State v. Watts, 1503015027

Defendant Jason Dale Watts pled guilty on September 23, 2015 to Assault in a Detention Facility and was sentenced to six years at Level Five. No direct appeal was filed; conviction became final October 23, 2015.
On August 29, 2016 Watts filed a first Motion for Postconviction Relief under Superior Court Criminal Rule 61 raising three claims: (1) his guilty plea was coerced; (2) he was not mentally stable at the time of the offense because he was not properly medicated at the Violation of Probation Center; and (3) he was high during the offense.
The court applied Rule 61(i) to assess procedural bars and whether the claims were subject to cause-and-prejudice standards for defaulted claims.
The court found the mental-state claims (improper medication, intoxication) procedurally defaulted under Rule 61(i)(3) because Watts failed to show cause (an external impediment) and prejudice (a substantial likelihood the outcome would differ).
The coerced-plea claim was treated as an ineffective-assistance-of-counsel claim governed by Strickland; the plea colloquy showed Watts knowingly, voluntarily, and intelligently entered the plea and expressed satisfaction with counsel, so the claim failed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural bar under Rule 61(i)(3) for mental-state claims	State: Watts did not raise these claims earlier and thus they are barred absent cause and prejudice	Watts: He was not properly medicated and/or was high during the offense, affecting culpability and plea validity	Court: Claims procedurally barred; Watts failed to show cause or prejudice
Ineffective assistance of counsel (coerced plea)	State: Counsel’s performance was reasonable; plea colloquy shows voluntariness	Watts: Plea was coerced by threats of extended prison time and intimidation, amounting to ineffective assistance	Court: Claim fails Strickland; counsel’s conduct reasonable and no prejudice shown
Validity of plea colloquy testimony	State: The plea colloquy is binding absent clear, convincing contrary evidence	Watts: Argues coercion/mental impairment undermined colloquy	Court: Colloquy shows waiver was knowing, intelligent, voluntary; Watts is bound by his statements
Entitlement to Rule 61 relief	Watts seeks reopening/relief from conviction	Court: Relief denied in full	Court: Motion for Postconviction Relief dismissed

Strickland v. Washington, 466 U.S. 668 (1984) (establishes two‑part ineffective assistance of counsel test: performance and prejudice)
Somerville v. State, 703 A.2d 629 (Del. 1997) (applies Strickland in guilty‑plea context and discusses presumption of counsel reasonableness)
Flamer v. State, 585 A.2d 736 (Del. 1990) (defines prejudice standard for cause-and-prejudice showing in postconviction proceedings)
Blackwell v. State, 736 A.2d 971 (Del. 1999) (addresses procedural default and requirements to overcome it)
Younger v. State, 580 A.2d 552 (Del. 1990) (discusses external impediment standard for cause)