Parris Hamilton v. State of State
124, 2016
| Del. | Jun 28, 2017Background
- In June 2012 a Superior Court jury convicted Parris Hamilton of multiple crimes arising from a shooting that killed one victim and injured two others; Hamilton received four life sentences plus additional years.
- Hamilton’s direct appeal was affirmed by this Court in 2013. He argued, among other things, that curative instructions were adequate and burglary was proven.
- Hamilton filed a Rule 61 postconviction motion in October 2014 raising many claims, including ineffective assistance of counsel (IAC) for failing to suppress physical evidence based on alleged misconduct at the Office of the Chief Medical Examiner (OCME).
- Postconviction counsel was appointed, later moved to withdraw, and the Superior Court denied relief in March 2016, finding most claims procedurally barred or without merit.
- On appeal Hamilton only pursues the IAC claim that trial/appellate counsel should have moved to suppress physical evidence or raised OCME misconduct on direct appeal. The Court reviews the denial for abuse of discretion and legal questions de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| IAC — OCME drug-evidence misconduct | Hamilton: counsel ineffective for not suppressing evidence or raising OCME drug-evidence misconduct discovered in 2014 | State: misconduct revealed in 2014 did not exist at trial; no link to Hamilton’s case or prejudice | Denied — no counsel deficiency or reasonable probability of different outcome because misconduct postdated trial and no causal connection shown |
| IAC — excluded blood sample (seal issue) | Hamilton: counsel ineffective for not moving to suppress all physical evidence based on court’s exclusion of his blood sample | State: claim not raised below; cannot be considered first on appeal; exclusion of blood sample would not require exclusion of other physical evidence | Not considered on appeal (procedurally barred); even if considered, fails to show how exclusion of one sample would alter outcome |
| Procedural default/waiver of other Rule 61 claims | Hamilton: originally raised many grounds in Rule 61; on appeal he relies on OCME claim | State: appellate waiver — Hamilton abandoned other claims by not raising them here | Held that all other claims are waived on appeal; only OCME claim reviewed |
| Standard for IAC and prejudice | Hamilton: alleges counsel errors would have changed result | State: strong presumption of reasonable representation; must show concrete prejudice under Strickland | Applied Strickland standard; Court requires objective unreasonableness and reasonable probability of different outcome and found Hamilton did not meet burden |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-part test for ineffective assistance of counsel)
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecutor’s duty to disclose exculpatory evidence)
- Dawson v. State, 673 A.2d 1186 (Del. 1996) (prejudice requirement for IAC claims)
- Younger v. State, 580 A.2d 552 (Del. 1990) (procedural requirements for postconviction review)
- Murphy v. State, 632 A.2d 1150 (Del. 1993) (appellate waiver principles)
- Hamilton v. State, 82 A.3d 723 (Del. 2013) (direct-appeal decision affirming trial convictions)