Robinson v. State, 152, 2016

In 2010 Robinson was tried for the shooting death of Cameron Johnson and the wounding of Jarren Glandton; jury convicted him of first‑degree murder and one weapons count and acquitted on other counts; sentence was life plus 8 years; conviction was affirmed on direct appeal.
During the 2013 trial the prosecutor received mid‑trial information that eye‑witness Glandton had expressed uncertainty about the shooter in communications with Keisha Henry; the prosecutor immediately disclosed that information to defense and the court.
Also during trial Officer Monet Cummings testified that Glandton initially told police he did not know who shot him; that initial remark did not appear in police reports and was disclosed late.
Robinson filed a Rule 61 postconviction motion alleging Brady violations for the State’s failure/delay in disclosing those statements, and ineffective assistance for counsel’s failure to move for a mistrial; the Superior Court Commissioner found a Brady violation but no prejudice and denied relief; the Superior Court adopted the Commissioner’s findings.
The Supreme Court reviewed the Rule 61 denial (questions of Brady and ineffective assistance reviewed de novo) and affirmed: it held the delayed disclosure did not preclude effective use at trial, counsel reasonably used the information and chose strategy, cumulative error did not warrant relief, and no evidentiary hearing was required.

Issue	Robinson's Argument	State's Argument	Held
Brady disclosure of Glandton’s statements to Henry and Cummings	State suppressed favorable/impeaching statements; late disclosure prejudiced trial	Statement to Henry was disclosed when learned; Cummings’ initial remark was used effectively by counsel; no prejudice	Only Cummings’ initial statement arguably Brady; disclosure was delayed but defense used it effectively; no reversible Brady prejudice
Ineffective assistance for not moving for mistrial	Counsel unreasonably failed to move for mistrial after Brady violations, causing prejudice	Counsel’s decision was strategic; he effectively cross‑examined and used the material so no prejudice	Counsel’s choice was reasonable strategy; Robinson failed to show prejudice under Strickland
Cumulative due process error	Combined Brady violations and counsel’s failures require new trial	Individual claims lack merit or prejudice, so cumulative error fails	No cumulative error; claim denied
Denial of evidentiary hearing under Rule 61(h)	Commissioner’s summary disposition omitted needed fact‑finding	Record (affidavits, trial transcript) sufficed for decision; hearing discretionary	No abuse of discretion; court permissibly declined an evidentiary hearing

Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution must disclose material exculpatory or impeaching evidence)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑part ineffective assistance standard: deficient performance and prejudice)
White v. State, 816 A.2d 776 (Del. 2003) (late disclosure of Brady material requires inquiry whether delayed disclosure precluded effective use at trial)
Starling v. State, 130 A.3d 316 (Del. 2015) (Brady claims and standard of review for postconviction relief)