State v. Hamilton
1501012432
| Del. Super. Ct. | Oct 12, 2017Background
- On Jan. 10, 2015 Delaware State Police (DSP) responded to 113 E. Cayhill Lane after Keisha Hamilton was reported missing by her sister; DSP found large pools of blood, blood spatter, and a large knife in the house.
- Keisha’s son, Alvin (age 14), furnished police a key and asked them to search for his mother; police entered without a warrant, discovered blood, and did field testing confirming human blood.
- DSP issued an AMBER alert for the missing children; Indiana State Police (ISP) located and stopped a red 2005 Chevrolet Suburban later that day, detained Cortez Hamilton (defendant) and found the children.
- ISP obtained a warrant and searched the Suburban (Jan. 11, 2015), seizing bloody items and personal effects; DSP also obtained warrants and searched the Toyota Matrix (Jan. 11) and performed additional residence searches (Jan. 10, Jan. 15, Feb. 13).
- Defendant moved to suppress evidence on multiple grounds: unlawful warrantless residence entry; invalid warrants or overbroad searches (Residence, Suburban, Matrix); improper AMBER alert/stop; and untimely warrant returns.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Warrantless entry of residence (Jan. 10) | State: entry was lawful by Alvin West's consent or under emergency/community-caretaker doctrines; plain-view seizures admissible | Hamilton: no valid consent (minor), entry exceeded scope; field testing of blood improper; suppress fruits of entry | Denied — entry valid: Alvin (14) had actual authority under totality; emergency doctrine also satisfied; plain-view seizures and field tests admissible |
| AMBER alert and ISP stop | State: AMBER properly issued; alert provided reliable, specific BOLO supporting investigatory stop | Hamilton: AMBER unjustified; stop unlawful, so seizure/search invalid | Denied — AMBER issuance within police discretion; information reliable and specific enough to justify Terry-style stop |
| ISP warrant/search of Suburban (probable cause & scope) | State: affidavit (blood at home, AMBER, Suburban matching description) provided probable cause; seized items related to crime | Hamilton: lacked probable cause; search exceeded warrant scope | Part Granted/Part Denied — warrant supported by probable cause; most seized items admissible except Suburban brake pad and gas pedal (no indication blood/fibers present) |
| DSP warrant/search of Toyota Matrix (probable cause & scope) | State: abandoned vehicle belonging to missing Keisha near scene; probable cause to search for evidence of assault/disappearance | Hamilton: no nexus showing vehicle contained evidence; some seized items exceeded warrant scope | Part Granted/Part Denied — probable cause existed to search vehicle; but duct tape and soil/brake-pedal/shifter-knob dirt samples suppressed as outside warrant/plain-view nexus |
| Timeliness of warrant returns | State: late returns do not invalidate valid warrants; no prejudice shown | Hamilton: late inventory/returns require suppression of seized evidence | Denied — late filings do not invalidate otherwise lawful searches; suppression not warranted for late returns |
Key Cases Cited
- Rakas v. Illinois, 439 U.S. 128 (U.S. 1978) (standing requires legitimate expectation of privacy)
- United States v. Matlock, 415 U.S. 164 (U.S. 1974) (third-party consent via common authority)
- Illinois v. Rodriguez, 497 U.S. 177 (U.S. 1990) (limits on third-party consent when common authority absent)
- Arizona v. Gates, 462 U.S. 213 (U.S. 1983) (totality-of-the-circumstances test for probable cause in warrant affidavits)
- State v. Derrickson, 321 A.2d 497 (Del. 1974) (late warrant returns do not invalidate otherwise legal searches)
- Guererri v. State, 922 A.2d 403 (Del. 2007) (emergency-doctrine standards for warrantless home entry)
- Tomlinson, 648 N.W.2d 367 (Wis. 2002) (minor’s consent evaluated under totality of circumstances)
- Moore v. State, 997 A.2d 656 (Del. 2010) (plain-view and limits on warrantless seizure)
- People v. Bondi, 474 N.E.2d 733 (Ill. App. Ct. 1984) (missing-person report can support emergency entry)
- Sisson v. State, 903 A.2d 288 (Del. 2006) (Delaware four-corners test for probable cause in warrant affidavits)