State v. Stanford, 1511011810

Defendant Shamar T. Stanford pled guilty on December 12, 2016 to Possession of a Firearm by a Person Prohibited (PFBPP) and misdemeanor Endangering the Welfare of a Child and received mandatory and suspended portions of incarceration.
Stanford filed a pro se motion for postconviction relief (Rule 61), amended twice; the Superior Court initially denied relief but the Supreme Court remanded to consider the Second Amended Motion.
The Second Amended Motion raised six claims including ineffective assistance of counsel (based on inexperience and on failing to produce photographs or object to alleged false police statements), a Fourth Amendment challenge, a claim that his plea was coerced (duress), alleged police perjury, and complaints about prior counsel’s withdrawal and speedy-trial waiver.
The Court treated the remaining claims under Rule 61 procedural bars (timeliness, repetitiveness, procedural default, former adjudication) and, where appropriate, applied summary dismissal under Rule 61(d)(5).
The Court dismissed several claims as procedurally barred (speedy-trial/withdrawal, Fourth Amendment challenge, plea-duress, and parts of perjury claim) and summarily dismissed the remaining ineffective-assistance claims for failure to satisfy Strickland prejudice or to plead particularized facts.

Issue	Plaintiff's Argument (Stanford)	Defendant's Argument (State)	Held
Whether counsel’s inexperience rendered assistance ineffective	Trial counsel lacked experience for a "high profile" case and that inexperience prejudiced Stanford	Inexperience alone does not establish ineffective assistance; no specific deficient acts tied to prejudice	Dismissed: inexperience unconnected to specific performance fails Strickland inquiry
Whether prior counsel’s withdrawal and alleged speedy-trial waiver violated rights	Counsel who withdrew allowed waiver of Stanford’s speedy-trial rights without his consent	Claim could have been raised pretrial or on direct appeal; Stanford waived speedy-trial by pleading guilty	Procedurally barred under Rule 61(i)(3); not considered on merits
Whether plea was entered under duress/coercion	Plea was result of an ultimatum and was involuntary	Plea bargaining inherently involves negotiation; plea colloquy showed plea was knowing and voluntary	Formerly adjudicated and barred under Rule 61(i)(4); claim rejected
Whether police perjured themselves and counsel was ineffective for failing to object	Officer made contradictory/misleading statements; counsel failed to challenge affidavit/testimony and withheld photos	Accuracy challenges were waived by guilty plea; ineffective-assistance portion lacks particularized prejudice showing	Perjury/account claims procedurally barred; ineffective-assistance claim summarily dismissed for failure to show prejudice

Strickland v. Washington, 466 U.S. 668 (1984) (two-part test for ineffective assistance: deficient performance and prejudice)
United States v. Cronic, 466 U.S. 648 (1984) (experience alone does not create a presumption of ineffective assistance)
Bordenkircher v. Hayes, 434 U.S. 357 (1978) (plea bargaining does not make a plea involuntary simply because it was the result of negotiation)
Sykes v. State, 147 A.3d 201 (Del. 2015) (discussion of Strickland and Rule 61 procedures)
Bradley v. State, 135 A.3d 748 (Del. 2016) (Rule 61 procedural-bar principles)
Middlebrook v. State, 802 A.2d 268 (Del. 2002) (remedy for speedy-trial violation is dismissal of indictment)