Sartin v. State, 103 A.3d 515

Sartin was indicted in 2011 for multiple felonies from burglaries and robberies in Kent and New Castle counties and pleaded guilty in Kent County Superior Court to Robbery in the First Degree, two Robbery in the Second Degree, and Burglary in the Second Degree.
The Truth-In-Sentencing Guilty Plea Form and plea colloquy reflected Sartin as a habitual offender under 11 Del. C. § 4214(a) with a joint recommendation of 21 years of Level V incarceration.
Sartin was sentenced on August 18, 2011: 25 years for Robbery in the First Degree, eight years for Burglary in the Second Degree, and five years for each Robbery in the Second Degree count; the sentence was partially suspended.
On August 10, 2012, Sartin filed a postconviction relief motion claiming ineffective assistance of counsel and diminished capacity; the motion was referred to a Commissioner who permitted briefing and affidavits.
The Commissioner issued a Report and Recommendation unfavorable to Sartin; the Superior Court conducted de novo review and denied the motion.
Sartin sought transcript/review of appointment of counsel; the court denied these requests and this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 61 motion was properly denied as procedurally barred	Sartin asserts denial as an abuse of discretion and barred by Rule 61(i)(3).	State contends the postconviction claims were properly analyzed and barred under Rule 61.	Denied; no abuse of discretion.
Whether Sartin received ineffective assistance of counsel	Sartin claims counsel failed to investigate mental health, failed to communicate, and failed to recognize medications affected plea.	State argues no deficient performance or prejudice; counsel acted reasonably and records show safeguards.	No merit; ineffectiveness claims rejected.
Whether diminished capacity rendered the plea involuntary	Sartin contends mental illness/diminished capacity affected voluntariness of the plea.	State notes evidence of prior treatment and lithium use showing competency; the plea was voluntary.	Not involuntary; plea valid.
Whether Sartin was entitled to a transcript and counsel for first postconviction motion	Sartin sought transcript and counsel; argues entitlement under Rule 61.	State provided transcript; no sua sponte appointment of counsel shown under applicable Rule 61 at the time.	Transcript issue moot; no entitlement to sua sponte counsel.

Dawson v. State, 673 A.2d 1186 (Del. 1996) (standard for ineffective assistance claims and procedural bar)
Zebroski v. State, 12 A.3d 1115 (Del. 2010) (de novo review for constitutional claims)
Hill v. Lockhart, 474 U.S. 52 (1985) (ineffective assistance standard for guilty pleas)
Allbury v. State, 551 A.2d 53 (Del. 1988) (standard for voluntariness of guilty plea)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance)
Somerville v. State, 703 A.2d 629 (Del. 1997) (prejudice framework for postconviction review)