Waller v. State
283, 2024
Del.Apr 14, 2025Background
- Zaire Waller was convicted by a jury in Delaware of disregarding a police officer’s signal and two counts of disregarding a red light after leading police on a car chase.
- The incident involved Waller failing to stop after being signaled by a uniformed police officer in a marked car, followed by multiple traffic violations before being apprehended and arrested.
- The statute under which Waller was charged, 21 Del. C. § 4103(b), does not expressly state a mental state (mens rea) required for conviction.
- Before trial, Waller objected to the jury instructions, claiming they failed to specify the necessary mens rea, arguing that the statute required intentionality and the jury needed a dictionary definition of "willful."
- The trial court, relying on precedent, inserted “willfulness” as the implied mental state in its instructions and told jurors to use the term’s common meaning, declining to provide a dictionary definition when asked during deliberations.
- After conviction, Waller appealed, arguing the jury instructions were both legally incorrect and confusing without a dictionary definition of "willful."
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jury instruction's failure to specify mental state | Jury must be instructed on intent, not just "willfulness" | "Willfulness" is the correct mens rea based on precedent | No error; "willfulness" sufficient, instructions proper |
| Omission of dictionary definition of “willful” | Failure to define "willful" confused jury | Common meaning is sufficient; jury not misled | No error; common meaning acceptable, not misleading |
| Application of default mens rea under § 251(b) | Default intent standard applies absent statutory mens rea | Statute and precedent already imply "willfulness" | Court followed correct standard, precedent controls |
| Standard of review for jury instruction dispute | De novo review applies | Abuse of discretion standard applies | Abuse of discretion standard used; instruction affirmed |
Key Cases Cited
- Edwards v. State, 285 A.2d 805 (Del. 1971) (establishes "willfulness" as implied mens rea for disregarding a police signal)
- Hankins v. State, 976 A.2d 839 (Del. 2009) (addresses standards for reviewing jury instructions)
- Burrell v. State, 953 A.2d 957 (Del. 2008) (guidance on reversing jury verdicts based on instructional error)
- Bullock v. State, 775 A.2d 1043 (Del. 2001) (standard for correct statement of law in jury instructions)