Hubbard v. State, 16 A.3d 912

Hubbard was arrested in Wilmington for a West 5th Street shooting and indicted on multiple offenses including Attempted Murder in the First Degree, two counts of Robbery in the First Degree, Carjacking in the First Degree, Conspiracy in the Second Degree, Reckless Endangering in the First Degree, Possession of a Deadly Weapon by a Person Prohibited, and five counts of Possession of a Firearm During the Commission of a Felony.
A separate bench trial addressed Possession of a Deadly Weapon by a Person Prohibited, with Hubbard found guilty there as well.
After a six-day trial, the jury returned verdicts on eleven counts; Hubbard was sentenced to twelve life terms after the habitual-offender finding.
Hubbard moved to suppress a custodial statement arguing the Miranda waiver was not knowing, intelligent, and voluntary, based on the rapid recitation, lack of explicit checked consent, and claimed intoxication affecting competency.
The State relied on a videotaped interrogation in which Hubbard acknowledged understanding his rights and ultimately admitted involvement.
The Superior Court denied the suppression motion; the Delaware Supreme Court affirmed, holding Hubbard knowingly and intelligently waived his Miranda rights and was competent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Hubbard's Miranda waiver valid under Moran?	Hubbard argues the waiver was not knowing or intelligent due to rapid recitation and lack of explicit confirmation.	State contends warnings conveyed the complete substance and Hubbard knowingly waived.	Waiver valid under Moran; warnings adequate and knowingly made.
Does the pace of recitation or lack of written waiver undermine validity?	Hubbard asserts rapid recitation and handwritten waiver undermine understanding.	State none required beyond complete Miranda substance; videotape confirms understanding.	Written waiver not required; videotaped warnings support validity.
Was Hubbard competent to waive rights given alleged intoxication?	Hubbard's prior intoxication calls into question capacity to understand waivers.	Intoxication does not per se invalidate a valid waiver; competency assessed from conduct.	Hubbard was competent to waive; prior intoxication did not negate understanding.
Did the trial court properly deny suppression based on the Miranda analysis?	None stated beyond overall suppression challenge.	State maintained Miranda warnings and waiver complied with law.	Motion to suppress correctly denied; judgments affirmed.

Moran v. Burbine, 475 U.S. 412 (U.S. 1986) (two-part Moran test for waiver sincerity and awareness)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (necessity of warnings and waiver procedures)
Howard v. State, 458 A.2d 1180 (Del. 1983) (intoxication does not per se invalidate a valid waiver)
Whalen v. State, 434 A.2d 1346 (Del. 1981) (considerations for evaluating waiver and competency)
Berghuis v. Thompkins, 130 S. Ct. 2250 (2010) (defendant's statements must reflect a voluntary, knowing waiver)
Florida v. Powell, 130 S. Ct. 1195 (2010) (clarified sufficiency of Miranda warnings when conveyed)
Traylor v. State, 458 A.2d 1170 (Del. 1983) (factors informing capacity to understand Miranda rights)
Moran v. Burbine, 475 U.S. 412 (U.S. 1986) (two-part test for waiver voluntariness and awareness)