Justia Criminal Law Opinion Summaries

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

In August 2022, Corey Reyes was involved in an altercation with his girlfriend, Jennifer Deems, which resulted in Deems sustaining a broken leg. Reyes was subsequently arrested and charged with second-degree assault, resisting arrest with force or violence, and disorderly conduct. At trial, Reyes and Deems provided differing accounts of the events leading up to the assault. Reyes was found guilty on all charges.The Superior Court of the State of Delaware allowed an amendment to Reyes's indictment during the trial, changing the citation of the statute under which he was charged with resisting arrest. Reyes appealed his conviction, arguing that the amendment was substantive and thus impermissible. He also claimed that the prosecution made statements that constituted prosecutorial misconduct, affecting the integrity of the trial process and his substantive rights.The Supreme Court of the State of Delaware affirmed the lower court's decision. The court found that the amendment to Reyes's indictment was one of form rather than substance, and thus permissible. The court also found that while some of the prosecutor's statements were improper, they did not rise to the level of plain error that would warrant reversal of Reyes's conviction. The court further noted that the prosecutor's statements did not constitute repetitive errors over multiple trials that would require reversal. View "Reyes v. State" on Justia Law

In the case of James McDougal v. State of Delaware, McDougal was convicted of possession of a firearm by a person prohibited, possession of ammunition by a person prohibited, and carrying a concealed deadly weapon. His convictions and sentence followed the Superior Court’s denial of his pretrial motion to suppress evidence obtained from him during a street encounter with police officers. According to the State, the police had reasonable suspicion that McDougal was loitering, which justified his initial detention. A subsequent pat-down search revealed a concealed firearm. McDougal appealed the denial of his motion to suppress.The Supreme Court of the State of Delaware reversed and vacated the lower court’s judgment. The court found that the officers' suspicion of loitering was not reasonable and did not justify even a limited investigative seizure. The court also stated that the citizen is not required to answer the officer’s questions during a consensual encounter, and his refusal to answer cannot form the basis for reasonable suspicion of criminal activity. Applying these principles, the court concluded that the detention of McDougal and the consequent nonconsensual search of his person was unlawful. The court held that the Superior Court erred when it denied McDougal's motion to suppress. View "McDougal v. State" on Justia Law

Kathleen McGuiness, an elected state official in Delaware, was indicted and tried on various criminal charges related to her conduct while in office. She was convicted of three charges and acquitted of two others. She appealed, claiming that the trial was fundamentally unfair and unconstitutional. The Supreme Court of Delaware held that the trial was fair and rejected most of McGuiness's arguments. However, the court agreed with McGuiness that the legal insufficiency of one of the charges resulted in a spillover of evidence that prejudiced the jury’s consideration of a closely linked charge. Therefore, the court reversed McGuiness's conviction for Official Misconduct. The case was remanded for further proceedings. The court also affirmed the trial court's decisions and McGuiness's convictions on all other charges. View "McGuiness v. State" on Justia Law

In 2019, Jose Terreros was left in charge of his girlfriend's children. Upon returning home, his girlfriend was informed by her four-year-old daughter that Terreros had sexually abused her. The girlfriend immediately asked Terreros to leave and called the police. She later discovered concerning web searches on Terreros's phone, which he had left behind, including queries about how long saliva and fingerprints remain on bodies and clothes, and whether police can detect if a child has been raped. Based on this, investigators obtained a warrant to search Terreros's phone. They searched his messages, messaging apps, photos, videos, internet search history, GPS coordinates, and incoming and outgoing calls without any date restrictions. On trial, Terreros was found guilty of Sexual Abuse of a Child and Dangerous Crime Against a Child, but not guilty of Rape First Degree. Terreros appealed his conviction, arguing that the warrant was overbroad and that the verdicts were inconsistent. The Supreme Court of the State of Delaware agreed with Terreros regarding the warrant, finding it to be a general warrant and thus unconstitutional. The court held that all evidence obtained from the phone should have been suppressed. The court also remanded the inconsistent verdicts issue back to the lower court for further consideration, as it had not been fully addressed by the State. The court reversed Terreros's convictions and remanded the case for further proceedings. View "Terreros v. State" on Justia Law

In the Supreme Court of the State of Delaware, defendant Kwesi Hudson, who was convicted of first-degree kidnapping, first-degree robbery, second-degree rape, and other crimes, appealed on two grounds. First, he challenged the Superior Court's decision to deny his pre-trial motion to exclude the State’s expert testimony on DNA mixture interpretation and technology. He argued that the STRmix software used to process the DNA was not scientifically reliable. Second, he contended that the Superior Court erred in denying his motion to suppress cell-site location information collected from cell tower dumps via ten search warrants. He claimed that these warrants violated his rights under the Fourth Amendment to the United States Constitution, Article I, Section 6 of the Delaware Constitution, and Delaware statutory law. The Supreme Court of the State of Delaware found Hudson’s challenges to be without merit and affirmed his convictions and the decisions of the Superior Court. The court ruled that the DNA evidence was reliable and admissible, and that a Daubert hearing to test its admissibility was not necessary. Additionally, the court concluded that the cell tower warrants were constitutional under the Fourth Amendment, as they were sufficiently particular and based on probable cause. View "Hudson v. State" on Justia Law

