State v. Murray

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE STATE OF DELAWARE, I.D. No. 1602007591 IMEIR MURRAY, Defendant. Submitted: October 25, 2016 Decided: January 11, 2017 Opinion Issued: April 13, 2017 Corrected: Apri127, 2017 OPINION Upon Defendant Imeir Murray ’s Motion to Dismiss, DENIED. Cynthia F. Hurlock, Deputy Attorney General, Department of JuStice, Wilmington, Delaware, Attorney for the State of Delaware. Colleen E. Durkin, Esquire, and Matthew C. Buckworth, Esquire, Collins & Associates, Wilmington, Delaware, Attorneys for Defendant Imeir Murray. WALLACE, J. I. INTRODUCTION Just over a year ago, Delaware decriminalized the act of possessing a small quantity of marijuana for personal use. This motion, brought by a criminal defendant arrested shortly after that enactment, brings to the fore some undereXamined (or, more likely, some wholly unanticipated) consequences of that change. II. STATUTORY BACKGROUND: DELAWARE’s FAsT-CHANGING DRUG LAwsl In 2011, at the urging of the Drug Law Revisions Committee, Delaware repealed significant portions of its extant criminal drug code and replaced it with laws creating three main drug crimes.2 The least serious drug offenses - those prohibiting simple possession of controlled substances were: (l) re-written; (2) enumerated as Sections 4763 and 4764 of Title 16; (3) placed within the original jurisdiction of the Court of Common Pleas; and, (4) assigned the lowest criminal penalties.3 l For simplicity’s sake, the statutory history recounted here and referenced throughout this Opinion will speak only to the changes made and the present statutory language applicable to adults who violate Delaware’s marijuana and firearms laws. 2 See Del. H.B 19 syn., 146th Gen. Assem., 78 Del. Laws ch. 13 (2011). 3 See id. (noting the new drug laws classified “the simplest form of unlawful [drug] possession” _ i.e., those defined in the new 16 Del. C. §§ 4763(a) & 4764(b) _ as Delaware’s lowest grade misdemeanors); ia’. at § 58 (stating simple possession of any controlled substance other than marijuana became a class B misdemeanor); id. at § 61 (stating simple possession of marijuana became an unclassified misdemeanor). _2_ That same 2011 Act also introduced a new felony to the Delaware Criminal Code. That crime defined a brand-new set of persons prohibited from possessing or controlling certain weapons: Any person, if the deadly weapon is a semi-automatic or automatic firearm, or a handgun, who, at the same time, possesses a controlled substance in violation of § 4763, 01~ § 4764 OrTirle 16.4 As the rather simple language manifests, this statute created this new low-grade felony “for a person who possesses a handgun or semi-automatic or automatic firearm at the same time as the person possesses a controlled substance.”5 Four years later, Delaware reduced the penalties for simple possession of marijuana even further. The provisions outlawing the illicit possession of marijuana were: (1) again re-written; (2) still enumerated as Section 4764 of Title 16; (3) conferred split original jurisdiction between the Court of Common Pleas and the Justice of the Peace Court; and, (4) assigned the lowest criminal misdemeanor and civil violation status.6 As applicable to this case, the law now 4 Ia’. at § 5 (codified at ll Del. C. § 1448(a)(9) (2011) [hereinafter “PFBPP”]). 5 Ia'. at syn. 6 See Del. H.B. 39 syn., 148th Gen. Assem., 80 Del. Laws ch. 38 (2015); id. at § 2 (creating new civil violation for possession of less than an ounce of marijuana for personal use and leaving that offense within § 4764 of Title 16); id. at § 5 (conferring original jurisdiction over criminal marijuana possession offense to the Court of Common Pleas and original jurisdiction over civil marijuana possession violation to the Justice of the Peace Court). _3_ provides: Any person 18 years of age or older, but under 21 years of age, who [l Paul R. Wallace, Judge _17_