The Delaware Supreme Court has upheld the Superior Court’s decision to deny Ralph Reed’s motion to correct his sentence for a 1999 murder conviction. Reed, who was 18 at the time of the crime, had argued that his sentence was illegal and unconstitutional. The Supreme Court disagreed, finding his arguments without merit and affirming the lower court’s ruling.
Background of the Case
The case dates back to November 1999, when Reed fatally shot Gregory Howard. Reed was subsequently convicted of first-degree murder and possession of a firearm during the commission of a felony (PFDCF). He received a sentence of life imprisonment without parole for the murder conviction and twenty years of incarceration for the firearm conviction. The Delaware Supreme Court previously affirmed these convictions on direct appeal in 2001.
Reed’s Arguments for Sentence Correction
In June 2025, Reed filed a motion for correction of illegal sentence with the Superior Court. He presented two primary arguments:
* Erlinger Claim: Reed argued that his sentences were illegal under the Supreme Court case *Erlinger v. United States* because the sentencing judge, he claimed, enhanced his sentences based on factual findings not determined by a jury.
* “Emerging Adult” Claim: Reed also contended that his life-without-parole sentence was unconstitutional because he was between the ages of eighteen and twenty when he committed the crimes, thus falling into the category of an “emerging adult.”
The Supreme Court’s Analysis and Ruling
The Supreme Court reviewed the Superior Court’s decision for abuse of discretion and considered any questions of law *de novo*. The court outlined what constitutes an illegal sentence, as defined by Delaware law, including sentences that exceed statutory limits, violate the Double Jeopardy Clause, or are ambiguous.
The Supreme Court rejected both of Reed’s arguments, affirming the Superior Court’s denial of his motion.
* Rejection of the Erlinger Claim: The court found that *Erlinger* didn’t apply in Reed’s case. The *Erlinger* case dealt with situations where a judge’s factual findings increased the maximum or minimum sentence a defendant could receive. However, in Reed’s case, the sentencing judge did not make any such factual determinations. The sentences Reed received (life without parole for murder and the statutory maximum for PFDCF) fell within the legal parameters at the time of the crime.
* Rejection of the “Emerging Adult” Claim: The court noted that it had previously rejected the argument that a life-without-parole sentence for someone aged 18-20 was unconstitutional. Therefore, the court found no basis to overturn the Superior Court’s decision on this point.
The Supreme Court also addressed an additional argument raised by Reed: that the indictment failed to include facts essential to the charged crimes and sentences. However, because Reed did not raise this claim in the Superior Court, the Supreme Court declined to consider it for the first time on appeal, citing Supreme Court Rule 8.
Conclusion
The Delaware Supreme Court’s decision affirms the original sentences imposed on Ralph Reed. The court found that his arguments for a sentence correction lacked merit, and the Superior Court’s ruling was upheld.