State v. Britt

CourtSuperior Court of Delaware
DecidedOctober 16, 2024
Docket2308011956
StatusPublished

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

Bluebook
State v. Britt, (Del. Ct. App. 2024).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

STATE OF DELAWARE, ) ) Plaintiff, ) ) I.D.: 2308011956 v. ) ) DWAYNE BRITT, ) ) Defendant. )

Submitted: October 10, 2024 Decided: October 16, 2024

OPINION AND ORDER

Upon Consideration of Defendant’s Motion to Suppress

DENIED

Brett Fallon, Esquire, Deputy Attorney General, Delaware Department of Justice, 820 N. French Street, 7th Floor, Wilmington, Delaware, Attorney for the State.

John S. Malik, Esquire, 100 East 14th Street, Wilmington, Delaware, Attorney for the Defendant.

JONES, J. INTRODUCTION

This is the Court’s decision on a Motion to Suppress evidence seized during

the search of Dwayne Britt’s (“Britt” or “Defendant”) residence at 1406 West 6th

Street, Wilmington, Delaware. Following the search, Britt was indicted on Drug

Dealing, Drug Possession, two (2) counts of Possession or Control of a Firearm by

a Person Prohibited, Possession or Control of Ammunition by a Person Prohibited,

and Possession of Drug Paraphernalia.

The search was conducted incident to a warrant. Britt submits that the

evidence found in his residence should be suppressed because the affidavit in support

of the search warrant lacked probable cause to support a search of 1406 West 6th

Street, and there was no logical connection or nexus between the items sought and

Britt’s home. Therefore, Britt claims that the search of his residence violated his

rights under the Fourth Amendment to the United States Constitution and Article I,

§6 of the Delaware Constitution.

The state counters that the warrant was supported by probable cause to believe

that drug and other evidence of illegal activity was located at Britt’s residence. The

State contends that the totality of the circumstances contained within the warrant

affidavit give rise to a logical nexus between the items sought and Britt’s residence.

2 DISCUSSION

The Fourth Amendment protects against unreasonable searches and seizures

and provides that warrants cannot issue absent a showing of probable cause

supported by oath or affirmation.1 The Delaware Constitution also safeguards the

right to be free from unreasonable searches and seizures and requires that warrants

be based upon a sworn statement establishing probable cause. 2

The Delaware General Assembly codified the requirements for a

constitutionally adequate showing of probable cause in 11 Del. C. §§ 2306 and 2307

(“Section 2306” or “Section 2307”). Requirements for the content of the affidavit

in support of the search warrant are set forth in Section 2306:

It shall designate the house, place, conveyance or person to be searched and the owner or occupant thereof (if any), and shall describe the things or persons sought as particularly as may be, and shall substantially allege the cause for which the search is made or the offense committed by or in relation to the persons or things searched for, and shall state that the complainant suspects that such persons or things are concealed in the house, place, conveyance or person designated and shall recite the facts upon which such suspicion is founded. 3

The judicial officer issuing the search warrant must adhere to procedural and

substantive requirements contained in Section 2307:

If the judge, justice of the peace or other magistrate finds that the facts recited in the complaint constitute probable cause for the search, that person may direct a warrant to any proper officer 1 U.S. Const. amend. IV. 2 Del. Const. art. I, § 6. 3 11 Del. C. § 2306.

3 or to any other person by name for service. The warrant shall designate the house, place, conveyance or person to be searched, and shall describe the things or persons sought as particularly as possible. 4

The specific statutory provisions of Sections 2306 and 2307 were enacted to

enhance and elucidate the Federal and State constitutional safeguards against

unreasonable searches and seizures.5

Delaware courts have interpreted Sections 2306 and 2307 as imposing a four

corners test for probable cause.6 The facts alleged in the affidavit must suffice to

allow the issuing magistrate to independently evaluate the existence of probable

cause. 7 The face of the affidavit must present adequate facts to allow a reasonable

person to conclude that an offense has been committed and that seizable property

would be found in a particular place or on a particular person.8 By requiring all facts

relied upon by the magistrate to be contained within the written affidavit, the four

corners test insures that the reviewing court can determine the warrant’s validity

without “reliance upon faded and often confused memories.”9

The four corners test restricts the scope of a reviewing court’s inquiry but does

not constrain the court from adopting a flexible, nontechnical approach in evaluating