In the case of the State of Delaware v. Taha El-Abbadi, El-Abbadi was convicted of Murder by Abuse or Neglect in the First Degree for causing the death of three-year-old Julian Cepeda. El-Abbadi appealed his conviction on the basis of two issues: the trial court's refusal to provide jury instructions for lesser-included offenses and the limitation on cross-examination and testimony regarding the victim's mother's past involvement with the Division of Family Services.The Supreme Court of Delaware upheld the conviction. The court found that the trial court did not err in refusing to provide jury instructions for the lesser-included offenses of Manslaughter and Criminally Negligent Homicide. The court reasoned that there was no evidence that would allow the jury to find El-Abbadi not guilty of the Murder by Abuse or Neglect charges and instead guilty of Manslaughter or Criminally Negligent Homicide.The court also found that the trial court did not err in limiting cross-examination and testimony regarding the victim's mother's past involvement with the Division of Family Services. The Supreme Court concluded that the exclusion of this testimony was not an abuse of discretion and did not constitute plain error. The court found that the mother's past involvement was distinct from the facts of the case and the witnesses were questioned about the delay in medical assistance, which was the key point the defense was trying to establish.The Supreme Court of Delaware, therefore, affirmed El-Abbadi’s conviction of Murder by Abuse or Neglect in the First Degree. View "El-Abbadi v. State" on Justia Law

The Supreme Court of the State of Delaware examined the Adult Expungement Reform Act and the Clean Slate Act, which expanded eligibility for expungement and created an automatic expungement process for certain Delaware criminal records. The Acts are applicable to "all criminal cases brought and convictions entered in a court in this State" and limit expungement to individuals with "no prior or subsequent convictions." The three petitioners, Alex Osgood, Osama Qaiymah, and Eric Fritz, requested expungement of their criminal records. However, the Superior Court denied their requests due to their prior or subsequent misdemeanor convictions from other states.The issue the Supreme Court had to decide was whether the phrase "prior or subsequent convictions" in the Acts includes out-of-state convictions. The court ruled that "prior or subsequent convictions" refers only to Delaware convictions, not to out-of-state convictions. The court reversed the Superior Court's decision and remanded the case for further proceedings in line with its opinion.In reaching its decision, the court considered the specific language of the Acts, their purpose and legislative intent, as well as practical considerations. The court also noted that including out-of-state convictions could lead to inconsistencies and impracticalities. View "Osgood v. State" on Justia Law

Defendant-appellant Larry Martin appealed the sentence he received after pleading guilty to one count of Stalking and two counts of Non-Compliance with Bond (“NCB”). The trial court entered its first sentencing order on August 12, 2022, followed by three corrected sentencing orders, entered on September 8, September 21, and October 17, 2022, respectively. It was undisputed that the trial court’s first sentencing order was illegal because it imposed a sentence that exceeded the maximum lawful sentence for Stalking, which was three years at Level V supervision. In an email dated August 29, 2022, Martin’s trial counsel informed the trial court of the illegality of the sentence, and that the State recommended that the trial court fix its error by redistributing Martin’s five-year prison sentence across the Stalking conviction and the two NCB convictions. In a corrected sentencing order, issued on September 8, 2022, the trial court reduced Martin’s sentence for Stalking to three years of incarceration at Level V supervision, to bring it in line with the lawful maximum sentence. The trial court then added one year of incarceration at Level V supervision, suspended for probation, to the suspended fines for each NCB conviction. It was undisputed that if this had been the original sentence, Martin’s sentence would have been lawful. Martin appealed the trial court’s sentencing order insofar as it modified his sentence for the NCB convictions, arguing that by increasing his sentence for the NCB convictions, the trial court effectively resentenced him for those convictions despite the fact that he had already served them. This was because those sentences consisted solely of fines that were suspended when imposed and as such, were completed as of the date of the sentence. According to Martin, he completed his sentence for both NCB convictions on August 12, 2022, and any subsequent resentencing was barred by principles of double jeopardy. The Delaware Supreme Court was not persuaded by this argument and affirmed the sentence imposed by the trial court in its September 8, 2022 sentencing order, as modified by the September 21, 2022 and October 17, 2022 sentencing orders. View "Martin v. Delaware" on Justia Law