Newton v. State

CourtSupreme Court of Delaware
DecidedMarch 23, 2023
Docket200, 2022
StatusPublished

This text of Newton v. State (Newton 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
Newton v. State, (Del. 2023).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

CASSANDRA NEWTON, § § No. 200, 2022 Defendant Below, § Appellant, § Court Below: Superior Court § of the State of Delaware v. § § Cr. ID No. 2101006787 STATE OF DELAWARE, § § Appellee. §

Submitted: January 25, 2023 Decided: March 23, 2023

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

ORDER

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

to the Court that:

(1) Delaware State Police arrested Cassandra Newton for verbal threats she

made to a state trooper at the Delaware Division of Motor Vehicles. A New Castle

County grand jury indicted Newton for harassment, disorderly conduct, and

terroristic threatening of a public servant or public official. After a two-day trial, a

Superior Court jury found Newton guilty of harassment and disorderly conduct. The

court sentenced her to an aggregate of one year and thirty days at Level V

incarceration, with credit for two days served, suspended for one year of Level II

probation. (2) On appeal, Newton raises one issue contesting her conviction—the

Superior Court erred when it granted the State’s motion in limine to exclude

Newton’s anticipated testimony that Corporal Snook, the state trooper subject to

Newton’s harassment, had previous contact with her. Newton wanted to testify that

Corporal Snook arrested her eleven months earlier which allegedly caused her

miscarriage, and seeing him again triggered an “emotional, visceral reaction,” to

what she claimed was past trauma. The Superior Court excluded the testimony under

Rules 702 and 403 of the Delaware Rules of Evidence. We affirm Newton’s

conviction because the Superior Court did not exceed its discretion to exclude her

testimony under Rule 403.

(3) Newton’s first encounter with Corporal Snook occurred on February 9,

2020, when he arrested her and charged her with Resisting Arrest, Disorderly

Conduct, and Criminal Trespass. Newton claimed that she was pregnant at the time

of the arrest, but suffered a miscarriage immediately after, for which she blamed

Corporal Snook.1

(4) Eleven months later, in January, 2021, Newton encountered Corporal

Snook at the Department of Motor Vehicles where he was working on a security

1 Corporal Snook was cleared of any wrongdoing after an investigation into Newton’s allegations.

2 detail. According to Newton, the sight of Corporal Snook “triggered” her.2 Jennifer

Popo, Newton’s mother, observed that Newton sounded “very upset and excitable”

when Newton called her from the DMV.3 After spotting Corporal Snook, Newton

began a barrage of verbal threats and abusive language towards him, the most serious

being a threat to “follow him home and kill him.”4 Newton also yelled other

expletives and disparaging remarks towards Corporal Snook, calling him, among

other things, a “murderer” and a “[b]aby [k]iller.”5

(5) After her arrest, a New Castle County grand jury indicted Newton on

three counts: terroristic threatening of a public official or public servant, harassment,

and disorderly conduct. Before trial, the State moved in limine to exclude all

testimony related to Newton’s February 9th arrest and her miscarriage, including her

use of the phrase “[b]aby [k]iller.” The State argued that her testimony was

irrelevant to the charges, unfairly prejudicial, and there was no evidence that

Corporal Snook caused Newton’s miscarriage. In response, Newton argued that the

evidence was critical to her state of mind and lack of intent. According to Newton,

2 App. to Opening Br. at A69. Although Newton testified that the sight of Corporal Snook “triggered” her, she was clear and purposeful in her actions, testifying “I know exactly what I said to him. I called him a murderer. And that’s what I yelled…. That’s exactly what I said to him.” Id. at A69. 3 Id. at A67. 4 Id. at A55, A74. 5 Id. at A9, A44, A46–47, A74. Newton denied threatening Corporal Snook, and denied making derogatory statements towards him, but admitted that she called him a “murderer.” Id. at A69, A72–73.

3 she needed to testify about the arrest and miscarriage to show that her actions at the

DMV were a “visceral triggered reaction” and “coping mechanism to grief” rather

than an intent to harass, annoy, inconvenience, or alarm.6

(6) The Superior Court granted the State’s motion in limine on two

grounds: (i) the testimony was medical evidence that required medical or expert

proof; and (ii) the testimony was more prejudicial than probative because it would

have led to juror confusion and required a trial within a trial to connect the February

9th arrest and miscarriage to the threats made towards Corporal Snook at the DMV.

The Superior Court excluded all testimony related to the February 9 th arrest and

miscarriage but allowed a statement that Newton and Corporal Snook knew each

other from an interaction that occurred eleven months prior. The court suggested to

the State that it exclude any reference to “baby killer,” but allowed the State to use

the word “murderer.”7

(7) Following a two-day trial, a jury convicted Newton of disorderly

conduct and harassment and acquitted her of the more serious charge of terroristic

threatening of a public official or public servant. The Superior Court sentenced

Newton to an aggregate of one year and thirty days at Level V incarceration, with

credit for two days served, suspended for one year of Level II probation. The court

6 Id. at A25. 7 Id. at A28-29.

4 also imposed other conditions, including no-contact orders and continued mental

health counseling.

(8) Newton argues on appeal that the Superior Court erred when it granted

the State’s motion in limine and excluded her anticipated testimony regarding

Newton’s February 9th arrest, her miscarriage, and her use of the phrase “baby

killer.” She makes three points: (i) the excluded testimony was critical to negate the

intent element of harassment and disorderly conduct; (ii) no medical or expert proof

was required to substantiate the evidence; and (iii) excluding her testimony deprived

her of her constitutional right to present a defense.

(9) Newton did not make her constitutional claim below. Thus, we review

for plain error.8 Plain error must be “so clearly prejudicial to substantial rights as to

jeopardize the fairness and integrity of the trial process.”9 As explained below, the

Superior Court properly excluded Newton’s anticipated testimony under Rule 403.

Thus, there was no plain error.10

(10) We review evidentiary rulings to decide whether the Superior Court

exceeded its discretion.11 Our review is two-fold. First, we determine whether the

Superior Court exceeded “the bounds of reason in view of the circumstances” and

8 Goode v. State, 136 A.3d 303, 312 (Del. 2016) (citing Nance v. State, 903 A.2d 283, 285 (Del. 2006)). 9 Williams v. State, 796 A.2d 1281, 1284 (Del.2002). 10 United States v. Sheffer, 523 U.S. 303, 308 (1998) (explaining that evidence properly excluded under Rules of Evidence is not constitutional error). 11 Manna v. State, 945 A.2d 1149, 1153 (Del. 2008).

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Related

United States v. Scheffer
523 U.S. 303 (Supreme Court, 1998)
Nance v. State
903 A.2d 283 (Supreme Court of Delaware, 2006)
Manna v. State
945 A.2d 1149 (Supreme Court of Delaware, 2008)
Firestone Tire and Rubber Co. v. Adams
541 A.2d 567 (Supreme Court of Delaware, 1988)
Williams v. State
796 A.2d 1281 (Supreme Court of Delaware, 2002)
Goode v. State
136 A.3d 303 (Supreme Court of Delaware, 2016)

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Newton v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/newton-v-state-del-2023.