Patrick J. Collins

Every Count

After about nine hours of deliberation across two days, a Delaware jury found Roman Shankaras not guilty of every charge arising from the 2017 uprising at the James T. Vaughn Correctional Center. The verdict covered murder, assault, kidnapping, riot, and conspiracy. Shankaras had finished a seven-year sentence in an unrelated case, yet remained in pretrial custody under $2.8 million cash bail. The acquittal ended that detention.

The result came from a case shaped by violence and loss. Correctional officer Steven Floyd was killed. Other staff members were attacked, and a counselor was held hostage for nearly twenty hours. Prosecutors charged eighteen inmates after the uprising, sixteen of them with murder. Collins addressed that gravity directly while keeping the jury’s task fixed on the evidence against Shankaras.

Shankaras had faced a murder conviction carrying mandatory life imprisonment. A twelve-person jury rejected every theory presented against him. Delaware Public Media reported that he became the fourth inmate fully acquitted in the Vaughn trials. Earlier trials had produced only one murder conviction among seven defendants. In Shankaras’s case, the jury found the evidence insufficient on every count.

A Case Built on Accomplice Liability

The prosecution relied on accomplice liability. It argued that a person who agreed to take part in the uprising could be responsible for murder, kidnapping, and assault as foreseeable results of the common undertaking. The theory gave the State a route to conviction without proving that Shankaras personally killed Floyd or attacked the other staff members.

Deputy Attorney General Nichole Warner acknowledged that no evidence directly connected Shankaras to Floyd’s death. She also told jurors that no testimony would show him wielding a weapon and that no DNA evidence would connect him to the attacks. The State pointed instead to prison letters and asked the jury to infer that Shankaras had helped plan the uprising.

Collins accepted that accomplice liability could apply and disputed whether the facts proved it. The State had to show that Shankaras joined the criminal plan it described and could foresee its crimes. The scale of the uprising did not prove agreement or turn presence into personal responsibility.

The Witness Who Carried the Theory

Royal Downs supplied the prosecution’s principal account. Downs was serving a life sentence for murder and had pleaded guilty to riot through an agreement with prosecutors. He described Shankaras as a planner and treated prison letters, known as kites, as evidence of leadership. With little physical evidence and no surveillance footage, his credibility carried unusual weight.

Collins presented Downs’s cooperation as a transaction influenced by Downs’s own legal position. He traced the witness’s dealings with investigators to the day the uprising ended. Downs later entered a plea agreement within weeks of the October 2017 indictments and kept Shankaras’s letters until they became useful. Collins described the relationship as a business partnership and asked jurors to judge the witness’s motive, timing, and legal advantage along with his words.

After the verdict, Collins told Delaware Public Media that credibility and motivation had mattered more than the absence of physical evidence. The jury was asked whether Downs’s account proved the charged conduct beyond a reasonable doubt and acquitted Shankaras on every count.

The Burden in Five Words

Collins reduced the burden of proof to a sentence jurors could use: “Probably guilty equals not guilty.” The Associated Press reported the line from his opening statement. It came after he reminded jurors that their oath required a verdict based on the evidence and the law, with the State carrying proof beyond a reasonable doubt.

Jurors could draw rational inferences, as the prosecutor urged, but each inference still had to rest on reliable evidence. The cooperating witness, disputed letters, and accomplice-liability theory had to prove Shankaras’s guilt without borrowing weight from Floyd’s death or the public importance of the prosecution.

After a full trial, the jury heard the State’s evidence and acquitted Shankaras on every count.

Suspicion Specific to the Passenger

Five years earlier, Collins had pressed the same discipline during a traffic-stop suppression hearing. Famous Rhoades was a passenger in a car stopped by members of the Governor’s Task Force. Another occupant had outstanding capiases and drug paraphernalia. Officers also recovered a billy club from elsewhere in the vehicle, then frisked Rhoades and found cocaine and other contraband.

The Superior Court treated the vehicle stop and the pat-down as separate seizures. Detaining the car did not automatically authorize a frisk of each occupant. An officer needed articulable facts supporting a reasonable belief that Rhoades himself was armed and dangerous. The opinion stated the point precisely: the facts had to be “specific to the person frisked.”

Officers had reasons to proceed cautiously, but none justified frisking Rhoades. He had not fled or threatened anyone. The capiases and paraphernalia concerned another passenger. The billy club was found away from Rhoades, the record contained no photograph of it, and no weapons charge followed. The State offered no evidence tying him to that object. The court granted Collins’s motion and suppressed the evidence recovered in the frisk.

