Bradley v. State
135 A.3d 748
| Del. | 2016Background
- Bradley was convicted in 2012 of multiple counts related to rape, assault, and exploitation of children; he received fourteen life sentences plus 164 years.
- Bradley filed a postconviction relief motion; the Superior Court denied his Second Amended Motion on June 5, 2015.
- The prior direct appeal (2012) rejected Bradley’s challenge to the December 2009 BayBees Pediatrics search warrant.
- The December 2009 search warrant sought medical records and digital evidence from BayBees Pediatrics and its outbuildings, including an unnamed white outbuilding.
- Police seized multiple digital devices and memory cards from four BayBees buildings and later opened deleted video files during later searches, leading Bradley to challenge the search's scope and methods.
- Bradley claimed violations of Sixth Amendment right to choose counsel and ineffective assistance of counsel for trial and appellate representation regarding the search-related issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to choice of counsel at postconviction | Bradley argues state action deprived choice of counsel. | State provided ample funding/representation; lien did not deny choice. | No denial of right to counsel; no miscarriage of justice shown. |
| Ineffective assistance for challenging four-corners scope | Trial counsel failed to limit suppression argument to four corners. | Strategic choice allowed broader challenge; no prejudice shown. | No ineffective assistance; strategic decision reasonable; no prejudice. |
| Ineffective assistance on appeal re: outside-warrant evidence | Appellate counsel should have raised the outside-warrant evidence issue on appeal. | Counsel reasonably avoided rearguing a settled approach; no different result likely. | Appellate counsel not ineffective; no reasonable probability of different outcome. |
| Ineffective assistance regarding unguided thumb-drive search | Search of deleted files exceeded warrant's scope and was improperly unguided. | Issue barred by Rule 61(i)(4) as previously adjudicated and refined. | Rule 61(i)(4) bars this claim; no relief. |
Key Cases Cited
- Gonzalez-Lopez, 548 U.S. 140 (2006) (right to choice of counsel; structural vs. non-structural error)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance)
- United States v. Monsanto, 491 U.S. 600 (1989) (assets may be restrained based on probable cause to forfeit)
- Skinner v. State, 607 A.2d 1170 (Del. 1992) (interpretation of procedural governance in posconviction context)
- Bradley v. State, 51 A.3d 423 (Del. 2012) (direct appeal and prior rulings related to Bradley’s case)