Finney v. State

Summary

The Delaware Supreme Court affirmed Artezz Finney’s conviction for possession of a firearm by a person prohibited. The court held that Finney waived appellate review of Fourth Amendment challenges to the vehicle stop and inventory search because those grounds were not raised in his pretrial suppression motion. The court declined to conduct plain-error review because the evidentiary record was underdeveloped as a result of the default.

Holdings

1. A defendant who files a suppression motion narrowly focused on a Miranda violation waives appellate review of separate Fourth Amendment claims concerning the vehicle stop and inventory search when those claims were not raised in the pretrial motion.
2. The court will not engage in plain-error review when the defendant's failure to raise the suppression grounds before trial effectively prevented the State from developing an evidentiary record relevant to those grounds.

Questions Presented

1. Whether Finney's Fourth Amendment challenge to the officers' stop of his vehicle was waived because it was not raised in his pretrial motion to suppress.
2. Whether Finney's Fourth Amendment challenge to the inventory search was waived because it was not raised in his pretrial motion to suppress.
3. Whether the Supreme Court should review the newly raised Fourth Amendment claims for plain error.

Disposition

affirmed