IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
STATE OF DELAWARE ) ) v. ) I.D. 2405003475 ) JYAIRE HENRY, ) Defendant. )
Submitted: August 1, 2025 Decided: October 31, 2025 Corrected: November 3, 2025
Upon Defendant Jyaire Henry’s Motion to Suppress, DENIED.
ORDER
HAVING FULLY CONSIDERED Defendant Jyaire Henry’s Motion to
Suppress (D.I. 10) and its supplement (D.I. 22); the State’s Responses thereto (D.I.
16, 24); the parties’ arguments upon the hearing of the motion (D.I. 18); the
authorities cited; the applicable caselaw and governing rules; and the entire record
developed thus far; it appears to the Court that:
I. FACTUAL AND PROCEDURAL BACKGROUND
(1) Mr. Henry has been indicted for attempted murder and two other related
counts.1 These charges arise from an April 2024 altercation that resulted in a
1 D.I. 5 (Indictmnet). stabbing.2 On August 16, 2024, the Wilmington Police Department (WPD) took
Defendant Jyaire Henry into custody and he was placed in an interview room at the
station.3 Once there, Mr. Henry wasn’t acting normally.4 Among other behavior,
he wouldn’t sit still, would kneel and lie on the floor, and at times was panting,
gasping, and clutching his chest.5
(2) When WPD Detective Thomas Rittenhouse first interacted with
him in the interview room at 7:11 a.m., Mr. Henry’s “behavior was erratic,” “[h]e
was moving all over the interview room and started to complain of a medical issue
with his chest.”6 Once this began, detectives asked Mr. Henry about his health—he
reported a history of a heart condition—and contacted Mr. Henry’s family to confirm
whether he did indeed have such history.7
(3) Though Mr. Henry’s mother told Det. Rittenhouse she was not aware
of Mr. Henry having any heart condition, the detective contacted Emergency
Medical Services to have him assessed at the station and transported to the hospital.8
2 Id.; May 21, 2025, Supp. Hr’g. Tr. at 6, 15-16 (D.I. 20). 3 Supp. Hr’g. Tr. at 6. 4 Id. at 6-7. 5 Id. at 7-8; May 21, 2025, Supp. Hr’g. Exh. 1 at Ex. A (Video Recording of WPD Interview Room 2, Aug. 16, 2024), at 07:11:56—07:16:13 (hereinafter “Int. Rm. Video A”) (D.I. 18). 6 Supp. Hr’g. Tr. at 6-7; Int. Rm. Video A, at 07:16:15—07:28:35. 7 Supp. Hr’g. Tr. at 7; Int. Rm. Video A. at 07:16:16—07:26:40. 8 Supp. Hr’g. Tr. at 7-8; Int. Rm. Video A. at 07:28:54—07:37:04.
