Hamilton v. State
2013 Del. LEXIS 619
| Del. | 2013Background
- In 2009 Hamilton lived temporarily with Crystal Moody and her sons; Crystal later asked him to move out but he left some belongings, including a Playstation.
- After repeated refusals to reconcile, Hamilton returned while intoxicated; he forced entry, pushed Crystal, and shot Tyrone (who died), Christopher, and Crystal.
- Hamilton was tried and convicted of two counts of first‑degree murder, two counts of attempted murder, two counts of first‑degree kidnapping, one count of first‑degree burglary, and seven counts of PFDCF; he received multiple life terms plus additional years.
- At trial Hamilton pursued an extreme emotional distress (EED) defense; the State’s psychiatric witness, Dr. Raskin, testified that voluntary intoxication precludes the defense, offering a legal conclusion.
- The trial court warned jurors the doctor was stating his opinion and later gave jury instructions clarifying that voluntary intoxication does not necessarily preclude the EED defense.
- On appeal Hamilton argued (1) the expert misstated law and the curative instruction was untimely/inadequate; and (2) State failed to prove unlawful entry/remain element of burglary because Hamilton previously lived there.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility/misstatement of law by nonlegal expert and adequacy of curative instruction | State: court properly managed testimony; curative instructions cured any error | Hamilton: Dr. Raskin misstated law that voluntary intoxication bars EED and curative instruction was insufficient/untimely | Court: trial judge promptly cautioned jury and later gave correct instructions; juries presumed to follow instructions; no reversible error |
| Sufficiency of evidence for burglary (entered/remained unlawfully) | State: Crystal revoked Hamilton’s privilege to be in home; occupants demanded he leave, so entry/remaining was unlawful | Hamilton: as a prior resident and with utilities in his name, he had a privilege to remain | Court: evidence showed privilege was revoked and occupants asked him to leave; utility billing alone insufficient to establish lawful privilege; burglary proven |
Key Cases Cited
- Sammons v. Doctors for Emergency Servs., P.A., 913 A.2d 519 (Del. 2006) (abuse of discretion standard for evidentiary rulings)
- Collins v. State, 56 A.3d 1012 (Del. 2012) (standard for reviewing abuse of discretion quotes)
- Flamer v. State, 490 A.2d 104 (Del. 1984) (defendant’s right to correct legal instructions)
- McNair v. State, 990 A.2d 398 (Del. 2010) (presumption that juries follow court instructions)
- State v. Magner, 732 A.2d 234 (Del. Super. Ct. 1997) (to extent mental state is attributable to intoxication, it is not relevant to EED determination)