Edwards v. State
32, 2016
| Del. | Feb 27, 2017Background
- In 2014 Edwards stole cartons of Newport 100s from multiple Philadelphia Pike stores; indicted on three shoplifting counts and two first‑degree robbery counts (Wawa incidents and an Exxon incident).
- At trial identity was undisputed; Edwards admitted to the shopliftings and defended principally against the robbery charges.
- Exxon surveillance video was misplaced before trial; police officer’s interview notes regarding an ashtray allegation were discarded. The trial judge gave a missing‑evidence jury instruction for the video.
- A jury convicted Edwards of all five counts; he was sentenced to 15 years Level V, plus one year Level III probation. This is his direct appeal.
- Trial counsel filed a Rule 26 no‑merit brief and sought to withdraw; the Supreme Court reviewed the record for nonfrivolous issues and conducted de novo sufficiency review where appropriate.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Edwards) | Held |
|---|---|---|---|
| Severance of Exxon robbery from other charges | Joinder permissible under common scheme/similarity; same target (cigarettes) | Failure to sever prejudiced Edwards; Exxon incident distinct by time/location | No plain error; joinder proper; counsel strategically declined severance |
| Jury instruction on “physical injury” definition | Instruction matched statutory definition (impairment or substantial pain) | Instruction failed to sufficiently define "physical injury" | No plain error; instruction adequate under statute and precedent |
| Failure to preserve evidence (Exxon video and officer’s notes) | Video missing; court gave missing‑evidence instruction; notes not material | Missing evidence deprived Edwards of exculpatory material and warrant relief | No relief: video instruction given; officer notes not shown to be material or destroyed in bad faith |
| Sufficiency of evidence for first‑degree robbery (physical injury) | Witness testimony showed manager suffered scratches/bleeding and treatment | Testimony conflicted and insufficient to show statutory "physical injury" | Conviction upheld; evidence sufficient for a rational jury to find physical injury beyond a reasonable doubt |
| Fair‑cross‑section and peremptory challenge claims | Not raised below; State disputes the juror pool data and challenges inferred race‑based strikes | Jury pool underrepresents blacks; State used peremptories to strike black jurors | Court declined to consider on appeal for failure to raise in Superior Court; claim not reviewed on merits |
Key Cases Cited
- Penson v. Ohio, 488 U.S. 75 (1988) (procedural framework for counsel withdrawal/no‑merit brief)
- Anders v. California, 386 U.S. 738 (1967) (procedures when counsel asserts appeal is frivolous)
- McCoy v. Court of Appeals of Wisconsin, 486 U.S. 429 (1988) (appointment and duties of counsel on appeal)
- Wainwright v. State, 504 A.2d 1096 (Del. 1986) (plain error standard in Delaware criminal appeals)
- Skinner v. State, 575 A.2d 1108 (Del. 1990) (joinder/severance principles under common scheme)
- Robertson v. State, 596 A.2d 1345 (Del. 1991) (review standard for judgment of acquittal and jury credibility)
- Williamson v. State, 113 A.3d 155 (Del. 2015) (victim testimony alone can establish physical injury)
- Batson v. Kentucky, 476 U.S. 79 (1986) (prohibition on race‑based peremptory challenges)
- Duren v. Missouri, 439 U.S. 357 (1979) (fair cross‑section requirement for jury venires)