Justia Criminal Law Opinion Summaries

Defendant-appellant Jermaine Wright appealed a Superior Court order that denied his fourth motion for postconviction relief, and for reimposing Wright's conviction and sentence. Wright was convicted by jury in 1992 for first-degree murder, first-degree robbery and related weapons charges in connection with the death of a liquor store clerk. Wright was then sentenced to death. At trial, the State did not present any forensic evidence including fingerprints, shoe prints, or fibers placing Wright at the scene. Nor did the State present the murder weapon, shell casings, the getaway car, or eyewitnesses to identify Wright. Instead, a jury convicted Wright on his confession to the police while under the influence of heroin and the testimony (since recanted) of a prison informant who testified that Wright admitted the crime. In 2012, the Superior Court vacated Wright’s conviction and sentence because it had “no confidence in the outcome of the trial.” The Superior Court also found that Wright did not knowingly and intelligently waive his Miranda rights because police obtained his confession through defective warnings. The remaining claims were denied. The State appealed, and a majority of the Delaware Supreme Court reversed, ordering Wright’s conviction and sentence reimposed, because the Miranda issue was procedurally barred and that, given his confession, the evidence about the Brandywine attempted robbery would not have led to a different result. After a reinstatement of his conviction and sentence, Wright now appealed his remaining claims originally denied by the Superior Court. “[W]hen the State withholds from a criminal defendant evidence that is material to his guilt or punishment, it violates his right to due process of law in violation of the Fourteenth Amendment. This is exactly what happened here." The Supreme Court vacated Wright’s conviction and death sentence and remanded the case for a new trial. View "Wright v. Delaware" on Justia Law

Defendant-appellant Iziah Ashley appealed his convictions on two counts of Rape in the Second Degree, three counts of Unlawful Sexual Contact with a Child Under the Age of 13, Bribing a Witness, Interfering with a Child Witness, and Conspiracy in the Second Degree. On appeal, defendant argued: (1) the trial court abused its discretion when it denied severance of several claims because a single trial did not serve the judicial economy and caused substantial prejudice to defendant; (2) the trial court abused its discretion and violated Ashley’s right to a fair trial when it refused to grant a mistrial or issue a curative instruction when the State elicited highly prejudicial testimony from the victim’s mother; and, (3) the cumulative impact of all of the errors amounts to plain error. Upon review, the Supreme Court concluded that defendant's claims were without merit. Therefore, the judgments of the Superior Court were affirmed. View "Ashley v. Delaware" on Justia Law

Defendant-appellant Darryl Copper appealed his convictions for Possession with Intent to Deliver Cocaine, Possession of a Firearm During the Commission of a Felony, Carrying a Concealed Deadly Weapon, and Possession of Drug Paraphernalia. Defendant contended he was denied his right to a fair trial by an impartial jury because the jurors heard him say that he was not content with the jury and because one juror heard him say that he wanted to take a plea. Finding Defendant's claims was without merit, the Supreme Court affirmed his convictions. View "Copper v. Delaware" on Justia Law

Defendant-Appellant Tiffany Parker was convicted of second-degree assault. She appealed that conviction, arguing the Superior Court erred in admitting statements posted on her Facebook profile. Defendant urged the Supreme Court to adopt Maryland's approach to admitting this kind of evidence: social media evidence could only be authenticated through the testimony of the creator, documentation of the internet history or hard drive of the purported creator's computer, or information obtained directly from the social networking site. Under this approach, social media evidence is only authenticated and admissible where the proponent can convince the trial judge that the social media post was not falsified or created by another user. The State argued the Delaware Court adopt the Texas approach: the proponent could authenticate social media evidence using any type of evidence so long as he or she could demonstrate to the trial judge that a jury could reasonably find that the proffered evidence was authentic. The Superior Court adopted the Texas approach and found that Defendant's social media post was sufficiently authenticated by circumstantial evidence and by testimony explaining how the post was obtained. On appeal, Defendant contended that social media evidence requires greater scrutiny. The Delaware Supreme Court concluded that the Texas approach better conformed to the requirements of Rule 104 and Rule 901 of the Delaware Rules of Evidence. The Court therefore found no abuse of discretion by the trial court in admitting the social media evidence in accordance with the Delaware Rules of Evidence, and affirmed. View "Parker v. Delaware" on Justia Law