-1- Mr. Henry left for the hospital at 7:37 a.m.9 Det. Rittenhouse rode along with him
in the ambulance.10
(4) While at the hospital, Mr. Henry was administered “5 mg of
[D]roperidol and Versed intramuscularly to help with chemical sedation in addition
to physical sedation given his severe level of agitation and combativeness.”11 The
hospital staff determined “[t]his was necessary for both the safety of [Mr. Henry]
and the safety of the staff.”12 This medication was administered at approximately
7:50 a.m.13
(5) Droperidol and Versed were the medications used by medical staff for
sedation during Mr. Henry’s hospital visit.14 It appears the primary purpose of these
medications is to induce sedation in patients and reduce anxiety and agitation.15
9 Int. Rm. Video A. at 07:37:04—07:38:35. 10 Supp. Hr’g. Tr. at 8-9. 11 May 21, 2025, Supp. Hr’g. Exh. 1 at Ex. C (Def.’s CCHS Treatment Record, Aug. 16, 2024), at 2 (hereinafter “Def.’s CCHS Treatment Record”) (D.I. 18). 12 Id. 13 Supp. Hr’g. Tr. at 9-10. 14 Def.’s CCHS Treatment Record at 2. Both sides agree that Mr. Henry was given Droperidol and Versed to reduce his agitation. See Def.’s Mot. to Suppress at ¶ 6 (D.I. 10); State’s Resp. to Def.’s Mot. to Suppress at 2-3, 5 (D.I. 16). 15 Neither Mr. Henry nor the State have produced expert testimony or like opinion or evidence related to these medications and their use or effect in Mr. Henry’s case. Thus, the Court relies on the parties’ seeming agreement that it can limit its consideration to the sources they cite. Compare Def.’s Suppl. Br. (D.I. 22) with State’s Supp. Br. (D.I. 24). The parties relied primarily on the following: Droperidol, DRUGS.COM, https://www.drugs.com/mtm/droperidol.html (last visited Oct. 30, 2025) ; Versed, DRUGS.COM, https://www.drugs.com/mtm/versed.html (last visited Oct. 30, 2025); AMERICAN REGENT, INC., MANUFACTURER’S INSERT: DROPERIDOL INJECTION, https://www.americanregent.com/media/ 1574/droperidol_prescribing-information.pdf (Def.’s -2- Droperidol’s effects typically last two to four hours, but may persist for as long as
twelve hours.16 And Versed’s effects typically last for two hours, but may persist
for up to six hours.17
(6) Mr. Henry was discharged from Wilmington Hospital at 11:09 a.m.
after he “recovered appropriately from his chemical sedation,” “ha[d] no
complaints,” and “state[d] he feels better.”18
(7) He was then taken back to WPD headquarters. 19 Upon arrival, he was
returned to the WPD turnkey area.20 Det. Rittenhouse briefed the turnkey officer on
Mr. Henry’s medical situation and gave him the documentation provided by
Wilmington Hospital.21 Mr. Henry confirmed for the turnkey officer that he was
“okay.”22 By this point, Mr. Henry was acting normally and inquiring about his
Suppl. Br., Ex. D); HOSPIRA, MANUFACTURER’S INSERT: MIDAZOLAM INJECTION (Jan. 2023) (Def.’s Suppl. Br., Ex. E); and the Prescribers’ Digital Reference, the digital version of the venerable Physicians’ Desk Reference or PDR available at https://pdr.net (last visited Oct. 30, 2025). 16 Droperidol, DRUGS.COM, https://www.drugs.com/mtm/droperidol.html (last visited Oct. 30, 2025); AMERICAN REGENT, INC., MANUFACTURER’S INSERT: DROPERIDOL INJECTION, https://www.americanregent.com/media/ 1574/droperidol_prescribing-information.pdf (Def.’s Suppl. Br., Ex. D). 17 Versed, DRUGS.COM, https://www.drugs.com/mtm/versed.html (last visited Oct. 30, 2025); HOSPIRA, MANUFACTURER’S INSERT: MIDAZOLAM INJECTION (Jan. 2023) (Def.’s Suppl. Br., Ex. E). 18 Def.’s CCHS Treatment Record at 2. 19 Suppression Hr’g. Tr. at 10-12. 20 Id. at 12. 21 Id. at 12-13. 22 Id.
