State v. Delgado

CourtSuperior Court of Delaware
DecidedJuly 21, 2023
Docket2110007977
StatusPublished

This text of State v. Delgado (State v. Delgado) 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. Delgado, (Del. Ct. App. 2023).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

STATE OF DELAWARE, ) ) ) v. ) Case ID No.: 2110007977 ) ) ALEXANDER DELGADO, ) ) Defendant. )

ORDER

Submitted: May 17, 2023 Decided: July 21, 2023

ORDER DENYING MOTION FOR A NEW TRIAL AND MOTION FOR JUDGMENT OF ACQUITTAL

AND NOW TO WIT, this 21st day of July 2023, upon consideration of

Alexander Delgado (“Defendant”)’s Motions for New Trial and for Judgment of

Acquittal, the State’s Response, the supplemental briefs from both parties and the

record in this case, it appears to the Court that:

1. A two-men armed robbery occurred at a Rite Aid store on 4th Street in

Wilmington in June of 2021. For his role in that robbery, on November 8, 2021,

Defendant was indicted for Robbery First Degree, Possession of a Firearm During

the Commission of a Felony (PFDCF), and Conspiracy Second Degree.1

1 Indictment, D.I. 1. 2. On April 19, 2023, this Court presided over Defendant’s four-day jury

trial.2 The State’s evidence was relatively straightforward. It was undisputed that

the armed gunman was co-Defendant Keith Gibson (“Gibson”). A Rite Aid

employee/cashier/victim testified that she saw two men standing outside the entrance

of the store. She saw them don masks and gloves before they entered. The two

masked men then entered the store together and proceeded directly to her. She was

held at gunpoint by Gibson and ordered to put cash in a bag. She complied and also

placed security money—holding a GPS tracker in the center of bills—in the bag.

3. In addition to the victim’s testimony, the State introduced footage from

the store’s surveillance video that corroborated much of the victim’s testimony. It

also showed that while the victim was being held at gunpoint, Defendant took a red

bag from his hooded sweatshirt, walked through a waist-high door separating the

customer area from the cashier counter area, and proceeded behind the victim to steal

Newport cigarettes behind the counter. The video also captures Gibson walking out

with Defendant following behind.

4. The jury heard that Loss Prevention for Rite Aid tracked the GPS

coordinates from the GPS device in the security money and shared the information

with Wilmington police officers. The GPS coordinates showed that the security

2 Defendant and Co-Defendant Gibson’s charges were severed, and Defendant was tried separately. 2 money was moved to a certain location in Wilmington on W. 5th Street, where

Defendant and Gibson were also located at an unoccupied property, less than two

blocks away from the Rite Aid store.

5. The State also presented footage from a responding police officer who

was wearing a body-worn camera. The video depicts both Gibson’s attempts to flee,3

and Defendant standing on the deck rail of the unoccupied property watching

Gibson’s apprehension. On that same deck rail, police seized a Newport cigarette

box with bills from the security money.4

6. At trial, defense counsel argued that Gibson was the “bad guy” and his

client was simply tagging along. Conceding identification, the defense strategy,

therefore, focused on convincing the jury that Defendant should only be found guilty

of the Lesser-Included Offense of Robbery Second Degree because the State failed

to establish that Defendant was aware that Gibson was carrying and displaying a

firearm during the robbery. Attempts to so convince were made by defense counsel

3 During the officer’s search of an adjacent street/alleyway near the GPS tracking information, body-camera footage shows Gibson jumping over a fence and kneeling near a handicapped ramp located at 814 W. 5th Street. Gibson was apprehended wearing a tactical belt with an empty firearm holster and a knife sheath carrying a large knife and a bulletproof vest. The police later found a handgun consistent with the gun displayed in the surveillance video under the handicapped ramp. 4 Inside the unoccupied property, the police found a tie-dye blotch pattern hooded sweatshirt that matched Defendant’s DNA, and appeared to be the same sweatshirt with tie-dye blotch patterns captured on the store’s surveillance video. Defendant was arrested wearing clean white sneakers that also appeared to match the shoes of the suspect wearing the tie-dye sweatshirt in the video. 3 during closing arguments where he took the jury through a lengthy and detailed

second-by-second account through blown-up still shots of the surveillance video.

7. The jury was not persuaded. On April 21, 2023, the jury deliberated

for approximately one hour and returned verdicts of guilty as to all indicted charges,

including Robbery First Degree.

8. On April 25, 2023, Defendant filed a Motion for New Trial under

Superior Court Criminal Rule 33 and a Motion for Judgment Acquittal under Rule

29. The State opposed and the matter is now ripe for review.

New Trial

9. A motion for a new trial is addressed at the sound discretion of the

court,5 and considered under Rule 33 if the Court determines that a new trial is

required in the interest of justice.6 Defense counsel asserts as much,7 due to what is

blamed on the Court for its failure to provide a correct accomplice liability jury

instruction. And recognizing that he failed to oppose, object, or take exception to

that particular instruction and indeed, instead participated in the crafting and/or

approval of the same, he now argues that his failure to object falls on the Court as

plain error.8

5 State v. Matthews, 2018 WL 6498694, at *4 (Del. Super. Dec. 10, 2018) (citing Johnson v. State, 628 A.2d 83, 1993 WL 245374, at *1 (Del. June 22, 1993) (Table). 6 Del. Super. Ct. Crim. R. 33. 7 Def.’s Mot. for New Trial, D.I. 31, at 1. 8 Id., at 2. 4 10. The State maintains that a new trial is not warranted where sufficient

evidence supports findings of guilt for Robbery First Degree, PFDCF, and

Conspiracy Second Degree,9 and that the party autonomy rule prohibits Defendant

from arguing for special jury instructions, which he failed to—or chose not to—

request at trial.10

11. At the outset, whether or not his reasons were strategic, defense counsel

cannot now complain about the position he took—or failed to take—regarding the

instructions and/or his waiver of the right to challenge them. 11 Even if he had

objected, Defendant is not entitled to a new trial.

12. Here, a prayer conference was held after both sides conferred. With

respect to the language for accomplice liability, the Court considered the language

under 11 Del. C. § 274 which provides that “[w]hen, . . . , 2 or more persons are

criminally liable for an offense which is divided into degrees, each person is guilty

of an offense of such degree as is compatible with that person’s own culpable mental

state and with that person’s own accountability for an aggravating fact or

circumstance.” 12 Accordingly, “when an offense is divided into degrees, each

participant is only guilty for the degree of a crime that is commensurate with their

9 State’s Resp. to Mot. for New Trial and Mot. for Judgment of Acquittal, D.I. 36, ¶¶ 9–14. 10 Id. at ¶¶ 9–14; State’s Supplemental Filing Citing Additional Legal Authority, D.I. 38, at 1. 11 See State v. Owens, 2010 WL 2892701, at *7 (Del. Super. July 16, 2010); State v. Perkins, 2005 WL 3007807 (Del. Super. Nov. 9, 2005); Probst v. State, 547 A.2d 114, 119 (Del. 1988). 12 11 Del. C. § 274.

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Related

Probst v. State
547 A.2d 114 (Supreme Court of Delaware, 1988)
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970 A.2d 203 (Supreme Court of Delaware, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Delgado, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-delgado-delsuperct-2023.