Cogan v. State

Summary

The Delaware Supreme Court affirmed Jeffrey Cogan’s conviction for criminal contempt of a domestic violence protective order. The Court held that sufficient evidence supported the jury’s finding that Cogan’s violation occurred in Delaware, including evidence that the recipient received the offending text messages at her workplace in Delaware.

Holdings

1. The evidence was sufficient for a rational jury to find beyond a reasonable doubt that Cogan’s violation of the protective order occurred in Delaware.
2. On de novo review, the court determines whether any rational trier of fact, viewing the evidence in the light most favorable to the State, could find every element of the offense beyond a reasonable doubt.

Questions Presented

1. Whether sufficient evidence supported the jury’s finding that Cogan’s violation of the domestic violence protective order occurred in Delaware, as required by 11 Del. C. § 1271A(a)(1).

Disposition

affirmed