Heck v. State

── Heck v. State ── Court: Supreme Court of Delaware Date: April 17, 2026 Category: General IN THE SUPREME COURT OF THE STATE OF DELAWARE STEPHEN HECK, § § No. 79, 2025 Defendant Below, Appellant, § § Court Below–the Superior v. § Court of the State of Delaware § STATE OF DELAWARE, § Cr. ID No. N2310001233 § Appellee. § § Submitted: January 21, 2026 Decided: April 17, 2026 Before SEITZ, Chief Justice; VALIHURA, TRAYNOR, LEGROW, and GRIFFITHS, Justices, constituting the Court en banc. ORDER After careful consideration of the parties’ briefs and the record on appeal, and following oral argument, it appears to the Court that: (1) In this appeal, Stephen Heck challenges his criminal conviction for the murder of his girlfriend, Cynthia Amalfitano. For the reasons stated below, we affirm. BACKGROUND (2) Heck and Amalfitano began dating in 2020, just before the pandemic.1 On Saturday, September 23, 2023, the pair planned to travel to Amalfitano’s Rehoboth 1 App. to Opening Br. at A355 [hereinafter “A__”] (Trial Tr. 76:20–22) (Sandra Saienni) [hereinafter “Tr.”]. Beach condominium for a weekend getaway.2 Before leaving for the beach, Amalfitano had texted Heck, “okay sweetie see you in a bit.”3 (3) Amalfitano did not report to work on the following Monday. Amalfitano’s boss contacted her family to check on her because she had not requested the day off.4 Her sister, Sandra Saienni, tried calling Amalfitano and Heck, but neither answered their cell phones.5 Heck eventually called back but hung up without saying a word.6 (4) Amalfitano’s sister-in-law, Donna Galliani, went to Amalfitano’s New Castle County residence to look for her.7 Galliani went to the rear of Amalfitano’s home and knocked on the back door, but no one answered.8 Galliani found this odd because Amalfitano’s Jeep was sitting in the parking lot.9 Galliani tried to open the back door, found it unlocked, and walked inside.10 Galliani found no sign of Amalfitano.11 She discovered Amalfitano’s two dogs unattended, which was strange 2 A359–60 (Tr. 80:20–81:14) (Sandra Saienni). 3 A83 (Aff. in Support of an Application for Warrant ¶ 25) [hereinafter “Aff.”]. 4 A315–16 (Tr. 36:15–37:7) (Lori Bigalow). 5 A360–61 (Tr. 81:19–82:7) (Sandra Saienni). 6 Id. 7 A402 (Tr. 123:3–11) (Donna Galliani). 8 A402 (Tr. 123:18–19) (Donna Galliani). 9 A402–03 (Tr. 123:12–124:13) (Donna Galliani). 10 A402 (Tr. 124:1–3) (Donna Galliani). 11 A403 (Tr. 123:3–11) (Donna Galliani). 2 because one of the dogs never left Amalfitano’s side.12 Galliani also found Amalfitano’s luggage lying on the coffee table.13 Galliani went back outside to dial 911, but before she could dial, she spotted a New Castle County Police Department (“NCCPD”) vehicle passing by. She flagged it down.14 The police searched Amalfitano’s residence; they too found no sign of Amalfitano.15 But they did find a black purse containing Amalfitano’s wallet and cell phone.16 NCCPD initiated a missing-persons investigation.17 (5) After calling Heck’s cell phone several times with no answer, NCCPD went to his house.18 Upon arrival, the police saw Heck walking toward his car, a grey Subaru.19 As they approached him, the police noticed that he was shaking, his forearms were covered with scratch marks, and he had some additional