Ronald Hoennicke, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The court affirmed Hoennicke’s convictions, holding that the 2003 amendment eliminating the limitations period applied because the earlier limitations period had not expired when the amendment took effect. Applying the amendment did not violate the Ex Post Facto Clause, and the State sufficiently alleged and proved that the prosecution was not based on memories recovered through psychotherapy. The court also held that a rational factfinder could find the statutory element beyond a reasonable doubt despite the limited circumstantial evidence.