Justiniano v. State

CourtSupreme Court of Delaware
DecidedMay 2, 2018
Docket342, 2017
StatusPublished

This text of Justiniano v. State (Justiniano v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Justiniano v. State, (Del. 2018).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

LEONARDO JUSTINIANO, § § No. 342, 2017 Defendant-Below, § Appellant, § Court Below: Superior Court § of the State of Delaware v. § § STATE OF DELAWARE, § Cr. ID No. 1606021176B (N) § Plaintiff-Below, § Appellee. §

Submitted: April 18, 2018 Decided: May 2, 2018

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

ORDER

This 2nd day of May, 2018, having considered the briefs and the record below,

it appears to the Court that:

(1) Leonardo Justiniano appeals from a Superior Court conviction of

possession of a firearm by a person prohibited. Justiniano claims that the Superior

Court abused its discretion when it severed his person prohibited charge from his

other charges but allowed them to be heard consecutively by the same jury. After

careful review, we find that the Superior Court did not abuse its discretion by

allowing the same jury to hear the person prohibited charge after the trial for his

other charges. We affirm the Superior Court’s decision. (2) On the evening of June 25, 2016, three men challenged Walter Torres-

Santiago to a fight in front of his apartment in the Maryland Park apartment complex.

During the fight, Torres-Santiago was knocked to the ground, and, as he tried to get

up, a fourth man allegedly pointed a gun at Torres-Santiago and asked him, “are you

ready?”1 A bystander interrupted the fight and the four assailants fled. Torres-

Santiago told police that he recognized Justiniano as the one who pointed the gun at

him and later identified Justiniano in a photo line-up.

(3) On June 29, 2016, the police arrested Justiniano as he was leaving an

apartment in the Towne Estates apartment complex. Inside the apartment, the police

found little furniture or personal belongings, but found a nine-millimeter handgun

and ammunition. A grand jury indicted Justiniano for aggravated menacing,

possession of a firearm during the commission of a felony, possession of a firearm

by a person prohibited, and second and third degree conspiracy.

(4) Before trial, Justiniano moved to sever the person prohibited charge

from the aggravated menacing, possession of a firearm during the commission of a

felony, and third degree conspiracy charges. He argued that trying the charges

together would allow a jury to “infer a general criminal disposition of the defendant

1 App. to Opening Br. at 27 (Trial Tr., State v. Justiniano, No. N1606021176B, at 69–71 (Del. Super. Feb. 9, 2017)).

2 which may affect its judgment regarding the other indicted counts.”2 On February

9, 2017, the court granted Justiniano’s motion but, over defense counsel’s objection,

ordered that the same jury would hear both trials, first for the aggravated menacing,

possession of a firearm during the commission of a felony, and third degree

conspiracy charges, and second for the possession of a firearm by a person prohibited

charge.

(5) In the first trial, the jury heard evidence about the incident outside the

Maryland Park apartments and the gun found at the Towne Estates apartment, but

did not hear evidence about Justiniano’s person prohibited status. The bystander

testified that one of the men had a gun. Torres-Santiago testified that the gun pointed

at him resembled the gun found at the apartment. The jury could not reach a verdict,

and the court declared a mistrial.

(6) In the second trial, the court instructed the jury, “there is an additional

count that must be heard separately from the counts you just considered. I will

provide you an additional instruction on this count, but also understand that all of

the testimony and evidence that was previously admitted may be considered.”3 The

court then read a stipulation to the jury stating that Justiniano was a person

prohibited. In its closing argument, the State told the jury that the person prohibited

2 Id. at 21 (Pet’rs Mot. for Relief from Prejudicial Joinder, Justiniano, No. N1606021176B, at 4 (Del. Super. Jan. 9, 2017)). 3 Id. at 44 (Trial Tr., at 113).

3 charge concerned whether “the defendant possessed or controlled the physical

weapon that was found [at the Towne Estates apartment] independently of whether

or not you believe this was the weapon that was used in that initial incident [outside

the Maryland Park apartments].”4 The State explained that the evidence from the

first trial “now becomes circumstantial evidence”5 that “linked [Justiniano] a couple

days prior to having a firearm in his hands.”6 The jury found Justiniano guilty of

possession of a firearm by a person prohibited and the court sentenced him to eight

years at Level V suspended after five years, followed by six months Level IV, and

eighteen months at Level III. Justiniano appealed.

(7) “This Court reviews the trial court’s decision on a motion to sever for

abuse of discretion.”7 The Superior Court’s decision will not be overturned unless

there is a “reasonable probability” that the decision resulted in “substantial

prejudice.”8 “The defendant has the burden of demonstrating such prejudice and

mere hypothetical prejudice is not sufficient.”9

(8) Charges are joined to “promote judicial economy and efficiency,

provided that the realization of those objectives is consistent with the rights of the

4 Id. at 46 (Trial Tr., at 121). 5 Id. (Trial Tr., at 123). 6 Id. at 47 (Trial Tr., at 127). 7 Phillips v. State, 154 A.3d 1130, 1138 (Del. 2017). 8 Id. (quoting Skinner v. State, 575 A.2d 1108, 1118 (Del. 1990)). 9 Skinner, 575 A.2d at 1118.

4 accused.”10 Under Superior Court Criminal Rule 8(a), charges may be joined if they

“are of the same or similar character or are based on the same act or transaction or

on two or more acts or transactions connected together.” The trial court has

discretion to order “separate trials of counts, grant a severance of defendants or

provide whatever other relief justice requires.”11

(9) Joinder can prejudice a defendant when: (1) the jury “cumulate[s] the

evidence of the various crimes charged and find[s] guilt when, if considered

separately, it would not so find”; (2) the jury “use[s] the evidence of one of the

crimes to infer a general criminal disposition of the defendant in order to find guilt

of the other crime or crimes”; or (3) the defendant is “subject to embarrassment or

confusion in presenting different and separate defenses to different charges.”12 The

purpose of severance in person prohibited cases is to prevent a jury from inferring a

criminal disposition based on a defendant’s criminal history.13

(10) On appeal, Justiniano argues the Superior Court abused its discretion

because allowing both trials to be heard by the same jury caused him unfair

10 Wiest v. State, 542 A.2d 1193, 1195 (Del. 1988) (quoting Mayer v. State, 320 A.2d 713, 717 (Del. 1974)). 11 Super. Ct. Crim. R. 14. 12 Wiest, 542 A.2d at 1195. 13 See State v. Williams, 2007 WL 2473428, at *1 (Del. Super. Aug.

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Related

Boyer v. United States
132 F.2d 12 (D.C. Circuit, 1942)
Mayer v. State
320 A.2d 713 (Supreme Court of Delaware, 1974)
Wiest v. State
542 A.2d 1193 (Supreme Court of Delaware, 1988)
State v. Cooke
909 A.2d 596 (Court of Chancery of Delaware, 2006)
Monroe v. State
28 A.3d 418 (Supreme Court of Delaware, 2011)
Phillips v. State
154 A.3d 1130 (Supreme Court of Delaware, 2017)
Skinner v. State
575 A.2d 1108 (Supreme Court of Delaware, 1990)
Taylor v. State
76 A.3d 791 (Supreme Court of Delaware, 2013)
Ashley v. State
85 A.3d 81 (Supreme Court of Delaware, 2014)

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Justiniano v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/justiniano-v-state-del-2018.