State v. Evans-Mayes
1111012229
| Del. Super. Ct. | Aug 25, 2016Background
- Defendant Tyreek Evans-Mayes was indicted (Jan. 30, 2012) on multiple counts including first-degree robbery, PDWDCF, WDDCF, and conspiracy; tried and convicted on several counts on Oct. 7, 2013.
- Sentenced to 38 years, suspended after 16 years with decreasing probation; convictions and sentence affirmed by the Delaware Supreme Court (Sept. 11, 2014).
- Evans-Mayes filed a first Motion for Postconviction Relief (Sept. 10, 2015) alleging ineffective assistance of counsel and raising claims labeled "Prosecutorial Misconduct" and "Due Process."
- Conflict Counsel (Eaton) reviewed the case, filed to withdraw after finding no meritorious grounds; Evans-Mayes sought new counsel and sentence reduction (treated and denied as a Rule 35 motion).
- The Superior Court applied Rule 61(i) procedural bars: found prosecutorial-misconduct and due-process claims procedurally defaulted; found the ineffective-assistance claim timely and not barred.
- Court evaluated ineffective-assistance claim (Strickland standard) broken into three subclaims (lawyer’s alleged name-calling/threats; failure to subpoena an alibi witness; failure to move for judgment of acquittal) and denied relief on the merits.
Issues
| Issue | Evans-Mayes' Argument | State/Defense Argument | Held |
|---|---|---|---|
| Ineffective assistance — counsel’s abusive remarks and threats | Heyden called Evans-Mayes and alibi witnesses liars and threatened long imprisonment to force a plea | Even if true, Evans-Mayes rejected the plea and proceeded to trial, so no prejudice | Denied — no prejudice because defendant went to trial |
| Ineffective assistance — failure to subpoena an alibi witness | Heyden failed to subpoena a favorable alibi witness | Heyden investigated witnesses; the un-subpoenaed witness gave an adverse statement; defendant failed to identify witness or testimony with particularity | Denied — claim lacks particularity and fails both Strickland prongs |
| Ineffective assistance — failure to move for judgment of acquittal | Heyden did not file a motion for judgment of acquittal as requested | Appellate sufficiency review applied same standard; a motion would have failed, so no prejudice | Denied — no prejudice because motion would have been unsuccessful |
| Procedural default of prosecutorial-misconduct and due-process claims | Evans-Mayes raised prosecutorial-misconduct and a conflict/due-process claim now | Claims were not raised at trial or on direct appeal and movant showed no cause or prejudice; not within Rule 61(i)(5) exceptions | Denied as procedurally barred under Rule 61(i) |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong ineffective assistance standard: deficient performance and prejudice)
- Ploof v. State, 75 A.3d 811 (Del. 2013) (applies Strickland framework in Delaware postconviction context)
- Wright v. State, 671 A.2d 1353 (Del. 1996) (mere allegations insufficient; specificity and prejudice required for ineffective-assistance claims)
- Younger v. State, 580 A.2d 552 (Del. 1990) (addresses procedural bars and finality principles in postconviction context)