-3- charges.23
(8) In the ensuing couple of hours, Det. Rittenhouse completed reports and
warrants related to the morning’s incidents.24 During his fingerprinting, Mr. Henry
began to ask about the specific charges he faced.25 Det. Rittenhouse explained that
in order to discuss those Mr. Henry would have to return to the interview room for
a Mirandized statement.26 Mr. Henry “agreed that he’d like to come and waive his
Miranda rights and speak with [Det. Rittenhouse] upstairs.”27
(9) At approximately 1:50 p.m., Detective Rittenhouse and Mr. Henry
returned to the interview room where the detective read Mr. Henry his Miranda
rights and questioned him in furtherance of the attempted murder investigation.28
Mr. Henry waived his Miranda rights and gave the 23-minute statement that he now
seeks to have suppressed.29
II. PARTIES’ CONTENTIONS
(10) According to Mr. Henry, the statement he gave to Detective
23 Id. 24 Id. at 13-14. 25 Id. at 13-14. 26 Id. at 13-14. See Miranda v. Arizona, 384 U.S. 436 (1966) (articulating the procedural safeguards that secure one’s the privilege against self-incrimination when subject to custodial interrogation). 27 Id. at 14. 28 May 21, 2025, Supp. Hr’g. Exh. 1 at Ex. B (Video Recording of WPD Interview Room 2, Aug. 16, 2024), at 13:50:11—13:51:23 (hereinafter “Int. Rm. Video B”) (D.I. 18). 29 Suppression Hr’g. Tr. at 15; Int. Rm. Video B at 13:50:11—14:03:44.
-4- Rittenhouse should be suppressed because he did not have the capacity to knowingly
and intelligently waive his Miranda rights. He focuses on three factors in the
totality-of-circumstances analysis the Court must employ:30 (a) the behavior and
conduct of Detective Rittenhouse; (b) his own behavior and conduct both before and
after his hospital visit; and (c) his age and claimed relative inexperience with the
criminal justice system.31
(11) Mr. Henry insists the behavior and conduct of Det. Rittenhouse is
“especially telling” in this totality-of-circumstances examination.32 In support of
this, Mr. Henry first points to Det. Rittenhouse’ awareness that Mr. Henry had been
medically sedated approximately six hours before he waived Miranda and gave his
statement.33 Second, he criticizes Det. Rittenhouse’s desire to wait to speak with
Mr. Henry until after he was discharged from the hospital where he would have a
“second opportunity to Mirandize [Mr. Henry].”34 Third, he calls out
Det. Rittenhouse’s interrogation techniques.35
30 See Hubbard v. State, 16 A.3d 912, 916-19 (Del. 2011) (adopting and applying the United States Supreme Court’s test set forth in Moran v. Burbine, 475 U.S. 412 (1986), to a claim that the defendant wasn’t—due to drug and alcohol use—competent to understand the Miranda rights he was waiving and the consequences of such a waiver). 31 See generally Def.’s Mot. to Suppress at ¶¶ 16-20; see also Hubbard, 16 A.3d at 917. 32 Def.’s Mot. to Suppress at ¶ 16; Def.’s Suppl. Br. at 7-9. 33 Def.’s Mot. to Suppress at ¶ 16; Def.’s Suppl. Br. at 7-9. 34 Def.’s Mot. to Suppress at ¶ 16; Def.’s Suppl. Br. at 7-9. 35 Def.’s Mot. to Suppress at ¶ 16; Def.’s Suppl. Br. at 7-9.
-5- (12) Mr. Henry claims that he was likely still under the influence of the
medications administered at the hospital when he waived his Miranda rights.36 He
avers that he appears “drowsy and lethargic in his second interview and ha[d] to be
told to provide a verbal ‘yes’ to Detective Rittenhouse’s questions.”37
(13) Mr. Henry posits that his age and professed relative inexperience with
the criminal justice system are also factors that weigh against a finding of requisite
capacity.38
(14) In response, the State argues that Mr. Henry had adequate capacity.39
It highlights that the hospital found that he was properly recovered, his erratic
behavior had ceased, and he was alert and attentive during the challenged
interrogation.40 The State also views Mr. Henry’s previous arrests and conviction
history as weighing in its favor in this analysis.41
III. APPLICABLE LEGAL STANDARDS
(15) Prior to any custodial interrogation, the police must advise one of
certain rights against self-incrimination as prescribed in Miranda v. Arizona.42 After
36 Def.’s Mot. to Suppress at ¶¶ 17-19. 37 Id. at ¶ 18. 38 Def.’s Mot. to Suppress at ¶ 20. 39 See generally State’s Resp. 40 State’s Resp. at 5-6. 41 State’s Resp. at 6. 42 384 U.S. at 436, 444-45 (1966).
