Justia Criminal Law Opinion Summaries

Andrew Lloyd appeals his convictions for racketeering and other offenses related to his role in a Delaware heroin trafficking ring. He raised four issues on appeal: (1) the Superior Court abused its discretion by giving a jury instruction that did not adequately define “enterprise” according to the Delaware RICO statute; (2) the State presented insufficient evidence to prove that Lloyd was engaged in an “association-in-fact” enterprise under the RICO statute; (3) the State improperly vouched for and bolstered certain witnesses’ testimony by asking several of the witnesses about the contents of their plea agreements; and (4) the cumulative effect of the errors violated his due process rights. After a careful review of the record on appeal, the Delaware Supreme Court found no merit to any of these claims. Accordingly, the Court affirmed the Superior Court’s judgment. View "Lloyd v. Delaware" on Justia Law

The State appealed the superior court’s order granting Catherine Culp’s second pro se motion for sentence modification, which the court reviewed as a Motion for Review of Sentence. The superior court held that Culp’s rehabilitative efforts demonstrated “beyond cavil extraordinary circumstances” justifying reduction of her sentence pursuant to Superior Court Criminal Rule 35(b). On appeal, the State argued that the superior court abused its discretion in granting the Motion, which the State contended was barred as repetitive and untimely. After review, the Delaware Supreme Court concluded that the superior court’s modification of Culp’s sentence ignored the plain language of Rule 35(b) and established precedent, thereby abusing its discretion. Accordingly, the Supreme Court reversed the superior court’s order. View "Delaware v. Culp" on Justia Law

Defendant Tyrone Redden appealed the Superior Court’s Order denying his Amended Motion for Postconviction Relief. At issue in this appeal were two out-of-court statements introduced at Redden’s trial. In his Motion, Redden argued that his trial counsel was ineffective for failing to object to the statements after the State failed to ask each witness whether his or her out-of-court statement was truthful. Redden further argued that his appellate counsel was ineffective for failing to raise the same issue on direct appeal. The Superior Court denied the Amended Motion, holding that Redden’s claims were procedurally barred. After review, the Supreme Court agreed with the Superior Court that Redden’s claims were procedurally barred and affirmed the denial of Redden’s Motion. View "Redden v. Delaware" on Justia Law

The State appealed the grant of post-conviction relief to defendant-appellee Damone Flowers. The Superior Court recognized that Flowers post-conviction motion was untimely under Criminal Rule 61(i)(1) because he filed it three years after his conviction became final. However, the Superior Court invoked an exception to the procedural bars as a basis for addressing Flowers' motion on the merits. At the time of Flowers' second motion for relief, the bars to relief in Rule 61(1)(1)-(3) did not apply "to a colorable claim that there was a miscarriage of justice because of a constitutional violation that undermined the fundamental legality, reliability, integrity or fairness of the proceedings leading to the judgment of conviction." After its review, the Supreme Court concluded Flowers' second motion for relief was indeed untimely and that the exception was improperly invoked by the Superior Court. Accordingly, the Court reversed the Superior Court. View "Delaware v. Flowers" on Justia Law

Robert Ovens appealed the Superior Court’s reversal of the Delaware Human Relations Commission’s award of damages, attorney’s fees, and costs to Ovens based on the Commission’s determination that a prison was a place of "public accommodation." The Commission found that the Department of Correction (“DOC”), through its operation of Sussex Correctional Institution (“SCI”), violated section 4504(a) of the Delaware Code (known as theEqual Accommodations Law), by not providing equal accommodations to Ovens, who was deaf, while he was incarcerated. After review of the issue, the Delaware Supreme Court concluded that a prison was not a place of "public accommodation" as contemplated by the law. "Ovens’ argument hinges on his assertion that a prison is a state agency, and therefore, it falls under the second sentence of section 4502(14), which includes state agencies, local government agencies, and state-funded agencies in the definition of a place of public accommodation. But, he ignores that the second sentence of section 4502(14) cannot be decoupled from the critical language in the first." View "Ovens v. Danberg" on Justia Law

Defendant-appellant Joel Stevenson appealed convictions for first- and second-degree unlawful sexual contact and two counts of sex offender unlawful sexual conduct with a child. On appeal of those convictions, Stevenson argued that the trial court abused its discretion in admitting certain out-of-court statements of three child witnesses rebutting defendant's allegation that the State improperly influenced the witnesses' testimony. After review of the record, the Delaware found no merit to defendant's arguments and affirmed his convictions. View "Stevenson v. Delaware" on Justia Law