4 11 Del. C. § 2307. 5 State v. Cannon, 2007 WL 1849022 (Del. Super. June 27, 2007) 6 Id. See also E.g., Pierson v. State, 338 A.2d 571, 573-74 (Del. 1975); State v. Ivins, 2004 WL 1172351, at *4 (Del. Super. May 21, 2004). 7 Jensen v. State, 482 A.2d 105, 111 (Del. 1984) (citing Franks v. Delaware, 438 U.S. 154, 165 (1978)). 8 Blount v. State, 511 A.2d 1030, 1032-33 (Del. 1986); Ivins, 2004 WL 1172351, at *4. 9 Dorsey v. State, 761 A.2d 807, 811 (Del. 2000) (quoting Pierson, 338 A.2d at 574).

4 a warrant’s validity. The reviewing court’s task is to determine whether the warrant

application presented the issuing magistrate with a “substantial basis” to conclude

that probable cause existed. 10 In making this determination, the reviewing court

takes a deferential approach to the magistrate’s decision and eschews “a

hypertechnical approach to the evaluation of the search warrant affidavit in favor of

a common-sense interpretation.”11 The affidavit must be “considered as a whole and

not on the basis of separate allegations.”12

Unlike an arrest warrant, a search warrant is not directed at a person, but rather

at the particular place where police have probable cause to believe that evidence is

located.13 Probable cause to search depends upon the existence of a logical nexus

between the items sought and the place to be searched.14 In other words, probable

cause to believe that a suspect has committed a crime will support an arrest but not

necessarily a search warrant for the suspect’s home.15 Rather, the factual showing

necessary to establish probable cause to search a residence is two-fold: first, there

must be probable cause that a crime was committed, and second, there must be

10 Cannon, 2007 WL 1849022, at *3; Illinois v. Gates, 462 U.S. 213, 239 (1983) (citing Jones v. United States, 362 U.S. 257, 271 (1960)). See also Ivins, 2004 WL 1172351, at *4. 11 See Gardner v. State, 567 A.2d 404, 409 (Del. 1989); Ivins, 2004 WL 1172351, at *4. 12 Jensen, 482 A.2d at 111. 13 See, e.g., Zurcher v. Stanford Daily, 436 U.S. 547, 555-56 (1978); State v.

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Related

Jones v. United States
362 U.S. 257 (Supreme Court, 1960)
United States v. Harris
403 U.S. 573 (Supreme Court, 1971)
Zurcher v. Stanford Daily
436 U.S. 547 (Supreme Court, 1978)
Franks v. Delaware
438 U.S. 154 (Supreme Court, 1978)
Illinois v. Gates
462 U.S. 213 (Supreme Court, 1983)
United States v. Joseph A. Travisano
724 F.2d 341 (Second Circuit, 1983)
United States v. Jones
994 F.2d 1051 (Third Circuit, 1993)
United States v. Yanokura F Eliz
182 F.3d 82 (First Circuit, 1999)
Blount v. State
511 A.2d 1030 (Supreme Court of Delaware, 1986)
Gardner v. State
567 A.2d 404 (Supreme Court of Delaware, 1989)
Hooks v. State
416 A.2d 189 (Supreme Court of Delaware, 1980)
Dorsey v. State
761 A.2d 807 (Supreme Court of Delaware, 2000)
Jensen v. State
482 A.2d 105 (Supreme Court of Delaware, 1984)
Pierson v. State
338 A.2d 571 (Supreme Court of Delaware, 1975)

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Bluebook (online)
State v. Britt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-britt-delsuperct-2024.