State v. Martin
2202010805
| Del. Super. Ct. | Jun 16, 2023Background
- Late-night shooting at Coastal Taproom left victim fatally wounded; surveillance video and receipts identified Edward Martin as a suspect.
- Martin and his wife left the bar together and returned to their shared home; wife later arrested (DUI) and identified in video.
- Police located Martin’s residence, stopped a gray Mazda 3 shortly after the shooting, arrested Martin, and observed a handgun on the front passenger seat.
- An officer found an empty holster and a large quantity of 9mm ammunition in a culvert at the residence.
- Investigators seized two SD memory cards (one from a surveillance camera, one from Martin’s person), material from the residence, the Mazda 3, a Chevrolet Equinox, and obtained DNA via two warrants (second issued to correct a header error).
- Martin moved to suppress evidence from his residence, the Mazda 3, the Equinox (including a pool cue), the SD cards, and his DNA; parties declined live testimony and argued on briefs.
Issues
| Issue | State's Argument | Martin's Argument | Held |
|---|---|---|---|
| Validity / particularity of residence warrant | Warrant described items tied to the bar shooting (ballistics, trace, clothing); not a general warrant | Warrant was general/overbroad (language like "any article...to provide information") and trace-evidence language too vague | Denied suppression; warrant not general or overbroad |
| Validity / nexus for Mazda 3 warrant | Probable cause—Martin was linked to the crime, was driving the Mazda soon after shooting; clothing and ballistics items reasonably could be in vehicle | Warrant was general/overbroad and lacked nexus between Mazda and items sought | Denied suppression; warrant sufficiently particular and nexus established |
| Seizure from Chevrolet Equinox (pool cue) | Mostly conceded seizure exceeded scope for pool cue; other items were within warrant | Pool cue and other items exceeded scope | Suppression GRANTED as to pool cue; other Equinox items DENIED |
| SD memory cards (surveillance + card from pocket) | Warrant authorized forensic search of two SD cards; cards likely contained driveway/surveillance footage and the card from Martin matched camera card | Warrant language was sloppy and allegedly limited to cell phones; claimed lack of nexus between cards and residence | Denied suppression; sloppy drafting not fatal and nexus/support for both cards established |
| DNA warrants / Franks claim | Warrants (including reissued correct-copy) established probable cause to obtain DNA for comparison to seized evidence; no false statements warrant Franks hearing | Alleged scrivener/header errors and stale/false information; requested Franks hearing; argued lack of nexus to crime | Denied suppression; both warrants valid, no Franks hearing required, nexus and probable cause found |
| Phone evidence | State elected not to introduce phone contents | Sought suppression of cellphones | Moot (State represented it will not introduce cellphone evidence) |
Key Cases Cited
- State v. Sisson, 883 A.2d 868 (Del. Super. 2005) (defendant bears burden to show a search was unlawful)
- Cooper v. State, 228 A.3d 399 (Del. 2020) (magistrate’s probable-cause determination entitled to great deference)
- Wheeler v. State, 135 A.3d 282 (Del. 2016) (Particularity requirement and limits on general warrants)
- Fink v. State, 817 A.2d 781 (Del. 2003) ("including but not limited to" language may be acceptable when read with specific items)
- Dorsey v. State, 761 A.2d 807 (Del. 2000) (nexus requirement: logical inference that items sought will be found in place to be searched)