The Implied Willfulness Requirement for Disregarding a Police Officer’s Signal

Introduction

In Waller v. State, 285 A.2d 805 (Del. 2025), the Supreme Court of Delaware addressed the mens rea element required under 21 Del. C. § 4103(b) for the offense of disregarding a police officer’s signal. Appellant Zaire Waller challenged his conviction on the ground that the trial court’s jury instructions were legally incorrect and confusing because they used the term “willful” without further definition. This commentary examines the background facts, the parties’ arguments, and the Court’s resolution of the implied mental-state requirement, establishing a clear precedent that “willfulness” is the proper mens rea for § 4103(b) offenses and that undefined statutory terms may be left to the jury’s common-sense understanding.

Summary of the Judgment

Trooper Barry observed Waller commit minor traffic infractions, activated his emergency lights, and signaled Waller to pull over. Waller instead accelerated, weaved through intersections, ran two red lights, and struck a traffic sign. He was indicted on one count of disregarding a police officer’s signal (Count One, § 4103(b)) and two counts of disregarding a red light (§ 4108(a)(3)). At trial, Waller objected to the jury instruction for Count One, arguing the statute required a default mens rea (“intentionally, knowingly or recklessly”) under 11 Del. C. § 251(b). The Superior Court, following Edwards v. State, held that § 4103(b) implies a “willfulness” element and instructed the jury accordingly, without supplying a dictionary definition. The jury convicted Waller on all counts. On appeal, the Supreme Court of Delaware affirmed, finding no abuse of discretion in adopting “willful disregard” as the mens rea and declining to define the term further.

Analysis

Precedents Cited

The foundation for the Court’s ruling was Edwards v. State, 285 A.2d 805 (Del. 1971), which first construed § 4103(b) and held that the statutory language “operates in disregard of the signal” implies an element of willfulness. In Edwards, the Court explained that “to leave out the ‘required mental state’ could result in jury confusion.” Although Edwards arose in a different factual context, its statutory interpretation principle applies directly to Waller’s case. The Court also referenced general rules of statutory construction:

11 Del. C. § 251(b), which supplies a default mens rea (“intentionally, knowingly, or recklessly”) only when no state of mind is prescribed by law.
1 Del. C. § 303, mandating that undefined words in the Delaware Code be construed according to “common and approved usage of the English language.”

Legal Reasoning

The Supreme Court applied an abuse of discretion standard to the jury‐instruction issue because Waller did not seek a novel defense theory but only a different form of instruction. The Court held that:

Section 4103(b) does not explicitly state a mental state but, under Edwards, implies “willfulness” – a standard that encompasses deliberate or intentional conduct.
The trial court correctly instructed the jury that they must find the defendant “willfully operated the vehicle in disregard of the signal.”
The refusal to provide a dictionary definition for “willful” was not an error. The term is commonly used in Delaware’s traffic statutes and may be interpreted by the jury according to its ordinary meaning.

The Court emphasized that jury instructions “‘reasonably inform and not mislead’” when read as a whole. Here, the instructions accurately stated the law and guided the jury to apply their everyday understanding of “willful disregard.”

Impact

This decision clarifies several important points for Delaware criminal practice:

Implied Mens Rea: Where a statute is silent on mental state but requires a defendant to act “in disregard,” courts will imply “willfulness” rather than automatically supplying a default statutory mens rea.
Jury Instructions: Trial courts have discretion to use statutory or established precedent terminology for mens rea and need not supply dictionary definitions for common legal terms.
Statutory Construction: The ruling reaffirms that undefined code terms can be given their common‐sense meaning, reducing the risk of over‐complicating jury charges with separate definitions.

Future litigants will cite Waller v. State when challenging or defending jury instructions on implied mental‐state elements in Delaware traffic and criminal statutes.

Complex Concepts Simplified

Mens Rea: Latin for “guilty mind,” it refers to the mental state a defendant must have when committing an offense. In this case, “willful” means the driver intentionally chose to ignore the officer’s signal, not that he acted by accident or negligence.

Abuse of Discretion: A deferential appellate standard where the reviewing court upholds a trial judge’s ruling unless it is arbitrary or irrational. Because the trial court’s instruction followed binding precedent and common usage, no abuse occurred.

Conclusion

Waller v. State establishes that the crime of disregarding a police officer’s signal under 21 Del. C. § 4103(b) carries an implied mens rea of “willfulness,” drawing on the precedent of Edwards. The Supreme Court of Delaware affirmed that trial courts may rely on commonly understood legal terms without providing dictionary definitions, so long as the instructions accurately state the law and guide the jury’s understanding. This decision will shape how Delaware courts instruct juries on silent‐mens‐rea statutes and underscores the judiciary’s preference for statutory clarity grounded in precedent and ordinary language.