Cooke's counsel acted reasonably given Cooke's insistence on testifying and his refusal to cooperate with mental health evaluations. The court also found that Cooke was competent to stand trial, and his counsel's decisions were within the bounds of reasonable professional assistance. The court held that Cooke's claims of cumulative error and procedural issues were without merit and affirmed the Superior Court's denial of postconviction relief. View "Cooke v. State" on Justia Law

Police were surveilling a known drug dealer in a high-crime area. The dealer arrived at a Wawa convenience store in a car driven by his girlfriend. The dealer exited the car and stood near the gas pump. The defendant approached the dealer on foot, and they conversed briefly. The dealer then had his girlfriend exit the car, sat in the driver’s seat, reached under it for several seconds, and returned to the defendant. They engaged in a brief hand-to-hand exchange and then departed. Believing they had witnessed a drug transaction, police stopped the defendant, who informed them he had a firearm in his bag. Police found the firearm but no drugs, and the defendant was arrested for illegally possessing the gun.The defendant was charged with carrying a concealed deadly weapon and possession of a firearm with an altered serial number. He moved to suppress the evidence, arguing that police lacked reasonable articulable suspicion to stop him. The Superior Court of Delaware denied the motion, finding that police had reasonable articulable suspicion based on their belief that the defendant and the drug dealer had engaged in a hand-to-hand drug transaction. The defendant was found guilty on both counts and appealed the denial of his suppression motion.The Supreme Court of Delaware reviewed the case and affirmed the Superior Court’s decision. The court found that the trial court’s factual findings were supported by sufficient evidence. It held that, based on the totality of the circumstances and the experienced officers’ interpretation of the facts, police had reasonable articulable suspicion to stop the defendant. The court concluded that the stop was justified, and the evidence obtained was admissible. View "Register v. State" on Justia Law

In the early morning of June 22, 2022, Luis Coello called 911 after a vehicle crash. When officers arrived, they found Coello in pain and lying on the ground. Officer Miller asked Coello to sit down for medical reasons and requested his license as part of the accident investigation. Coello, still in pain, began to walk away, prompting Miller to ask him to stay. Officers Braun and Strickland arrived and questioned Coello, who indicated he only spoke Spanish. Coello admitted to driving the vehicle involved in the crash. He was not arrested at the scene but was later indicted on charges of Vehicular Homicide, Vehicular Assault, and Unreasonable Speed.The Superior Court of Delaware denied Coello's motion to suppress his statements made at the crash scene, ruling that he was not in custody for Miranda purposes and thus not entitled to Miranda warnings. The court found that the questioning was part of a routine, on-scene investigation and that Coello's statements were voluntary. Coello was subsequently convicted of all charges.On appeal, Coello argued that his statements should have been suppressed as they were obtained in violation of the Fifth Amendment and the Delaware Constitution. The Supreme Court of Delaware reviewed the case and held that Coello was not in Miranda custody during the on-scene questioning. The court emphasized that the questioning was part of a routine investigation and that Coello was not physically restrained or arrested at the scene. Therefore, the court affirmed the Superior Court's decision to deny the motion to suppress and upheld Coello's conviction. View "Coello v. State" on Justia Law

In this case, the defendant was convicted of first-degree murder, possession of a firearm during the commission of a felony, and possession of a firearm by a person prohibited. The key facts involve a shooting incident in Wilmington, Delaware, where the victim, Lionel Benson, was shot and later died from complications related to his injuries. The police investigation identified the defendant as the shooter based on statements from witnesses who later recanted their testimonies at trial.The Superior Court of Delaware admitted prison communications between the defendant and another inmate, which were used to show a conspiracy to dissuade witnesses from testifying. The court also admitted redacted statements from a key witness, which the defendant argued created a false impression and hampered his defense. The jury found the defendant guilty on all charges, and he was sentenced to life imprisonment plus additional years for the firearm charges.The Supreme Court of Delaware reviewed the case and affirmed the Superior Court's decisions. The court held that the prison communications were admissible under the co-conspirator exclusion from hearsay and as evidence of the defendant's identity and intent. The court also found that the redactions to the witness's statements did not violate the defendant's due process rights or constitute plain error. Additionally, the court upheld the reasonable doubt jury instruction, finding it consistent with constitutional requirements and previous case law.The Supreme Court of Delaware concluded that the Superior Court did not abuse its discretion in its evidentiary rulings and that the defendant's convictions were supported by the evidence presented at trial. The court affirmed the defendant's convictions and sentences. View "Burrell v. State" on Justia Law

