The Delaware Supreme Court has affirmed a sexual assault conviction in *DeAngelis v. State*, rejecting the defendant's argument that the trial court improperly coerced the jury into reaching a guilty verdict. Douglas DeAngelis, who was convicted on multiple sexual assault charges, had sought a new trial claiming the judge's response to jury communications functioned as an improper Allen charge.
The case stems from DeAngelis's arrest on Feb. 14, 2023, for allegedly sexually assaulting a female victim. He was subsequently indicted on one count of second-degree rape, one count of fourth-degree rape, and one count of second-degree assault. The charges reflect the serious nature of the alleged criminal conduct and carry significant potential penalties under Delaware law.
The trial proceedings began on Monday, April 15, 2024, and spanned six days. Following the presentation of evidence and closing arguments, the jury began deliberations on Friday, April 19, 2024. However, the jurors were unable to reach a verdict on that first day of deliberations, highlighting the complexity of the case and the careful consideration required.
Deliberations resumed the following Monday, April 22, 2024. During the morning session, the jury sent two critical notes to the trial judge just before the lunch break. The first note sought clarification on the legal definition of sexual intercourse in relation to the second-degree rape charge. Specifically, the jury asked: "In relation to Rape in the 2nd Degree: Is 'sexual intercourse' inclusive of genitalia coming in contact without penetration? The definition we received states 'an act of physical union of a person's gen[italia].' We are looking for clarity."
Before the trial court could respond to this first note, the jury sent a second communication that would become central to the appeal. While the full text of the second note is not completely provided in the court record, it began with: "IF THE JURY HAS REACHED A VERDICT ON ONE OR MORE." This second note appears to have addressed the jury's progress in reaching decisions on the multiple charges.
The trial judge's response to these jury communications became the focal point of DeAngelis's appeal. An Allen charge, named after the Supreme Court case *Allen v. United States*, refers to a specific type of jury instruction given when jurors report they are deadlocked. Such charges are designed to encourage continued deliberation while being careful not to coerce a verdict. The key legal issue is whether the instruction improperly pressures jurors to abandon their individual judgment in favor of reaching any verdict.
DeAngelis argued that the trial court's response to the jury's notes constituted an improper Allen charge that unduly coerced the jurors to reach a verdict against him. This type of claim is significant because defendants have a constitutional right to a verdict reached through the independent judgment of jurors, free from improper pressure from the court.
The Delaware Supreme Court, in a unanimous decision authored by Chief Justice Seitz and joined by Justices Valihura and Griffiths, rejected DeAngelis's argument. The court found that the trial court's response to the jury's notes did not constitute an Allen charge. The opinion, decided on Jan. 28, 2026, after submission on Nov. 19, 2025, affirmed the Superior Court's denial of DeAngelis's motion for a new trial.
The court's analysis focused on the specific language and context of the trial judge's response to the jury communications. Allen charges must be carefully crafted to avoid suggesting that jurors should abandon their honest convictions merely to reach consensus. Courts must balance the goal of encouraging thorough deliberation with the imperative of preserving each juror's independent judgment.
The timing of the jury's questions and the trial court's responses appears to have been crucial to the Supreme Court's analysis. The jury's first note sought legal clarification on the definition of sexual intercourse, which is a standard type of question that trial judges routinely address during deliberations. The second note, though incomplete in the record, appears to have related to the jury's progress on reaching verdicts.
This case highlights the delicate balance trial courts must maintain when communicating with deliberating juries. While courts have a duty to provide legal guidance when juries ask legitimate questions about the law or their duties, they must avoid any appearance of pressuring jurors to reach a particular outcome or to abandon their honest beliefs about the evidence.
The affirmance of DeAngelis's conviction means that his convictions on the sexual assault charges remain in effect. The Delaware Supreme Court's ruling establishes that the trial proceedings were conducted properly and that the defendant received the fair trial guaranteed by the Constitution.
The case demonstrates the careful scrutiny appellate courts apply to claims of jury coercion while also showing the high standard defendants must meet to prove that a trial court's communications with a jury were improper. The unanimous nature of the Delaware Supreme Court's decision suggests that the trial court's handling of the jury communications clearly fell within acceptable bounds.