-6- being advised of such rights, that person is free to waive them.43 To effectively
waive the Miranda rights, it is required that:
First, the relinquishment of the right must have been voluntary in the sense that it was the product of a free and deliberate choice rather than intimidation, coercion, or deception. Second, the waiver must have been made with a full awareness of both the nature of the right being abandoned and the consequences of the decision to abandon it.44
(16) Here, the State bears the burden of showing, by a preponderance of
evidence, that “not only did [Mr. Henry] make an express waiver of his Miranda
rights, but that he ‘knowingly and intelligently waived those rights.’”45
(17) When capacity is questioned, the Court must look to the totality of the
circumstances, “including ‘the behavior of the interrogators, the conduct of the
defendant, his age, his intellect, his experience, and all other pertinent factors.”46
Fundamental to this inquiry is, “whether [the interrogatee] had sufficient capacity to
know what he was saying and to have voluntarily intended to say it.”47
(18) Even were one deemed to be intoxicated during interrogation, such fact
“does not per se invalidate an otherwise proper waiver of rights.”48 But “[o]nly if
43 Id. at 444-45. 44 Moran, 475 U.S. at 421. 45 Hubbard, 16 A.3d at 919 (citing Howard v. State, 458 A.2d 1180 (Del. 1983)). 46 Id. at 917 (quoting Whalen v. State, 434 A.2d 1346, 1351 (Del. 1981)). 47 Traylor v. State, 458 A.2d 1170, 1176 (Del. 1983). 48 Id.; Howard, 458 A.2d at 1183.
-7- the ‘totality of the circumstances surrounding the interrogation’ reveal both an
uncoerced choice and the requisite level of comprehension may a court properly
conclude that the Miranda rights have been waived.”49
IV. ANALYSIS
(19) After reviewing the record and examining the totality of the
circumstances, the Court finds that Mr. Henry had the capacity to enter a knowing,
intelligent, and voluntary waiver of his Miranda rights. First, the conduct and
behavior of Det. Rittenhouse wasn’t improper or overbearing. Next, the conduct and
behavior of Mr. Henry indicates that—at the time he ultimately gave his statement
on the afternoon of August 16, 2024, he was able to fully understand and validly
waive his Miranda rights.50 His ability to comprehend statements and questions,
challenge the detective on certain things, recall specific details of events, and
intelligently answer questions belie any contention that he did not have the capacity
to waive his Miranda rights.51 Last, Mr. Henry’s age and criminal justice experience
provide no support for the notion that he was unable to “comprehend the ‘plain
meaning of his basic Miranda rights.’”52
49 State v. Revel, 2016 WL 5409032, at *5 (Del. Super. Ct. Sept. 26, 2016) (quoting Marine v. State, 607 A.2d 1185, 1195 (Del. 1992) (citing Moran, 475 U.S. at 421)). 50 Suppression Hr’g. Tr. at 15-18. 51 Id.; Int. Rm. Video B at 13:50:11—14:03:44. 52 Def.’s Mot. to Suppress at ¶ 20; Hubbard v. State, 16 A.3d 912, 917 (Del. 2011) (quoting Bennett v. State, 2010 WL 987025, at *3 (Del. March 18, 2010)).
-8- A. There is nothing about Det. Rittenhouse’s conduct or behavior that weighs in favor of invalidating Mr. Henry’s waiver of his Miranda rights.
(20) In Mr. Henry’s view, Det. Rittenhouse’s behavior and conduct—a
consideration in the Hubbard-Moran totality of the circumstances analysis—is an
“especially telling” factor in his favor.53 Not so.
