State v. Church

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE STATE OF DELAWARE ) ) v. ) I.D. No. 2403005415 ) CHRISTIAN CHURCH, ) ) Defendant. ) Submitted: June 2, 2025 Decided: June 11, 2025 ORDER Upon Defendant’s Motion For Reargument DENIED 1. Following a jury trial, Christian Church (“Defendant”) was convicted of two counts of Assault in the Second Degree. On Defendant’s renewed motion, the Court granted a judgment of acquittal for one assault but denied acquittal for the other. Defendant now moves for reargument. For the reasons that follow, Defendant’s motion is DENIED. FACTUAL AND PROCEDURAL BACKGROUND 1 2. The relevant facts are included in this Court’s memorandum opinion and order dated May 15, 2025. 2 3. Beginning January 21, 2025, Defendant was tried on the charge of Assault in the First Degree of Kaden Handte (“Handte”) and Assault in the Second Degree of Amarion Nutter (“Nutter”). At the close of the State’s case-in-chief, Defendant moved for judgment of acquittal on both charges. The Court denied that 1 Citations in the form of “D.I. ___” refer to docket items. 2 See State v. Church, 2025 WL 1411722, at *2–4 (Del. Super. May 15, 2025). motion. On January 29, 2025, the jury returned a verdict of guilty on the lesser included offense of Assault in the Second Degree of Handte (the “Handte Conviction”) and the charged offense of Assault in the Second Degree of Nutter (the “Nutter Conviction”). 4. Defendant timely filed a renewed motion for judgment of acquittal and a motion for a new trial. On May 15, 2025, the Court issued an opinion and order granting Defendant’s motion for judgment of acquittal as to the Nutter Conviction, denying it as to the Handte Conviction, and denying his motion for a new trial.3 5. On May 22, 2025, Defendant attempted to file a motion for reargument seeking acquittal of the Handte Conviction. That motion was rejected because it exceeded the applicable page limitations. On May 23, 2025, Defendant re-filed the motion along with a motion to exceed page imitations (the latter of which the State did not oppose).4 The Court approved the motion to exceed page limitations on May 27, 2025.5 On June 2, 2025, the State filed a response to Defendant’s motion for reargument. 6 STANDARD OF REVIEW 6. In Delaware, there is no specific criminal rule governing motions for reargument. 7 Superior Court Criminal Rule 57(d) provides for the application of the 3 See generally id. 4 D.I. 41, 42. 5 D.I. 43. As a technical matter, Defendant’s motion for reargument was untimely, as he was required to file the motion no later than May 22, 2025. However, because Defendant attempted to file the motion on that date, the Court will consider it on its merits. Cf. Dishmon v. Fucci, 32 A.3d 338, 346 (Del. 2011) (“Delaware has a strong public policy that favors permitting a litigant a right to a day in court.”). 6 D.I. 45. 7 See Samuel v. State, 3 A.3d 1098, 2010 WL 3245109, at *1 (Del. Aug. 17, 2010) (ORDER) (“A timely-filed motion for reargument is ‘the proper device for seeking reconsideration’ of [this Court's] findings of fact and conclusions of law.”); accord Whitfield v. State, 981 A.2d 1174, 2009 WL 3111680, at *1 (Del. Sept. 29, 2009) (ORDER). 2 Superior Court Civil Rules when no criminal rule is controlling. Thus, Superior Court Civil Rule 59(e) applies to Defendant's motion.8 7. “Delaware law places a heavy burden on a party seeking relief pursuant to [Superior Court Civil] Rule 59.” 9 “Motions for reargument should not be used to rehash arguments decided by the Court, or to present new arguments not previously raised” 10 because such use “frustrates the efficient use of judicial resources, places the opposing party in an unfair position, and stymies the orderly process for reaching closure on the issues.” 11 The Court will grant a motion for reargument only if the movant shows that “the Court has overlooked a controlling precedent or legal principles, or the Court has misapprehended the law or facts such as would have changed the outcome of the underlying decision.” 12 ANALYSIS 8. Defendant makes three core arguments. The first is that the jury’s verdict acquitting Defendant of Assault in the First Degree but convicting him of Assault