Djavon P. Holland, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The court held that the second indictment was not barred by the applicable successive-prosecution statute or collateral-estoppel principles, but that the State’s addition of attempted-robbery charges after the first trial triggered a presumption of vindictive prosecution that the State failed to rebut. It therefore reversed the attempted-robbery, home-invasion, and associated firearm convictions while leaving the convictions on charges included in the first indictment intact. The court also held that Holland knowingly, intelligently, and voluntarily waived his Sixth Amendment right to counsel. No separate opinions were filed.