State v. Jean

CourtSuperior Court of Delaware
DecidedJuly 30, 2025
Docket2206007604; 2212003202
StatusPublished

This text of State v. Jean (State v. Jean) 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. Jean, (Del. Ct. App. 2025).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

STATE OF DELAWARE ) ) v. ) I.D. Nos. 2206007604 ) 2212003202 JASON ST. JEAN, ) ) Defendant. )

Submitted: June 12, 2025 Decided: July 30, 2025

MEMORANDUM OPINION AND ORDER

Upon State’s Motion To Correct Illegal Sentence

DENIED

Erik C. Towne, Deputy Attorney General, Department of Justice, Dover, Delaware, Attorney for the State.

James M. Stiller, Jr., Esq., Schwartz & Schwartz, Attorneys at Law, P.A., Dover, Delaware, Attorney for the Defendant.

Primos, J. INTRODUCTION At his sentencing pursuant to a felony guilty plea, the Court relieved Jason L. St. Jean (“St. Jean”) of his obligation to register as a Tier I sex offender. The State then filed a motion to correct illegal sentence, contending that this Court lacks statutory authority to grant such relief to felons. The Court concludes that the relevant statute grants the sentencing court authority to relieve Tier I felons. Accordingly, the State’s motion for correction of illegal sentence is DENIED. I. BACKGROUND 1 On May 31, 2023, St. Jean pled guilty to three felony counts and two misdemeanor counts of violation of privacy. 2 Due to the nature of the offenses, St. Jean’s guilty plea would ordinarily have required him to register as a Tier I sex offender. 3 However, prior to his October 12, 2023, sentencing, St. Jean moved for relief from sex offender registration pursuant to 11 Del. C. § 4121(d)(6). 4 At his sentencing, the Court granted St. Jean’s request over the State’s objection. 5 On November 1, 2024, the State filed a motion to correct illegal sentence, contending that the Delaware Code did not permit the Court to relieve felons of sex- offender registration via the process just described.6 St. Jean opposed the State’s motion, conceding the relevant facts but disputing the State’s interpretation of the statute and case law.7 On February 14, 2025, the Court issued a letter order finding that the relevant statute was ambiguous and requesting briefing on legislative history relating to the

1 Citations in the form of “D.I. ___” refer to docket items in case number 2206007604. 2 D.I. 24. 3 See 11 Del. C. § 4121(a)(4)(a); 11 Del. C. § 1335(a)(6); 11 Del. C. § 4121(d)(3). 4 D.I. 25. 5 D.I. 26. 6 D.I. 31. 7 D.I. 32. 2 statutory language at issue. 8 Following briefing, the Court heard oral argument on May 9, 2025, and reserved judgment pending a written decision. 9 On May 22, 2025, the Court issued a second letter order requiring the State to brief the Court on the classification of felonies and misdemeanors at the time the statute was amended, and permitting St. Jean to respond.10 The State and St. Jean did so on June 11 and June 12, 2025, respectively. 11 The State’s motion is now ripe for decision. II. ANALYSIS A. Standard of review Under Superior Court Criminal Rule 35(a), this Court “may correct an illegal sentence at any time[.]” A sentence is illegal when “it exceeds the statutorily authorized limits . . . or is a sentence which the judgment of conviction did not authorize.”12 This is an unusual case in which the State asserts that by relieving St. Jean of his registration obligations, the Court effectively imposed a sentence more lenient than that authorized by statute, given the offenses of which he was adjudged guilty. Accordingly, the appropriate resolution of the State’s motion turns on whether the Court had statutory authority to grant St. Jean relief from sex offender registration at sentencing. B. Delaware’s sex offender tier system Delaware law classifies sex offenders into three “tiers,” determined by the offense with which they were originally charged. 13 Tier II and Tier III offenders are subjected to more stringent community notification requirements 14 and must update

8 State v. St. Jean, 2025 WL 503042 (Del. Super. Feb. 14, 2025). 9 D.I. 37. 10 D.I. 38. 11 D.I. 39, 40. 12 McLeaf v. State, 2007 WL 2359554, at *1 (Del. Aug. 20, 2007) (ORDER) (citing Brittingham v. State, 705 A.2d 577, 578 (Del. 1998)). 13 11 Del. C. § 4121(c). 14 11 Del. C. § 4121(i). 3 their registration information more frequently 15 than Tier I offenders. The sentencing court may assign individuals convicted of certain Tier I offenses to Tier II or Tier III upon motion of the State, if it finds by a preponderance of the evidence that “public safety will be enhanced by assigning the offender” to that tier. 16 An individual who is convicted of a Tier I offense within 5 years after a previous conviction for such an offense is automatically redesignated to Tier II. 17 C. The registration relief process Delaware law provides two processes by which a sex offender may have his or her registration obligations relieved by this Court. The first allows the Court to relieve those who do not reoffend for a specified period. The second allows the Court to relieve offenders at or before sentencing if, in the Court’s view, public safety does not require registration. It is this second process by which St. Jean was relieved, but a full understanding of the statutory scheme is necessary to resolve the question this case presents. Under the first process, an offender who has, for a statutorily-defined period, neither been convicted of any crime (other than a motor vehicle offense) nor violated his or her probation may petition the Court to have his or her registration reduced by one tier.18 In the case of Tier I offenders, such a reduction results in relief from registration. 19 Before the Court may grant such a petition, the offender must “establish[], by a preponderance of the evidence, that the public safety no longer requires preservation of the original designation.” 20 Delaware law affords a second process by which offenders may obtain relief,

15 11 Del. C. § 4120(g); 11 Del. C. § 4121(k). 16 11 Del. C. § 4121(d)(1)–(2). 17 11 Del. C. § 4121(d)(5). 18 11 Del. C. § 4121(e)(2)c. 19 11 Del. C. § 4121(e)(2). 20 11 Del. C. § 4121(e)(2)d.1. 4 provided that they make a request before sentencing. The procedural and substantive requirements for such relief are outlined by 11 Del. C. § 4121(d)(6): Notwithstanding any provision in this section or in § 4120 of this title to the contrary, any person who would otherwise be designated as a sex offender pursuant to this section and to § 4120 of this title may petition the sentencing court for relief from such designation, and from all obligations imposed by this section and § 4120 of this title if: a. The tier II or Tier III offense for which the person was convicted was a misdemeanor and the victim was not a child under 13 years of age; and b. The person has not previously been convicted of a violent felony, or any other offense set forth in paragraph (a)(4) of this section,21 or of any offense specified in the laws of another state, the United States or any territory of the United States, or any offense in a foreign jurisdiction which is the same as, or equivalent to, such offense; and c. The sentencing court determines by a preponderance of the evidence that such person is not likely to pose a threat to public safety if released from the obligations imposed by this section, and by § 4120 of this title. Notwithstanding anything in this paragraph to the contrary, no person designated as a Tier II or Tier III sex offender shall be afforded relief from designation as a sex offender if the victim of any of the offenses for which the person was convicted were less than 12 years old at the time of the crime, unless the person was also less than 18 years old at the time of the crime in which case the prohibition set forth in this sentence shall not apply. Any person seeking relief from designation as a sex offender under this paragraph shall file a petition with the sentencing court prior to sentencing requesting such relief.

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Bluebook (online)
State v. Jean, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-jean-delsuperct-2025.