Cleveland A. Baldwin v. State of Delaware
166 A.3d 938
Del.2017Background
- Cleveland Baldwin was convicted by a Superior Court jury of first-degree assault, possession of a deadly weapon during a felony, carrying a concealed deadly weapon, and second-degree conspiracy; convictions affirmed on direct appeal.
- At trial the State’s case relied primarily on the victim’s testimonial identification; the defense was alibi (Baldwin and his aunt testified he was not present) and pointed to inconsistencies in the victim’s statements; no forensic evidence linked Baldwin to the pipe alleged to be the weapon.
- Baldwin, proceeding pro se, filed a timely first Rule 61 postconviction petition alleging three ineffective-assistance-of-counsel claims and one claim challenging trial testimony; he did not contemporaneously request appointed counsel on the form.
- The Superior Court summarily dismissed the petition under Rule 61(d)(5), addressing procedural bars and the merits in a written order; Baldwin appealed the summary dismissal.
- This Court affirmed most of the Superior Court’s rulings (procedural bars and two Strickland claims) but reversed as to one claim: counsel’s alleged failure to obtain fingerprint/DNA testing of the pipe and to present an expert that testing would have been negative.
- The Supreme Court held that the summary dismissal was improper as to that specific testing claim because the record did not permit a reliable determination that the claim lacked colorable merit; remanded for appointment of counsel and further proceedings on that claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the petition was procedurally barred under Rule 61(i) for failing to raise claim earlier | Baldwin argued prosecutor’s leading questions and related trial error warranted relief | State argued Baldwin failed to raise claim on direct appeal and Rule 61(i)(3) bars it | Held: Barred by Rule 61(i)(3); dismissal affirmed |
| Whether counsel was ineffective for failing to challenge confrontation by not calling victim’s boss and for failing to challenge sufficiency | Baldwin contended counsel failed both at trial and on appeal | State defended counsel’s performance as reasonable; Superior Court found no Strickland deficiency | Held: Dismissal affirmed; Superior Court’s analysis sustained |
| Whether counsel was ineffective for failing to obtain fingerprint/DNA testing of the pipe and present expert showing no Baldwin prints/DNA | Baldwin alleged counsel promised testing and that negative results would have been exculpatory and affected the verdict | State argued Baldwin cannot show results would be exculpatory and absence of prints/DNA would not justify suppression; summary dismissal appropriate | Held: Superior Court erred to summarily dismiss; reversed as to this claim and remanded for appointment of counsel and further development |
| Whether absence of forensic link would render the pipe inadmissible | Baldwin implied negative testing could bolster alibi/credibility | State argued lack of prints/DNA does not legally bar admission if foundation exists | Held: Court agreed with State that absence of prints/DNA would not by itself render evidence inadmissible; but sufficiency for summary dismissal on merits was lacking |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong standard for ineffective assistance of counsel claims)
- State v. Reyes, 155 A.3d 331 (Del. 2017) (standard of review for Rule 61 decisions and summary dismissals)
- Baldwin v. State, 129 A.3d 231 (Del. 2015) (affirming Baldwin’s convictions on direct appeal)