On June 24, 2013, a Grand Jury indicted appellant Kahlil Lewis on charges of second degree murder, two counts of possession of a firearm during the commission of a felony, first degree reckless endangering, and possession of a firearm by a person prohibited. In December, the State filed an information charging Lewis with an additional crime, possession of a firearm by a person prohibited - negligently causing death. A few days later, the Grand Jury re-indicted Lewis. The re-indictment repeated the charges in the original indictment, and added the new charge under 11 Del. C. 1448(e)(2). In this appeal, the issue presented for the Supreme Court's review concerned whether the Grand Jury properly indicted appellee for a crime under a criminal statute mistakenly repealed by the General Assembly. Appellant argued the Grand Jury improperly indicted him for an additional crime as part of a renewed indictment incorporating earlier charges because the General Assembly repealed the statute covering the added crime before he was re-indicted. The General Assembly discovered the mistake but did not re-enact the repealed subsection until after the re-indictment. The Delaware Supreme Court held, after review and consistent with decisions interpreting a similar federal saving statute, that Delaware’s criminal saving statute permitted the State to prosecute crimes under a repealed criminal statute when the crimes were committed before the statute’s repeal. Because Lewis committed the crime before the statute was repealed, he was still subject to prosecution under the later repealed statute. Lewis also raised other arguments on appeal, but the Court found no merit to those arguments and affirmed Lewis' convictions. View "Lewis v. Delaware" on Justia Law

Delaware charged defendant Benjamin Rauf with one count of First Degree Intentional Murder, one count of First Degree Felony Murder, Possession of a Firearm During those Felonies, and First Degree Robbery. The State expressed its intention to seek the death penalty if Rauf was convicted on either of the First Degree Murder counts. In January 2016, the United States Supreme Court held in "Hurst v. Florida" that Florida‘s capital sentencing scheme was unconstitutional. In light of the "Hurst" decision, the trial court in this matter certified five questions of law to the Supreme Court, asking the Supreme Court to address the constitutionality of Delaware's state's death penalty statute; the Superior Court believed that Hurst "reflected an evolution of the law that raised serious questions about the continuing validity of Delaware‘s death penalty statute." After review, the Court concluded that Delaware's death penalty statute conflicted with the Sixth Amendment, and prior cases on the constitutionality of Delaware's capital sentencing scheme were overruled to the extent they were inconsistent with this opinion. View "Rauf v. Delaware" on Justia Law

Tracey West was pulled over by police officer Thomas Gaul when her car was drifting back and forth in the lane. The officer saw the car swerve sharply to avoid hitting a concrete island. When he approached the car, Gaul smelled alcohol. West "staggered out of the car" and failed field sobriety tests. She was charged with an illegal lane change and driving under the influence. Before trial, West moved to suppress the evidence that she was intoxicated. She claimed that Officer Gaul lacked the reasonable suspicion required by the Fourth Amendment to make an investigative stop of her car. Thus, any evidence of her intoxication gathered after the stop should have been suppressed. After hearing testimony from the officer and reviewing the video from the police car camera, the trial judge dismissed the lane change charge, but denied the motion to suppress. The State then introduced at trial the evidence of her intoxicated state, and a jury convicted West of drunk driving. West appealed her conviction to the Superior Court, which affirmed the trial court’s ruling on the community caretaker doctrine, and also found that Officer Gaul had reasonable suspicion to stop West for driving while intoxicated. West then appealed to the Delaware Supreme Court, arguing the community caretaker doctrine did not apply, and Officer Gaul lacked reasonable suspicion as required by the Fourth Amendment for an investigatory stop of her car. Finding no reversible error, the Supreme Court affirmed. View "West v. Delaware" on Justia Law

Defendant-appellee Isaiah McCoy was a pretrial detainee awaiting trial on capital murder and related charges. In May 2010, McCoy was arrested and charged with the murder of James Munford in Dover. He was convicted and sentenced to death at his first trial in June 2012. In January 2015, the Supreme Court reversed his conviction and remanded the case for a new trial. Using a points-based, objective risk assessment tool, the Department of Correction classified him to be held in the maximum security Secured Housing Unit (“SHU”) at James T. Vaughn Correctional Center (“JTVCC”). McCoy filed a motion in the criminal case requesting that he be transferred from the SHU to the prison’s general population on the ground that detention at the SHU was interfering with his Sixth Amendment right to assistance of counsel. The Superior Court, over the State’s objection, granted McCoy’s motion, and McCoy was, in fact, transferred to general population. While McCoy had some complaints about the adequacy of the attorney visitation rooms in the SHU and access to the library, the Superior Court based its order in significant part upon its perception of “the emotional and physical impact that prolonged, solitary placement has had on [McCoy’s] Sixth Amendment right to assistance of counsel . . . .” The Superior Court found there that it had such jurisdiction under 10 Del. C. sec. 542, 11 Del. C. sec. 6504, and several other cases, to order the transfer of a detainee from maximum security to the general population. The State renewed its jurisdictional argument in this case. After review, the Delaware Supreme Court concluded that neither the Sixth Amendment right to assistance of counsel nor the statutes and cases relied upon by the Superior Court granted it the authority to transfer a detainee from one housing unit to another in a criminal case. The order of the Superior Court was, therefore, vacated. View "Delaware v. McCoy" on Justia Law