State v. Bradley, 2204007572

Bradley was indicted on ten charges stemming from an April 14, 2022 shooting after police pursued a fleeing Honda Pilot and found him hiding nearby with clothing matching the suspect. 1
Police recovered a black sweatshirt, New Balance sneakers, and a Taurus 9mm handgun along the suspect’s flight path, and Bradley was a person prohibited because of a prior felony drug conviction. 2
Bradley later pled guilty to possession of a firearm by a person prohibited and possession of a firearm during the commission of a felony, and the State dismissed the remaining charges. 3
The plea agreement called for the minimum mandatory sentence, and the court sentenced Bradley to fifteen years at Level V. 4
Bradley filed a timely first Rule 61 motion alleging ineffective assistance of counsel, and postconviction counsel moved to withdraw after finding the claims unsupported. 5
The court applied Strickland and the plea-colloquy rule that defendants are bound by their sworn statements absent clear and convincing contrary evidence. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Bradley’s Rule 61 motion procedurally barred? 7	Bradley’s ineffective-assistance claims should be heard.	The State argued Rule 61 bars the motion.	No bar applied; the motion was timely, first, and unadjudicated. 8
Did counsel fail to investigate and prepare? 9	Bradley claimed counsel did not investigate his case.	The State argued Bradley’s plea colloquy refuted the claim.	No; Bradley was bound by his statement that counsel did everything possible. 10
Did counsel give inadequate advice causing an unwise plea? 11	Bradley claimed bad advice led to a questionable plea.	The State argued the evidence and exposure made the plea sensible.	No; the plea was favorable and colloquy showed informed advice. 12
Was Bradley coerced into pleading guilty? 13	Bradley claimed he was pressured to accept the plea.	The State argued the record showed a voluntary plea.	No; the record showed no coercion and Bradley swore the plea was voluntary. 14
Did counsel’s personal belief in guilt show ineffective assistance? 15	Bradley claimed counsel was biased because they believed he was guilty.	The State argued the plea colloquy contradicted any bias claim.	No; Bradley produced no evidence and was bound by his colloquy statements. 16

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (sets the two-prong ineffective-assistance standard 17)
Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (applies Strickland to guilty-plea challenges 18)
Somerville v. State, 703 A.2d 629 (Del. 1997) (guilty-plea ineffective-assistance standard 19)
Albury v. State, 551 A.2d 53 (Del. 1988) (defendant must show plea would have gone to trial but for counsel’s errors 20)
Neal v. State, 80 A.3d 935 (Del. 2013) (explains deficient performance and prejudice under Strickland 21)
Ploof v. State, 75 A.3d 811 (Del. 2013) (no need to reach deficient performance if no prejudice is shown 22)
Miller v. State, 840 A.2d 1229 (Del. 2003) (a voluntary guilty plea waives prior defects and errors 23)
Young v. State, 580 A.2d 552 (Del. 1990) (procedural bars govern Rule 61 review 24)