State v. Lewis, 2402003067

Mashawn Lewis was found guilty by a jury of Possession of a Firearm by a Person Prohibited (PFBPP), based on a prior conviction for Carrying a Concealed Deadly Weapon (CCDW).
After the verdict, the Court needed to determine whether Lewis was subject to a three-year or five-year minimum mandatory sentence under 11 Del. C. § 1448(e)(1), based on the timing of his prior violent felony conviction.
The issue arose after the State sought to impose the enhanced five-year minimum mandatory sentence under § 1448(e)(1)(b), which applies if the prior violent felony occurred within the last 10 years.
Lewis argued, relying on recent U.S. Supreme Court precedent, that any fact increasing the mandatory minimum (e.g., timing of the prior conviction) should be proven to a jury beyond a reasonable doubt.
The Court considered recent case law on the limits of judicial factfinding at sentencing, specifically distinctions between acceptable findings of prior convictions and prohibited factfinding of case-specific details.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court or jury must determine if prior conviction occurred within 10 years for 5-year minimum under § 1448(e)(1)(b)	State: Court can make this determination using conviction documents	Lewis: Only jury can determine this, per recent SCOTUS cases	Court may make this determination; State’s request granted
Scope of judicial authority to examine facts related to prior convictions under recent case law	Court can look to date & jurisdiction of conviction	Factfinding beyond conviction elements violates Erlinger	Court can use indictment date; no additional factfinding required

Erlinger v. United States, 602 U.S. 821 (2024) (jury must determine specific factual questions regarding the nature/timing of prior offenses under the ACCA)
Almendarez-Torres v. United States, 523 U.S. 224 (1998) (established an exception allowing judicial factfinding as to the existence of prior convictions at sentencing)