(21) Mr. Henry first points out that Det. Rittenhouse accompanied
Mr. Henry to the hospital and was present when Mr. Henry was medically sedated.54
He posits “that Detective Rittenhouse would have been aware of [Mr. Henry’s]
ability to know what he was saying and have voluntarily intended to say may have
been compromised.”55 In support of this, Mr. Henry distinguishes
Det. Rittenhouse’s firsthand knowledge of his medical sedation from Hubbard—
“where the defendant [only] told the officer he was voluntarily intoxicated the night
before.”56
(22) But the fact that Det. Rittenhouse was aware that Mr. Henry had been
medically sedated earlier in the day “is irrelevant to the question of the intelligence
and voluntariness of [Mr. Henry’s] election to abandon his rights.”57 Indeed, in this
instance, Det. Rittenhouse’s firsthand witnessing of Mr. Henry’s previous erratic
53 See Def.’s Mot. to Suppress at ¶ 16. 54 Id.; Def.’s Suppl. Br. at 8. 55 Def.’s Mot. to Suppress at ¶ 16. 56 Id. 57 Moran, 475 U.S. at 423.
-9- behavior, medical treatment, and changed ability to cogently and calmly
communicate demonstrate a more fully informed understanding of his capacity when
questioned that afternoon.
(23) Mr. Henry also asks the Court to consider “Detective Rittenhouse’s
choice to wait to speak with Mr. Henry until he had ‘a second opportunity to
Mirandize him’, and to press him about details of the incident in hopes of obtaining
a confession.”58
(24) As the Court in Miranda v. Arizona recognized, “custodial
interrogations, by their very nature, generate ‘compelling pressures which work to
undermine the individual’s will to resist and to compel him to speak where he would
not otherwise do so freely.’”59 This is, in part, why the police must always advise a
person of their Miranda rights prior to a custodial interrogation.60
(25) It was wholly appropriate that Det. Rittenhouse waited to speak with
Mr. Henry until after his medical treatment. The recording of their first interaction
in the morning and recounting of the trip to the hospital demonstrate clearly that
Mr. Henry should not have been interviewed until that occurred.
(26) When Det. Rittenhouse did Mirandize Mr. Henry, he “read off a
58 Def.’s Suppl. Br. at 9. 59 Moran, 475 U.S. at 420 (quoting Miranda, 384 U.S at 467). 60 See Miranda, 384 U.S. at 444-45.
- 10 - Miranda form,” asked Mr. Henry if he understood those rights, and received a verbal
confirmation.61 There is no indication that any of Det. Rittenhouse’s conduct either
deprived Mr. Henry “of knowledge essential to his ability to understand the nature
of his rights and the consequences of abandoning them”62 or was in any way
untoward. To the contrary, the record demonstrates a prudent and cautious approach
when dealing with Mr. Henry and ensuring recognition of his rights.
B. Mr. Henry’s conduct after his hospital visit evidences his capacity was unimpaired.
(27) Mr. Henry asserts that his “conduct after returning from the hospital, in
comparison with his conduct prior to being taken to the hospital is compelling
evidence that he did not have the capacity to waive his Miranda rights.”63 But, the
circumstances around the return of Mr. Henry to the police station and video
evidence of the statement itself say quite the opposite.
(28) Mr. Henry’s discharge records and subsequent interactions with the
WPD turnkey officer and Det. Rittenhouse prior to the custodial interview
demonstrate his capacity was not impaired.64 Mr. Henry’s medical records indicate,
61 Suppression Hr’g. Tr. at 17; Int. Rm. Video B at 13:50:11—13:51:23. See Hubbard, 16 A.3d at 918 (explaining that while “written Miranda waivers are a best police practice . . . [t]hey are not required, . . . as a matter of law”). 62 Moran, 475 U.S. at 424. 63 Def.’s Mot. to Suppress at ¶ 17. 64 See Suppression Hr’g. Tr. at 12-15; Def.’s CCHS Treatment Record at 2.