The case involves Rakiim Strickland, who was captured on surveillance video in possession of an assault weapon and discharging it in the direction of another person. Strickland, a convicted felon prohibited from possessing a firearm, was charged with possession of a firearm and ammunition by a person prohibited. At trial, the State presented video evidence showing Strickland with the weapon, which the jury viewed without objection from Strickland. Strickland was convicted and sentenced to 35 years in prison.Strickland appealed, arguing that the trial judge should have instructed the jury, sua sponte, to consider the video evidence only for identifying the person in possession of the firearm, not for any other improper purposes. He also contended that the trial court abused its discretion by allowing the prosecution to introduce evidence of two firearm-related convictions of a defense witness, which he claimed did not involve crimes of dishonesty.The Supreme Court of the State of Delaware reviewed the case. The court held that the video evidence was admissible as it directly proved the charged possessory offense and did not fall under the rule governing other, uncharged bad acts. The court found no plain error in the trial court’s failure to give a limiting instruction sua sponte. Regarding the defense witness's prior convictions, the court determined that any error in admitting the convictions was harmless, as the witness's credibility was already compromised by his relationship with Strickland and his other admissible conviction.The Supreme Court of the State of Delaware affirmed Strickland’s convictions. View "Strickland v. State" on Justia Law

In the fall of 2020, the Wilmington Police Department investigated the NorthPak street gang, which was involved in a series of violent crimes in Wilmington, Delaware. Gregory Wing, identified as a leader and shooter for NorthPak, was implicated in multiple shootings, including the murders of Ol-lier Henry and Taquan Davis. The investigation revealed that NorthPak was engaged in a violent feud with the M-Block Grimy Savages (MGS) gang. Wing was tied to the crimes through ballistics evidence, cell tower data, social media posts, and witness testimony. He was arrested in September 2020 with a firearm linked to the shootings.The Superior Court of Delaware tried Wing and his co-defendant Elijah Coffield together. The trial lasted 14 days, with over 50 witnesses and 600 exhibits. The jury found Wing guilty of gang participation, two counts of first-degree murder, and four counts of attempted first-degree murder, among other charges. He was sentenced to two life terms plus additional years in prison. Wing appealed, challenging two evidentiary rulings: the admission of a witness's out-of-court statement and the limitation on cross-examination of another witness.The Supreme Court of Delaware reviewed the case. Wing argued that the Superior Court erred in admitting Kenneth Griffin's out-of-court statement under 11 Del. C. § 3507, claiming it was not voluntary and not truthful. The court found that Griffin's statement was voluntary, as he initiated contact with the police and was read his Miranda rights. The court also determined that Griffin's indication of the truthfulness of his statement met the requirements of § 3507. Wing also contended that the court improperly restricted cross-examination of Tyrie Burton, a witness who testified against Coffield. The court held that the trial judge did not abuse his discretion in limiting the cross-examination to avoid Fifth Amendment issues.The Supreme Court of Delaware affirmed Wing's convictions and sentences. View "Wing v. State" on Justia Law

