Palmer v. State, 485, 2016

Police received tips in Oct–Nov 2015 that 311 W. 29th St. in Wilmington was a "stash house" for weapons; one tip came from a confidential informant described as "past proven and reliable."
Surveillance showed frequent short-term visitor activity consistent with a stash house; officers also knew defendant Isaiah Palmer lived at that address and was prohibited from possessing firearms because of prior convictions.
Police obtained a magistrate-issued search warrant for firearms at the residence, executed it on November 12, 2015, and found a .45 handgun on a box in the basement bedroom, ammunition in a shed, and quantities of heroin in the house and outside bins.
Palmer was indicted on drug and weapons charges; a motion to suppress the search results was denied; trials produced convictions for Aggravated Possession and Possession of a Firearm During Commission of a Felony (jury), and Possession of a Firearm/Ammunition by a Person Prohibited (bench).
On appeal Palmer argued (1) the warrant affidavit lacked probable cause (insufficient informant corroboration) and (2) the trial court erred by instructing the jury on joint possession and failing to give a curative instruction after a jury question.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for warrant	State: affidavit (two informants, surveillance, officers' knowledge of Palmer) gave magistrate enough for probable cause	Palmer: informant info insufficiently corroborated; affidavit lacked detail on informants' basis of knowledge; anonymous shooting call irrelevant	Affirmed — totality of circumstances (reliable CI, corroborative surveillance, officers' knowledge) supported magistrate's finding of probable cause
Jury instruction on joint possession (and curative instruction)	State: instruction appropriate where others had access to room where drugs found; jury must still find possession beyond reasonable doubt	Palmer: no evidence of joint enterprise or shared possession; jury question implied unsupported assumption; requested curative instruction not given	Affirmed — joint-possession instruction supported by evidence of other persons' access; curative-instruction claim waived for failure to raise at trial or in opening brief

Rivera v. State, 7 A.3d 961 (Del. 2010) (standard of review for suppression rulings)
Fink v. State, 817 A.2d 781 (Del. 2003) (search-warrant issuance requires probable cause)
Sisson v. State, 903 A.2d 288 (Del. 2006) (affidavit must show reasonable belief evidence will be found in place searched)
McKinney v. State, 107 A.3d 1045 (Del. 2014) (deference to magistrate’s probable-cause determination)
Smith v. State, 887 A.2d 470 (Del. 2005) (totality-of-circumstances test for informant tips)
Robertson v. State, 41 A.3d 406 (Del. 2012) (standard of review for jury instructions)
Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for probable cause)