Chambers v. Emig
N25M-04-068
Del. Super. Ct.Apr 14, 2025Background
- Michael D. Chambers was convicted in 2006 of several drug and firearm-related offenses and sentenced as a habitual offender to 25 years in prison.
- Chambers’ conviction and sentence were affirmed by the Delaware Supreme Court.
- Since his conviction, Chambers has repeatedly filed unsuccessful motions for postconviction relief, sentence modifications, and state habeas petitions.
- In April 2025, Chambers filed a new state habeas petition, arguing that recent Supreme Court precedent (Erlinger v. United States) renders his habitual offender sentence unconstitutional.
- Chambers sought his immediate release, or at least expedited review of his pending motions, through this habeas petition.
- The state opposed, arguing Chambers has not met the requirements for habeas corpus relief under Delaware law.
Issues
| Issue | Chambers' Argument | State’s Argument | Held |
|---|---|---|---|
| Whether Chambers is entitled to state habeas corpus relief based on alleged constitutional infirmity in his sentence | Sentence is void due to Erlinger; habeas is appropriate to seek review and/or release | Habeas unavailable for facially regular convictions; other remedies exist | Petition denied; regular facial commitment precludes habeas relief |
| Scope of habeas corpus in postconviction context | Habeas can be used to challenge sentence’s legality when there are constitutional issues | Habeas only reviews jurisdiction/regularity, not legal soundness of conviction | Habeas not a means to review conviction legality |
| Use of habeas as means to expedite review or secure release pending other motions | Entitled to habeas or release while postconviction motions are pending | Habeas not available to hasten/postpone criminal motions | Not permitted; must pursue available postconviction remedies |
| Sufficiency of commitment documentation | Commitment facially irregular due to unconstitutional enhancement provisions | Commitment is facially regular and court had proper jurisdiction | Court found commitment regular; Chambers not entitled to relief |
Key Cases Cited
- Hall v. Carr, 692 A.2d 888 (Del. 1997) (explaining the limited scope of habeas corpus in Delaware and its application to review only the court's jurisdiction).
- Jones v. Anderson, 183 A.2d 177 (Del. 1962) (prisoner cannot obtain habeas relief if commitment is regular on its face).
- Curran v. Woolley, 104 A.2d 771 (Del. 1954) (habeas corpus unavailable to contest errors in conviction or sentence if judgment is valid on its face).