Manley v. State; Stevenson v. State

Summary

The Delaware Supreme Court affirmed the death sentences imposed on Michael R. Manley and David Stevenson for the murder of a witness scheduled to testify against Stevenson. The court rejected challenges to the use of an accomplice-liability instruction during the penalty phase and to the defendants' eligibility for capital punishment under Enmund and Tison. The court also upheld the evidence supporting the statutory aggravating circumstances and concluded that the sentences were neither arbitrary nor disproportionate.

Holdings

1. The Superior Court did not commit reversible error by explaining accomplice liability to the second penalty-phase jury because, viewed in the context of the entire charge, the explanation provided necessary background and did not authorize the jury to impose vicarious liability for statutory or nonstatutory aggravators.
2. Enmund and Tison did not preclude either defendant's death sentence, and the Superior Court did not err by refusing to submit separate Enmund/Tison interrogatories.
3. Sufficient evidence supported the jury's findings that Heath was killed to prevent his testimony, that Manley committed the murder as Stevenson's agent, and that the murder was premeditated and the result of substantial planning.
4. The death sentences were not arbitrarily or capriciously imposed and were not disproportionate to sentences imposed in similar Delaware capital cases.

Questions Presented

1. Whether the Superior Court committed reversible error by explaining accomplice liability to the second penalty-phase jury.
2. Whether Enmund v. Florida and Tison v. Arizona required submission of proposed interrogatories concerning the defendants' eligibility for the death penalty.
3. Whether sufficient evidence supported the statutory aggravating circumstances found as to Manley.
4. Whether the defendants' death sentences were arbitrarily or capriciously imposed or disproportionate under Delaware's statutory capital-sentence review.

Disposition

affirmed