Aricidiacono v. State
125 A.3d 677
| Del. | 2015Background
- Consolidated appeals ask whether guilty pleas to illegal narcotics offenses remain valid despite OCME drug-evidence handling problems.
- 2014 investigation revealed OCME employees stole drug evidence due to lax oversight and security; no evidence of “evidence planting.”
- Defendants contend ignorance of OCME problems could have affected plea bargaining and argue Brady-style involuntariness; they did not allege coercion or false admissions.
- Superior Court upheld the convictions and declined to vacate pleas; reasoning grounded in lack of evidence that OCME misconduct coerced or affected factual guilt.
- Delaware Supreme Court affirms, applying Ira Brown, Anzara Brown, and Brewer to reject pleas’ vacatur; no equitable basis to undermine voluntary pleas; affirms December 3, 2014 judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether OCME problems invalidate voluntary pleas | Defendants rely on OCME issues to claim involuntary pleas | State argues no coercion or false admissions; pleas valid | No; pleas upheld despite OCME problems |
| Whether Brady involuntariness applies | Defendants claim Brady-based involuntariness | State contends lack of coercion or impact on guilt | No; Brady claim rejected |
| Whether relief should vacate pleas or sentences | Defendants seek vacatur to address OCME misconduct | State argues no unfairness in light of admissions and plea benefits | No; no basis to vacate pleas or sentences |
| Whether government misconduct affected guilt or process | Defendants assert OCME issues tainted process | State contends no evidence of planted drugs or coerced pleas | No; misconduct did not undermine voluntary pleas |
Key Cases Cited
- Ira Brown v. State, 108 A.3d 1201 (Del. 2015) (no relief for pleas unless misconduct affected conviction)
- Anzara Brown v. State, 117 A.3d 568 (Del. 2015) (OCME misconduct not proven to have tainted pleas)