Benson v. State

Supreme Court of Delaware·Decided November 6, 2020·No. 497, 2019·Published

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

JEREMY L. BENSON, § § Defendant Below, § No. 497, 2019 Appellant, § § Court Below—Superior Court v. § of the State of Delaware § STATE OF DELAWARE, § Cr. ID No. 1712014868A (N) § Plaintiff Below, § Appellee. §

Submitted: September 4, 2020 Decided: November 6, 2020

Before SEITZ, Chief Justice; VALIHURA and VAUGHN, Justices.

ORDER

Upon consideration of the parties’ briefs and the record on appeal, it appears

to the Court that:

(1) The defendant below-appellant, Jeremy L. Benson, filed this appeal

from his conviction for attempted first-degree rape as a lesser-included offense of

first-degree rape. After careful consideration of the parties’ arguments, we affirm

the Superior Court’s judgment.

(2) In February 2018, a New Castle County grand jury charged Benson

with first-degree rape and sex offender unlawful conduct against a child. The parties

agreed to try the rape charge first, and separately, from the other charge. In March

2019, the first trial ended in a mistrial. (3) The evidence presented at the second trial, in June 2019, established

that a therapist reported a child’s (“the Child”) disclosure of sexual abuse in March

2017. The Child, who was born in 2003, disclosed that he had sexual contact with

his younger sister1 and that Benson, his uncle, had molested him. According to the

police reports of the Wilmington Police Department detective assigned to investigate

the case, the Child reported that Benson assaulted him at the family’s Church Street

address in 2015 or 2016. The detective later learned that the family moved out of

the Church Street address to live at a new address by October 1, 2014, but did not

update his reports. It was unknown when the family moved into the Church Street

address, but the Child’s father thought they lived there for about a year-and-a-half.

(4) The Child’s mother, who suffered from seizures that sometimes

affected her memory, testified that Benson was her brother. Both of the Child’s

parents recalled an incident at the Church Street address involving Benson. They

had left the residence, possibly to find food for the family. While they were gone,

they left the Child in charge of his four younger siblings. The children understood

that they were not to open the door to anyone and that Benson was not permitted

inside the home.

1 The Superior Court granted Benson’s motion to offer evidence relating to the Child’s sexual conduct under Delaware’s rape shield law, 11 Del. C. § 3508. Benson’s defense at trial was that the Child and his family members lied about what Benson did to the Child because they feared the Child could go to jail for what he did to his sister.

2 (5) The Child called his parents to report that Benson came inside the

house. The parents returned to the home where they found Benson (inside the house

according to the Child’s mother and outside the house according to the Child’s

father). The Child’s mother and Benson got into an argument. Benson was upset

that one of the children had told him to “get the F out” and said the children could

“suck his dick.”2 After the Child’s mother shoved Benson into a fireplace, Benson

left the house. The parents yelled at the Child and punished him for letting Benson

into the house.

(6) After the family moved out of the Church Street address, the parents

noticed that the Child was lying, stealing, and acting angry. In 2017, one of the

Child’s younger sisters told the parents that the Child had touched her

inappropriately. The mother testified that when she and the father spoke to the Child

about this, he disclosed for the first time that Benson had sexually assaulted him.

The father testified that the Child did not disclose Benson’s assault at that time.

(7) Both parents testified that they were concerned the Child might go to

jail because of what he did to his sister. They chose not to contact the police, but

instead took the Child to a therapist. After the Child told the therapist about what

he had done to his sister and what Benson had done to him, the therapist reported

2 Appendix to State’s Answering Brief at B290.

3 the incidents to the authorities. The father testified that he learned of Benson’s

assault after the Child disclosed it to the therapist.

(8) The Child testified that Benson forced his way into the Church Street

home after the parents left the Child alone with his younger siblings. The Child was

downstairs and his four younger siblings were upstairs. After hearing a knock at the

door, the Child opened the door even though his parents had told the children not to

open the door when they were not there. When the Child saw it was Benson at the

door, he tried to close the door because Benson was not allowed in the house.

Benson pushed his way into the house and pulled the Child in the bathroom. The

Child testified that Benson locked the bathroom door, bent the Child over the

bathtub, put his hand over the Child’s mouth, pulled down the Child’s pants and

underwear, and put his penis between the Child’s buttocks. The Child was not sure

if Benson’s penis penetrated his anus, but said there was pain.

(9) After the Child’s younger brother cursed and told Benson to get out of

the house, Benson pulled up his pants, unlocked the bathroom door, and left the

bathroom. Before leaving the bathroom, Benson told the Child that if he told anyone

about what had happened, Benson would kill his parents. Benson left the house to

sit outside in his car.

(10) The Child called his parents about Benson coming into the house. The

parents came home and got into a fight with Benson in the house. The Child testified

4 that his mother shoved Benson into a fireplace. The Child did not tell his parents

about what happened in the bathroom because they were already angry with him for

opening the door and he did not want to cause more trouble. The Child said he did

not tell his parents about what Benson had done until shortly before or around the

time they learned what he had done to his younger sister. The Child admitted that

he was charged with felonies for what he did to his younger sister.

(11) On direct and cross-examination, the State and Benson explored

differences between the Child’s trial testimony and his previous accounts of the

assault. These differences included: (i) the Child stating during a May 2017

interview at the Children’s Advocacy Center (“CAC”) that Benson bent him over a

sink, not a bathtub, and that only two, instead of four, of his younger siblings were

in the house at the time of the assault; (ii) the Child stating on another occasion that

Benson put his elbow, not his hand, over his mouth; and (iii) the Child telling his

therapist that Benson almost molested him, but did not because his younger brother

started yelling.

(12) Two of the Child’s younger siblings also testified about the incident at

the Church Street home. The younger brother testified that he was standing on the

stairs when he saw Benson push past the Child to come into the house and go toward

the bathroom. The younger brother cursed and told Benson to get out because he

was not supposed to be in the house. Benson left the bathroom and demanded to

5 know who had cursed at him. According to the younger brother, the Child had a

weird look on his face and tears in his eyes. When asked why he said only he, the

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