Monceaux v. State
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Defendant-Appellant Patrick Monceaux appealed the denial of his motion to dismiss charges against him under Section 777A of the Delaware Code. He contended that the statute violated his right to due process under the United States and the Delaware Constitutions because placing his status as a sex offender directly in issue lessened the State's burden of proof and the presumption of innocence. He also contended that the trial judge erred by failing to address this constitutional argument when denying his motion to dismiss. Instead, the trial judge bifurcated the trial into two phases. In the first phase, the elements of the Unlawful Sexual Contact Second Degree charge were tried before a jury with no evidence of Monceaux's status as a sex offender. With the consent of Monceaux, the second phase of the trial, limited to determining his status as a registered sex offender, was tried before the trial judge. The bifurcation procedure used by the trial judge in this case prevented the jury from hearing evidence of Monceaux's sex offender status before determining his guilt for purposes of Section 777A. For that reason, the Supreme Court found no merit to Monceaux's constitutional claim. Furthermore, the Court held that the Superior Court must use a bifurcation procedure in all future Section 777A cases, to avoid the potential constitutional issues raised here. Finally, because the alternate relief requested in Monceaux's motion to dismiss was bifurcation, which the trial judge granted, Monceaux's second claim on appeal lacked merit. Accordingly, the Supreme Court affirmed.
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