Summary
The Delaware Supreme Court conducted mandatory review of Chauncey S. Starling's two death sentences following his convictions for first-degree murder. The court held that the statutory aggravating circumstances were supported by the evidence, the sentences were not arbitrarily or capriciously imposed, and the sentences were not disproportionate to those imposed in comparable Delaware cases. The court affirmed both death sentences and remanded for further proceedings.
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Practice areas
Questions Presented
- Whether sufficient evidence supported the jury's findings that the three statutory aggravating circumstances had been established beyond a reasonable doubt.
- Whether the Superior Court's imposition of two death sentences was arbitrary or capricious under 11 Del. C. § 4209(g)(2)(a).
- Whether the death sentences were disproportionate to sentences imposed in comparable Delaware first-degree murder cases.
Holdings
- The evidence was sufficient to support the jury's unanimous findings beyond a reasonable doubt that all three alleged statutory aggravating circumstances existed.
- The Superior Court's imposition of death for each murder was neither arbitrary nor capricious.
- The death sentences were not disproportionate to sentences imposed in other Delaware first-degree murder cases involving a penalty hearing and a final life or death sentence.
Key quotations
“The Supreme Court shall limit its review under this section to the recommendation on and imposition of the penalty of death and shall determine:” (903 A.2d at 762-763)
“is not a mere counting process of X number of aggravating circumstances and Y number of mitigating circumstances but rather a reasoned judgment as to what factual situations require the imposition of death and which can be satisfied by life imprisonment in light of the totality of the circumstances present.” (903 A.2d at 765)
“the product of a deliberate, rational and logical deductive process” (903 A.2d at 765)
Factual background
On March 9, 2001, a masked gunman entered the Made-4-Men barbershop in Wilmington and shot Darnell Evans multiple times, including twice in the head, and also shot five-year-old Damon Gist Jr. Both victims died. The prosecution's principal witness testified that Starling had identified Evans, armed himself, entered the shop, and later admitted shooting the child. The jury convicted Starling of two first-degree murders and related firearm and conspiracy offenses and unanimously recommended death for both murders.
Procedural history
Starling was convicted by a jury of two counts of first-degree murder and related firearm and conspiracy offenses. The Superior Court initially imposed two death sentences on June 10, 2004; on direct appeal, the convictions were affirmed but the death sentences were vacated and the matter was remanded for resentencing. After a second penalty hearing, the Superior Court again imposed death sentences on October 12, 2005, leading to this mandatory review.
Remand instructions
The matter was remanded to the Superior Court for further proceedings consistent with the opinion.