Muhammad v. State

CourtSupreme Court of Delaware
DecidedJanuary 20, 2022
Docket7, 2020
StatusPublished

This text of Muhammad v. State (Muhammad 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
Muhammad v. State, (Del. 2022).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

JAMEEL MUHAMMAD, § § No. 7, 2020 Defendant Below, § Appellant, § Court Below—Superior Court § of the State of Delaware v. § § Cr. ID. Nos: 1904007225(N) STATE OF DELAWARE, § 1905000605(N) § 1905000911(N) Appellee. §

Submitted: November 17, 2021 Decided: January 20, 2022

Before SEITZ, Chief Justice; VALIHURA, VAUGHN, TRAYNOR, and MONTGOMERY-REEVES, Justices, constituting the Court en banc.

ORDER

This 20th day of January, 2022, the Court has considered the parties’ briefs,

the record on appeal, and the argument of counsel, and it appears that:

(1) In this criminal appeal, Jameel Muhammad, who entered guilty pleas

and was sentenced with the assistance of an Office of Defense Services (“ODS”)

lawyer, contends that the Superior Court violated his right to self-representation by

forcing him to utilize the ODS lawyer despite his earlier knowing, intelligent, and

voluntary waiver of his right to counsel.

(2) In the summer of 2019, a New Castle County grand jury returned two

indictments charging Muhammad with eight felonies and two misdemeanors. (3) In the first indictment, Muhammad was charged with two counts of

human trafficking and two counts of forced sexual servitude. This order refers to

the first indictment as the “Trafficking Case.” Muhammad’s arrest in this case

followed statements to police by two individuals who admitted that they worked as

prostitutes under Muhammad’s supervision and control. One of the reporting

individuals alleged that Muhammad would beat her if she did not make a specified

amount of money for him on a daily basis. If convicted on all counts under this

indictment, Muhammad faced 100 years of Level V incarceration, eight of which

would have been mandatory—that is, they could not be suspended.

(4) In the second indictment, Muhammad was charged with numerous drug

offenses, including three counts of drug dealing. This order refers to the second

indictment as the “Drug Cases.” Under those counts, the indictment alleged that

Muhammad possessed with intent to deliver 20 grams or more of cocaine on April

10, 2019, and that, on May 2, 2019, he possessed with intent to deliver

methamphetamine and cocaine.

(5) Muhammad was arrested for the April offenses after police officers

encountered him in a motel room in Newark, Delaware. A search of that room

uncovered, among other things, $3,164.00 in United State currency, crack cocaine,

marijuana, and paraphernalia typically used to smoke crack cocaine and package

heroin.

2 (6) The May charges were the product of a controlled purchase the police

had arranged with the assistance of a confidential informant. When Muhammad

arrived where the transaction was to occur, the police arrested him, finding

methamphetamine in his lap and a large amount of cash on his person. A search of

Muhammad’s sport utility vehicle uncovered two bags containing crack cocaine.

(7) If convicted on all counts in the Drug Cases, Muhammad faced 42 years

of Level V incarceration, two of which would have been mandatory. Thus, if

convicted on all counts under both indictments, Muhammad faced 142 years of

Level V incarceration, and ten of those years would have been mandatory.

(8) Muhammad was on probation when he was arrested in April and May

of 2019.

(9) Before the indictments were filed, and in particular when Muhammad’s

cases were pending in the Court of Common Pleas for preliminary-hearing purposes,

Muhammad made it known that he was not pleased with the ODS lawyer assigned

to his case. In this Order, we refer to the ODS lawyer as Trial Counsel. In fact,

when Muhammad appeared in the Court of Common Pleas for his preliminary

hearing on the drug charges arising from his April arrest, the Court of Common Pleas

“released” Trial Counsel from representing Muhammad at that stage of the

3 proceedings1 and told Muhammad that he would either have to hire private counsel

or represent himself.2

(10) Two days after the indictment in the Drug Cases was filed, Trial

Counsel filed a motion to withdraw as counsel in the Superior Court, but only as to

the Trafficking Cases. In the motion, Trial Counsel advised the court that

Muhammad had “expressed to the Court of Common Pleas, to Counsel, and to

Counsel’s supervisors that [Muhammad] wishes [Trial Counsel] to be removed from

this case.”3

(11) At the outset of the hearing on Trial Counsel’s motion to withdraw,

Muhammad told the court that “he did not necessarily want to represent himself, but

rather he did not wish Trial Counsel to represent him.”4 This theme—that

Muhammad would prefer to be represented by counsel, just not Trial Counsel—

recurs throughout the relevant interactions between Muhammad and the trial court.

(12) The Superior Court then conducted a colloquy with Muhammad to

determine whether Muhammad was knowingly and intelligently waiving his right to

counsel. It is undisputed that this colloquy satisfactorily adhered to the guidelines

1 App. to Opening Br. at A116. 2 Id. at A115. 3 Id. at A237. 4 Opening Br. at 15. App. to Opening Br. at A242–243 (“This is my first time being heard, and I never stated that I want to go pro se in my preliminary hearing phase under another jurisdiction. I stated that I would go pro se if I couldn’t get proper representation or whatever.”) 4 this Court adopted in Briscoe v. State5 for determining whether a defendant is

knowingly and intelligently waiving his Sixth Amendment right to counsel.

Satisfied with Muhammad’s responses during the colloquy, the court concluded that

Muhammad had knowingly, voluntarily, and intelligently waived his right to counsel

and granted Trial Counsel’s motion to withdraw.

(13) At this juncture, therefore, Muhammad was proceeding pro se as to the

Trafficking Case, but was still represented by Trial Counsel in the Drug Cases. That

Trial Counsel still represented Muhammad in the Drug Cases was confirmed by Trial

Counsel’s September 16, 2019 letter to the court stating that, despite a recently filed

federal lawsuit in which Muhammad had named Trial Counsel as a defendant—a

stratagem apparently designed to create a conflict of interest so that other counsel

would be assigned to Muhammad’s case—“it [was] not [ODS’s] intention to re-

assign or declare a conflict[]”6 in the Drug Cases.

5 Briscoe v. State, 606 A.2d 103, 106 (Del. 1992) (adopting guidelines enunciated by the United States Court of Appeals for the Third Circuit in United States v. Welty, 674 F.2d 185 (3d Cir. 1982). Under the Briscoe/Welty guidelines, the trial court should advise the defendant: (1) that the defendant will have to conduct his defense in accordance with the rules of evidence and criminal procedure, rules with which he may not be familiar; (2) that the defendant may be hampered in presenting his best defense by his lack of knowledge of the law; (3) that the effectiveness of his defense may well be diminished by his dual role as attorney and accused; (4) the nature of the charges; (5) the statutory offenses included within them; (6) the range of allowable punishments thereunder; (7) possible defenses to the charges and circumstances in mitigation thereof; and (8) all other facts essential to a broad understanding of the whole matter. 6 App to Opening Br. at A260.

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