Gattis v. State, 637 A.2d 808 (Del. 1994)

Cases | Gattis v. State, 637 A.2d 808 (Del. 1994) | 2018

The defendant was convicted of first-degree murder, first-degree burglary and possession of a deadly weapon. At sentencing, the State presented testimony of the victim’s mother concerning the effect of her daughter’s death, including a statement that the trial was difficult. The defense counsel objected, and the court instructed the jury that the family member’s view of the trial was not particularly relevant. The defendant was sentenced to death and appealed on several grounds, including that the jury instruction was legally insufficient. The court held that the trial court properly considered the victim impact evidence. To the extent that any victim impact evidence was received, it was used only to establish the existence of a non-statutory aggravating circumstance. The evidence was of limited significance in the total mix of aggravating circumstances or in weighing all aggravating factors against the mitigating factors. The trial court confined the evidence within the narrow bounds of the pain and trauma caused by the victim’s death.