Rivera v. State
7 A.3d 961
| Del. | 2010Background
- Christine Pate's body was found in the Leipsic River on October 8, 2007, with evidence of a violent assault and asphyxiation by drowning.
- Rivera, Pate's neighbor and former spouse of Deanna Hall, became a focus of the investigation after River a's links to Hall and to Pinewood Acres surfaced.
- DNA from blood spots at the Pinewood Acres trailer matched Pate's DNA; Rivera had fresh lacerations on his left hand and is left-handed, consistent with the ME's findings.
- Detectives obtained a warrant to search Rivera's 1997 Pontiac Grand Am, which was registered to Hall, uncovering dirt, mud, and Pate's DNA in the vehicle.
- A Grand Am blood analysis connected to Pate's profile provided probable cause for arrest and charged Rivera with first-degree murder.
- Rivera moved to suppress the Grand Am evidence and sought to introduce expert testimony on parasomnias; the Superior Court denied suppression and limited the expert testimony, and Rivera was convicted after a five-day trial in December 2009.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the suppression court erred in probable cause analysis | Rivera contends the warrant relied on Hall being missing. | Rivera argues the affidavit misstated facts and misled the magistrate. | Probable cause supported; not harmed by Hall-missing-person misperception. |
| Whether omitted exculpatory facts negated probable cause under reverse-Franks | Rivera asserts omissions would undermine probable cause. | State contends omissions are not material or would not undermine probable cause. | Omissions not material; corrected affidavit still supports probable cause. |
| Whether expert testimony on parasomnias was properly admitted under evidence rules | Rivera argues Dr. Mark should opine Rivera had sleep terrors during the murder night. | State argues such testimony would be unreliable under Daubert/Delaware Rule 702. | Trial court did not abuse; Dr. Mark could address history but not testify that a terror occurred during the murder night. |
| Whether exclusion of certain expert testimony prejudiced Rivera | Excluded testimony foreclosed defense on mens rea for first-degree murder. | Judge acted within discretion; Rivera waived by not testifying; jury heard Rivera's narrative via other testimony. | No prejudice; jury credited the mens rea despite limitations on expert testimony. |
Key Cases Cited
- Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (omission of material false statements requires suppression if reckless disregard for truth)
- Sisson v. State, 903 A.2d 288 (Del. 2006) (reverse-Franks framework for material omissions in probable cause affidavits)
- Smith v. State, 887 A.2d 470 (Del. 2005) (probable cause review requires deference to magistrate's determination when supported by substantial basis)
- Blount v. State, 511 A.2d 1030 (Del. 1986) (purpose and scope of probable cause in warrant determinations)
- M.G. Bancorporation, Inc. v. Le Beau, Inc., 737 A.2d 513 (Del. 1999) (Daubert/Rule 702 gatekeeping; reliability of expert testimony)