Heck v. State

Summary

The Delaware Supreme Court affirmed Stephen Heck’s conviction for first-degree murder. The Court held that the affidavit established probable cause for obtaining Heck’s cell-site location information and that presumptive blood-test evidence was sufficiently reliable for admission under Delaware Rule of Evidence 702. The Court also rejected Heck’s unpreserved prosecutorial-misconduct claim concerning the prosecutor’s statement about the estimated time of death.

Holdings

1. The CSLI warrant affidavit established probable cause because, viewed under the totality of the circumstances and within the affidavit's four corners, it demonstrated a logical nexus between Heck's CSLI and evidence related to Amalfitano's murder.
2. The Bluestar and PPB presumptive blood tests and accompanying expert testimony were sufficiently reliable for admission under D.R.E. 702; the rule requires reliability, not conclusive or infallible methods.
3. The prosecutor's statement did not warrant reversal because it was likely an inadvertent mid-sentence correction, and, even assuming intentional misconduct, it did not adversely affect Heck's substantial rights or the fairness and integrity of the trial.

Questions Presented

1. Whether the affidavit supporting the warrant for Heck's cell-site location information established probable cause and a logical nexus between the requested CSLI and evidence of Amalfitano's murder.
2. Whether presumptive Bluestar and reduced phenolphthalein blood tests, together with related expert testimony, satisfied Delaware Rule of Evidence 702's reliability requirement.
3. Whether the prosecutor's inaccurate statement about the estimated time of death constituted prosecutorial misconduct and plain error requiring reversal.

Disposition

affirmed