Supreme Court of Delaware
Garnett v. State
October 24, 2023
Summary
The Delaware Supreme Court affirmed the denial of Aaron Garnett’s motion to suppress physical evidence and his confession after police entered a residence without a warrant and discovered the victim’s body. The Court held that Delaware recognizes an inevitable-discovery exception under Article I, § 6, provided the State proves by a preponderance of the evidence that the evidence would have been lawfully discovered and that police did not act in bad faith to accelerate its discovery. The Court concluded that the body, related physical evidence, and confession would have been discovered through lawful investigative steps, although it did not reach the alternative attenuation theory.