Shannon Watson was convicted of Assault Second Degree after striking Damon Howard in the face multiple times, resulting in severe and permanent head injuries. The incident occurred outside the bathroom of Catherine Rooney’s Irish Pub. Watson claimed he acted in self-defense due to prior tensions with Howard, who was his friend’s ex-boyfriend. Both men testified, providing conflicting accounts of the altercation. Watson argued that Howard had a history of violence and that he felt threatened during the encounter.The Superior Court of Delaware presided over the initial trial. Watson did not object to the trial court’s use of the term “victim” when referring to Howard, nor did he request a specific jury instruction regarding character evidence. The jury found Watson guilty, and he was sentenced to eight years in custody, suspended for one year at supervision Level II.The Supreme Court of Delaware reviewed the case on appeal. Watson argued that the trial court’s reference to Howard as the “victim” and the failure to issue a “character of the defendant” jury instruction constituted plain error. The Supreme Court held that the single reference to Howard as the “victim” did not amount to plain error, as it did not suggest the trial court’s acceptance of the State’s version of the facts. Additionally, the court found that the omission of a specific character evidence instruction did not deprive the jury of its ability to perform its duty, as the jury was adequately instructed to consider all evidence and determine the appropriate weight to give it. Consequently, the Supreme Court of Delaware affirmed Watson’s conviction. View "Watson v. State" on Justia Law

In December 2017, Antoine Terry was found dead from multiple gunshot wounds in New Castle, Delaware. The police arrested Terry’s friend, Shaheed Matthews, for the murder. In 2019, Matthews was tried for murder and possession of a firearm during the commission of a felony. The State's case relied on circumstantial evidence, including evidence from Matthews’s cellphone, witness testimony, video camera footage, and gunshot residue found on Matthews’s jacket. Matthews was convicted and sentenced to life plus three years in prison.Matthews appealed his conviction, arguing that his trial counsel was ineffective for failing to move to suppress evidence obtained from his cellphone. The Superior Court denied Matthews’s motion, concluding that Matthews had provided valid consent for the search of his cellphone and that the cellphone evidence had no bearing on the outcome of the case. Matthews appealed this decision to the Supreme Court of the State of Delaware.The Supreme Court of the State of Delaware reversed the Superior Court's decision. The court found that Matthews did not provide valid consent for the search of his cellphone and that the warrant obtained by police to search Matthews’s cellphone was an unconstitutional general warrant. The court also found that the cellphone evidence was material and significant to the State's case. Therefore, the court concluded that Matthews’s trial counsel’s failure to move to suppress the evidence obtained from his cellphone constituted deficient performance and prejudiced Matthews. The court vacated Matthews’s convictions and remanded the case to the Superior Court for a new trial. View "Matthews v. State" on Justia Law

The case revolves around Deonta Carney, who was indicted for crimes stemming from three separate incidents. In one of these incidents, Carney and an accomplice allegedly robbed a man named Angelo Flores of his dirt bikes. Although Carney did not physically hold the firearm used in the robbery, he was charged with possession of a firearm by a person prohibited due to his involvement in the crime. Initially, Carney rejected a plea offer from the State, but he changed his mind and accepted a revised plea offer on the morning of the trial when he learned that the victim had appeared to testify. However, before sentencing, Carney attempted to withdraw his guilty plea, arguing that he was "legally innocent" of the firearm possession charge because he did not physically hold the gun during the robbery.The Superior Court of the State of Delaware denied Carney's motion to withdraw his guilty plea. The court found no procedural defects in the plea colloquy and determined that Carney's plea was entered knowingly, intelligently, and voluntarily. The court also concluded that Carney had effective legal counsel throughout the proceedings and that granting the motion would prejudice the State. Regarding Carney's claim of innocence, the court found that Carney's plea colloquy statements were inconsistent with his later innocence assertion. The court also determined that there was sufficient factual basis to convict Carney of the firearms charge because he had constructive possession of the firearm during the robbery.Carney appealed to the Supreme Court of the State of Delaware, arguing that the Superior Court exceeded its discretion when it denied his motion to withdraw his guilty plea. However, the Supreme Court affirmed the Superior Court's judgment, concluding that the lower court did not exceed its discretion when it found that Carney did not present a fair and just reason to withdraw his guilty plea. The Supreme Court agreed with the lower court's assessment that Carney's claim of innocence was weak and that his involvement in the robbery was sufficient to establish constructive possession of the firearm. View "Carney v. State" on Justia Law