Defendant-appellant Izzy Whitehurst appealed his conviction on First Degree Assault, Robbery in the First Degree, Burglary in the First Degree, Conspiracy in the Second Degree, three counts of Possession of a Firearm During the Commission of a Felony, and three counts of Tampering with a Witness. Defendant argued on appeal: (1) that the trial court erred in denying a motion to suppress his prison telephone calls because the State lacked a legal basis to collect them; and (2) that the admission of those prison telephone calls improperly tainted his trial. Finding no merit to his first contention, the Supreme Court did not address defendant's second contention, and affirmed his conviction. View "Whitehurst v. Delaware" on Justia Law

Defendant-Appellant Parris Hamilton appealed his conviction on two counts of Murder First Degree, two counts of Attempted Murder First Degree, two counts of Kidnapping First Degree, one count of Burglary First Degree, and seven counts of Possession of a Firearm During the Commission of a Felony. On appeal, defendant argued: (1) that the trial court erred when it allowed a nonlegal expert witness to make a misstatement of the law and failed to give a timely and adequate curative instruction; and (2) that the State failed to prove every element of the burglary charge. Finding no merit to Hamilton's claims, the Supreme Court affirmed. View "Hamilton v. Delaware" on Justia Law

Defendant Tyrone Guy appealed the denial of his application for postconviction relief. The issue before the Supreme Court in this case centered on how the procedural bars of Superior Court Criminal Rule 61 applied to his claims, including a claim of ineffective assistance of postconviction counsel. Defendant argued on appeal: (1) that the Superior Court erred during his trial by failing to give the "modified 'Bland'" jury instruction on accomplice testimony mandated by the Supreme Court's 2012 decision in "Brooks v. Delaware"; and (2) that his appointed counsel was ineffective in his first postconviction proceeding for failing to present ten out of eleven claims of ineffective assistance of trial counsel. Upon review, the Court concluded that defendant's claims were untimely and that his first claim was previously adjudicated. Defendant failed to meet the procedural burdens. Accordingly, the Court affirmed the Superior Court's judgment in this case, although it did so on independent and alternative grounds. View "Guy v. Delaware" on Justia Law

Defendant-appellant Kalvin Peterson a Superior Court judgment convicting him of one count of Possession of a Firearm by a Person Prohibited. Peterson's claim of error was that collateral estoppel and double jeopardy barred his conviction: that the bench trial conviction was precluded because at a concurrent trial, a jury acquitted him of both Possession of a Firearm During the Commission of a Felony, and the underlying felony of Assault in the First Degree. Upon review, the Supreme Court concluded that Peterson's arguments were without merit. View "Peterson v. Delaware" on Justia Law

Defendant-appellant Ronald Jones appealed his bench trial conviction on one count of Failing to Reregister as a Sex Offender. Jones raised one claim on appeal: that the evidence failed to show beyond a reasonable doubt that Jones had knowingly or recklessly failed to re-register as a homeless sex offender. Finding Jones' argument without merit, the Supreme Court affirmed his conviction. View "Jones v. Delaware" on Justia Law

Defendant Michael Neal appealed the denial of his motion for post-conviction relief. The issue before the Supreme Court in this matter was whether defendant received ineffective assistance of both trial and appellate counsel. Defendant was arrested after a series of robberies on New Year’s Eve 2008. Defendant argued that his trial and appellate counsel were ineffective for failing to request at trial, and for failing to argue on direct appeal: (1) the inclusion of a "Bland" instruction in connection with certain accomplice testimony; and (2) the admission of certain out-of-court statements under Delaware Rule of Evidence 804(b)(3). Ultimately, the Supreme Court held that the defendant's trial and appellate counsel were not ineffective in their representation. View "Neal v. Delaware" on Justia Law