Summary
This Delaware Superior Court order denies Defendant Jesse R. Longfellow’s Motion for Correction of Illegal Sentence under Rule 35(a). Longfellow contended that his jointly recommended 31-year sentence violated Erlinger v. United States because it allegedly required jury findings and constituted an illegal enhancement. The court rejected these arguments, explaining that the sentence fell within the standard statutory range, involved no judicial enhancements, and resulted from a negotiated plea agreement that waived further evidentiary burdens. Accordingly, the motion and request for appointed counsel were denied.
Topics
Practice areas
Questions Presented
- Whether a Rule 35(a) motion for correction of illegal sentence is proper when the sentence was not enhanced and no facts required jury determination.
- Whether Erlinger v. United States applies to the defendant’s sentence.
Holdings
- The motion is denied because the sentence was not enhanced and no facts required a jury finding.
Key quotations
“Mr. Longfellow has failed to demonstrate any illegality affecting his sentence. He has also failed to demonstrate Erlinger has any applicability to his sentence. Accordingly, his motion under Rule 35(a) is DENIED.” (at 7)
Factual background
Jesse R. Longfellow pleaded guilty to robbery in the first degree and possession of a deadly weapon during the commission of a felony in January 2012. He received a 31‑year sentence at supervision level V, with the sentence suspended after 30 years. No sentencing enhancements were applied, and the plea colloquy disclosed the statutory minimum and maximum penalties.
Procedural history
Defendant pleaded guilty in 2012 and was sentenced to 31 years. In June 2025 he filed a Rule 35(a) motion seeking correction of an allegedly illegal sentence. The court denied the motion.