State v. Miller
1001009884 1009013840 1111020024 1204003514
| Del. Super. Ct. | May 11, 2017Background
- In 2010–2013 eight defendants were arrested/convicted on drug-related charges; convictions resulted from guilty pleas, stipulated bench trials, or jury trial. OCME performed drug testing in many cases.
- In 2014 investigations revealed misconduct at the OCME involving missing/stolen narcotics and other laboratory problems; this spawned broad postconviction filings by defense counsel (ODS).
- Defendants filed Rule 61 postconviction motions asserting (1) Brady nondisclosure of impeachment/Brady material about OCME misconduct, (2) that guilty pleas were involuntary because of government misconduct or misrepresentations, and (3) estoppel based on the State’s conduct in unrelated OCME-implicated cases.
- The State and the court emphasized that most defendants either admitted possession or stipulated to OCME reports at trial/plea, and that the OCME wrongdoing was publicly revealed only in 2014.
- Court applied Rule 61 procedural rules (including amended June 4, 2014 version where applicable), found most claims procedurally barred, and rejected substantive Brady/voluntariness/estoppel arguments for the rest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady nondisclosure re: OCME misconduct | OCME misconduct was material impeachment/exculpatory evidence; nondisclosure prejudiced trials/pleas and undermines convictions | State: OCME problems did not exist or were not known at time of most cases; many defendants admitted guilt or stipulated to reports; no evidence OCME falsified results | Court: Brady fails — disclosure obligation not triggered retroactively; where defendants admitted guilt or stipulated, impeachment evidence would not have changed outcome; no showing of material prejudice |
| Voluntariness of guilty pleas (Brady v. United States) | Pleas were involuntary because induced by State misrepresentations (failure to disclose OCME issues) or by egregious government misconduct | State: No coercion or misrepresentation shown; pleas were knowing, intelligent, and voluntary; impeachment disclosures are not required before plea | Court: Pleas voluntary; Delaware precedent forecloses vacating knowing, voluntary pleas absent allegations of factual innocence or coercion; OCME scandal alone is insufficient |
| Estoppel based on State’s conduct in other OCME cases (e.g., allowing plea withdrawal) | State should be estopped from arguing pleas were voluntary because it sought relief in other, unrelated cases (e.g., allowed plea withdrawal in Young) | State: Prior positions were in different cases; judicial estoppel rarely applies against government; doctrine limited to inconsistent positions in same defendant’s proceedings | Held: Judicial estoppel inapplicable — prior actions in other cases do not bind State here |
| Procedural bars under Rule 61 (timeliness, successive/repetitive, default, Rule 61(i)(5) exceptions) | Movants invoke OCME revelations as newly discovered Brady material to overcome time/default bars | State: Many motions untimely or successive; amended Rule 61 narrows exceptions; defendants did not plead actual innocence or particularized miscarriage of justice | Court: Most motions procedurally barred; where Rule 61(i)(5) applies, defendants failed to plead particularized new-evidence showing or actual innocence; motions denied |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor must disclose material favorable evidence)
- Brady v. United States, 397 U.S. 742 (1970) (standards for voluntariness of guilty pleas)
- Ruiz v. United States, 536 U.S. 622 (2002) (no constitutional right to receive impeachment evidence before plea)
- Aricidiacono v. State, 125 A.3d 677 (Del. 2015) (Delaware precedent rejecting OCME-based plea-relief where plea was knowing and no claim of innocence)
- Brown v. State, 108 A.3d 1201 (Del. 2015) (same principle: no constitutional right to impeachment evidence pre-plea; context of OCME)
- Cannon v. State, 127 A.3d 1164 (Del. 2015) (Brady material must create reasonable probability of a different result; OCME scandal did not show falsified tests)
- Burton v. State, 142 A.3d 504 (Del. 2016) (judicial estoppel not applied based on positions in other cases)
- United States v. Bagley, 473 U.S. 667 (1985) (definition of "reasonable probability" for Brady prejudice)
- Kyles v. Whitley, 514 U.S. 419 (1995) (materiality standard and cumulative-effect approach for Brady)
- Ferrara v. United States, 456 F.3d 278 (1st Cir. 2006) (First Circuit test on plea involuntariness from egregious misconduct; discussed but not adopted)