Becerra v. State of Delaware

Summary

The Delaware Supreme Court affirmed Jose Becerra’s convictions and sentence for robbery, conspiracy, firearm offenses, aggravated menacing, and second-degree burglary. The court rejected his claims concerning the admission of alleged hearsay and irrelevant testimony and the Superior Court’s failure to grant a judgment of acquittal sua sponte, reviewing the unpreserved claims for plain error.

Holdings

1. The Superior Court did not commit plain error in admitting the challenged testimony. The unpreserved objections did not establish actual prejudice, and the co-conspirator statements would have been admissible because the State could have established the conspiracy by a preponderance of the evidence.
2. The Superior Court did not commit plain error by failing sua sponte to grant a judgment of acquittal because the evidence, viewed in the light most favorable to the State, was sufficient for a rational trier of fact to find Becerra guilty beyond a reasonable doubt.

Questions Presented

1. Whether the Superior Court committed plain error by admitting testimony that Becerra claimed contained hearsay and irrelevant statements.
2. Whether the Superior Court committed plain error by failing sua sponte to grant Becerra a judgment of acquittal at the close of the State's case.

Disposition

affirmed