From the Stop to the Apartment Searches

State v. Niyala required Collins to test a longer sequence. Police stopped Dilip Niyala’s vehicle, detained him, and conducted warrantless searches of the vehicle, his apartment, and another apartment. The resulting charges concerned drugs, firearms, ammunition, and related offenses. The State separately conceded that officers had questioned Niyala in custody without Miranda warnings and would not use his statement in its case-in-chief. Collins challenged the stop, the detention, the arrest authority, the consent searches, and the evidence obtained from each.

The Superior Court found that the State had not proven a valid traffic stop. It presented no testimony from the officers who actually stopped the vehicle, and the detective who said he saw a violation had separated himself from the stop. The court further found that any traffic purpose could not explain the extended detention that followed.

The confidential informant’s tip did not repair the problem. It lacked details about the alleged criminal activity and failed to establish reasonable articulable suspicion for the seizure or probable cause for a warrantless felony arrest. Niyala’s later consent followed the unlawful stop and detention without enough separation to purge the taint. The court suppressed the vehicle and apartment evidence as fruit of the poisonous tree.

Reargument Left the Ruling Intact

The State moved for reargument. It contended that one officer could relay a traffic observation to another, asked the court to revisit Delaware’s statutory arrest authority, and again asserted reasonable suspicion independent of the traffic stop. Collins opposed the motion and maintained that the ruling had applied the record and governing law correctly.

The court denied reargument. It found that the State had repeated positions already considered and had shown no controlling principle or material fact the court overlooked. The absence of testimony from the stopping officers remained consequential. So did the absence of new facts after the vehicle stopped that could support a longer detention.

The traffic observation, detention, informant’s information, arrest, consent, and resulting searches presented separate legal questions. Because the State failed to justify the stop and ensuing detention, the later consent did not remove the taint from the vehicle and apartment searches.

The State Entered the Defense File

State v. Robinson placed the boundary around the defense itself at issue. Robinson faced a first-degree murder prosecution when state officials searched his prison cell without a warrant or prior judicial approval and seized legal papers. Trial counsel Natalie Woloshin brought the intrusion to the court’s attention. The Superior Court appointed Collins to present the motion to dismiss.

The court reviewed the seized materials in camera and heard testimony about who ordered, carried out, and participated in the review. The State had created no effective taint team. Investigators and staff encountered attorney-client communications and Robinson’s notes about trial strategy. Officials retained the legal materials until four days before the scheduled murder trial, even after their review found no proof that Robinson or trial counsel had violated the protective order. A paralegal assigned to the homicide unit reviewed privileged material while continuing to work on final trial preparation.

In May 2018, the Superior Court held that the State had violated Robinson’s Sixth Amendment right and caused actual prejudice. It dismissed the indictment. Collins showed the practical harm: the State had learned defense strategy shortly before trial and had failed to isolate the prosecution team from what its investigators and staff discovered.

A Remedy Tailored to the Intrusion

The Delaware Supreme Court preserved the Sixth Amendment finding and the finding of actual prejudice, but reversed dismissal because the remedy had to be tailored to the injury while preserving the public interest in adjudicating the charges.

The court imposed a broad remedy. It disqualified Downs, Denney, Prater, Grubb, Ciritella, Marvel, and Dempsey from Robinson’s trial, together with anyone else exposed to the privileged materials through review or discussion. It also ordered the State to destroy all trial work product developed in the case. A new team would have to proceed without the advantage created by the intrusion.

The case continued after remand. Delaware’s Department of Justice later reported that Robinson pleaded guilty to manslaughter and a firearm offense. The court imposed ten years in prison and two years of probation. That plea resolved the prosecution. Collins litigated the motion and appeal that established the Sixth Amendment violation and forced the State to rebuild its case on clean ground.

Proof, Person by Person

Collins now serves as managing partner of Collins Price Warner Woloshin. His firm describes a Delaware defense practice extending from traffic and DUI matters through misdemeanors, felonies, homicide trials, juvenile cases, pardons, expungements, and appeals. He earned a bachelor’s degree from Cornell University, an M.B.A., and a J.D. cum laude from Widener University School of Law. Across the reported decisions, his arguments focus on the precise burden the State must satisfy in the case before the court.

The record includes a complete acquittal, suppression of unlawfully obtained evidence, an affirmed Sixth Amendment violation, disqualification of officials exposed to privileged material, destruction of tainted work product, and remand. Each result turned on what the State could lawfully prove against the individual defendant.