- 11 - at the time of discharge, he “ha[d] no complaints [and] state[d] he [felt] better” and
that he “recovered appropriately from his chemical sedation.”65 After Mr. Henry
was discharged from the hospital, he was brought to the WPD turnkey area where
he spoke with a turnkey officer.66 Mr. Henry informed the turnkey officer that he
was okay.67
(29) During processing, Mr. Henry asked Det. Rittenhouse about the charges
against him.68 When Det. Rittenhouse informed him that one of those charges was
attempted murder, he told the detective “that’s not right.”69 Mr. Henry agreed at that
time that he wished to speak with Det. Rittenhouse and would waive his Miranda
rights.70 While walking to the interview room, Mr. Henry continued “to talk about
how it was crazy that it was attempted murder without going into details specifically
about it.”71
(30) Prior to his medical treatment, Mr. Henry was no doubt in either
emotional or physical distress.72 When Mr. Henry was returned to the station, he
65 Def.’s CCHS Treatment Record at 2. 66 Id. at 12-13. 67 Id. 68 Id. at 14. 69 Id. 70 Id. 71 Id. 14-15. 72 See Int. Rm. Video A at 07:11:56—07:37:04. - 12 - appeared more relaxed and “normal” in his interactions with Det. Rittenhouse.73 He
was responsive to questions and asked questions of his own.74 While his demeanor
is undisputably calmer, it’s not at all “drowsy and lethargic” as Mr. Henry makes it
out to be.
C. Mr. Henry’s interactions with Det. Rittenhouse during his statement demonstrate his capacity was unimpaired.
(31) After arriving at the interview room, Det. Rittenhouse read Mr. Henry
his Miranda rights and Mr. Henry verbally agreed to waive them.75 Mr. Henry’s
responses to Det. Rittenhouse questions are particularly indicative of Mr. Henry’s
ability to knowingly and intelligently waive his Miranda rights.
(32) Instructive here is Traylor v. State.76 In Traylor, the Court found that
the defendant’s responses to interview questions, which were specific in nature, and
his ability to recall his arrest and interrogation, “negate[d] any implication that his
mental capacity was impaired when he was questioned.”77 Same here:
(a) Mr. Henry was able to readily recall various events and his statements and responses to Det. Rittenhouse’s questions were specific in nature.
73 See Suppression Hr’g. Tr. At 12-15; id. at 15 (noting though that “Mr. Henry was having some nervousness with his legs where he was moving his legs a little bit while during the questioning.”). 74 Suppression Hr’g. Tr. At 12-15. 75 Suppression Hr’g. Tr. at 15, 17; Int. Rm. Video B at 13:50:11—13:51:23. 76 45 A.2d 1170, 1176 (Del. 1983). 77 Id.
- 13 - (b) Mr. Henry “was able to recall various incidents involving his ex-girlfriend, involving the stabbing, as well as other points about what had occurred through each of those events.”
(c) Mr. Henry was able to recall “how he knows the individual, who he stabbed, he understood about the stabbing and why he was being questioned about it.” He described specific details, such as a concealed firearm he observed on the victim.
(d) Mr. Henry was able to recall and describe the direction of travel he took after the event “as well as what he did with the weapon after he was in possession of it.”
(e) Moreover, when questioned by Det. Rittenhouse about a knife recovered by WPD during the arrest, Mr. Henry was able to recall the knife in question and indicated that it was not the knife used in the stabbing. Mr. Henry was able to describe that the knife recovered during the arrest was a work knife and “gave [Det. Rittenhouse] an explanation of what he used that knife for.” 78
(33) All of Mr. Henry’s responses to Det. Rittenhouse’s questions were
specific in nature and he was able to cogently recall and corroborate details and
events. His demeanor—which was wholly normal, if somewhat understandably
nervous—and ability to give these responses during his interview with
Det. Rittenhouse belie any suggestion that his mental capacity was impaired at the
time he waived his Miranda rights.79
78 Suppression Hr’g. Tr. at 15-17; Int. Rm. Video B at 13:50:11—14:03:44. 79 See Traylor, 45 A.2d at 1176.
- 14 - D. Mr. Henry was neither too young nor inexperienced to understand and waive his Miranda Rights
(34) Mr. Henry claims his “age and relative inexperience with the criminal
justice system” suggest Mr. Henry “did not have the capacity to execute a knowing,
intelligent, and voluntary waiver of his Miranda rights.”80
(35) At the time of this encounter, Mr. Henry was 22 years-old81 and already
had a criminal history dating back almost a decade.82 His adult record included
convictions for one felony-resisting arrest and two misdemeanors—disorderly
conduct and terroristic threatening.83 His juvenile record also includes three
misdemeanor adjudications.84 It appears that, in all, Mr. Henry had been arrested no
less than a dozen times between November 2014 and August 2024.85
(36) This Court has had occasion to consider Miranda challenges by
defendants of similar age and experience with the criminal justice system. For
instance, in State v. Peters, the Court noted “though [the defendant] was only twenty-
one years old, he had significant experience with the criminal justice system—both
80 Def.’s Mot. to Suppress at ¶ 20. 81 Def.’s Suppl. Br., Ex. A (Def.’s DELJIS Criminal History) at 1 (documenting Mr. Henry’s date of birth as September 16, 2001); Int. Rm. Video A. at 07:16:58—07:17:07. 82 Def.’s DELJIS Criminal History at 9. 83 Def.’s DELJIS Criminal History at 1. 84 Id. 85 Id. at 2-9.
- 15 - as a juvenile and as an adult.”86 Just as in Peters, Mr. Henry’s age and relative
experience weigh in favor of his capacity to understand and waive his Miranda
rights.
(37) Mr. Henry further suggests that Det. Rittenhouse’s “involvement of
[Mr. Henry’s] mother, even though [Mr. Henry] is a legal adult, speaks to
[Mr. Henry’s] youth and relative inexperience.”87 But, the primary purpose for
Det. Rittenhouse’s phone call to Mr. Henry’s mother was to determine any prior
heart issues Mr. Henry may have had at the time he was complaining of such.88 In
this circumstance, Det. Rittenhouse’s conversation with Mr. Henry’s mother lends
nothing to his claimed lacked of ability to understand and provide a valid waiver of
his Miranda rights. While it appears that Mr. Henry’s mother told the detective that
Mr. Henry had a prior mental health history,89 there is nothing in the record
indicating that such prior history impaired his ability to properly waive his Miranda
rights.
(38) The relevant question here is whether Mr. Henry’s age and claimed
inexperience affected his ability to “comprehend the ‘plain meaning of his basic
86 283 A.3d 668, 683 (Del. Super. Ct. 2022), aff’d, 2023 WL 3880124 (Del. June 7, 2023). 87 Def.’s Mot. to Suppress at ¶ 20. 88 Suppression Hr’g. Tr. at 23-25. 89 Suppression Hr’g. Tr. at 25.
- 16 - Miranda rights.’”90 The Court finds that Mr. Henry was not so young and his
experience was not so limited to the extent that he was unable to do so. Moreover,
in the totality of the circumstances, any effect Mr. Henry’s age or claimed limited
experience may have had, is negated by his demonstrated ability to comprehend and
intelligently respond to questions asked by Det. Rittenhouse during the custodial
interrogation.91
V. CONCLUSION
(39) After considering the totality of the circumstances, the Court finds that
the State has met its burden of establishing that Mr. Henry had the capacity to enter
a knowing, intelligent, and voluntary waiver of his Miranda rights prior to giving
his custodial statement on the afternoon of August 16, 2024. Resulting, Defendant
Jyaire Henry’s Motion to Suppress that statement is DENIED.
IT IS SO ORDERED.
/s/ Paul R. Wallace _______________________ Paul R. Wallace, Judge
90 Hubbard, 16 A.3d at 917 (quoting Bennett, 2010 WL 987025 at *3). 91 See Suppression Hr’g. Tr. at 15-18.
- 17 -