State v. Wright
131 A.3d 310
| Del. | 2016Background
- In 1992 Jermaine Wright was convicted of first‑degree murder and related offenses for the Hi‑Way Inn robbery/murder; his recorded confession was admitted at trial after pretrial suppression hearings.
- At the 1991 suppression hearing the trial judge found Wright (who had been using heroin) had sufficient capacity and that his Miranda waiver was knowing, voluntary, and intelligent; that finding was reaffirmed in later postconviction proceedings.
- Decades later, after several postconviction proceedings and a 2014 reversal and remand on Brady grounds, a successor Superior Court judge held a new evidentiary hearing and concluded the Miranda warnings (as recited on videotape) were inadequate and suppressed Wright’s confession.
- The State appealed under 10 Del. C. § 9902(b). The Superior Court judge who suppressed the statement had expressed significant skepticism about the State’s evidence on the record.
- The Delaware Supreme Court held the original 1991 ruling that Wright knowingly and voluntarily waived Miranda created the law of the case, so the successor judge erred in re‑examining the adequacy of warnings; it reversed the suppression and directed reassignment to a different judge for further proceedings.
Issues
| Issue | Plaintiff's Argument (Wright) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether the adequacy of the Miranda warnings may be reconsidered at retrial | The adequacy of the warnings was never specifically decided; new inconsistencies from 2009 testimony justify reconsideration | Prior rulings (1991 suppression, 1992 postconviction) established waiver; law of the case bars reexamination | Law of the case applies; original implied finding that warnings were adequate controls — reconsideration barred |
| Whether testimony from detectives nearly 20 years later amounts to changed circumstances excusing law‑of‑the‑case bar | Inconsistent later testimony shows warnings were defective and that new facts exist | Memories fading is not a material changed circumstance; earlier proceedings considered the same facts | Inconsistent or faded memory testimony does not constitute the necessary changed circumstances or new evidence to overcome law of the case |
| Whether original rulings were clearly wrong or produced manifest injustice | The severity of the penalty (death) and the alleged deficiency in warnings justify reopening | Multiple opportunities to litigate; no clear error in prior findings that waiver was knowing and voluntary | No clear error or manifest injustice shown; exceptions to law of the case do not apply |
| Whether the case should be reassigned after reversal | (implied) Wright did not contest reassignment request | Trial judge’s on‑record statements show lack of confidence in State’s evidence; reassignment necessary to preserve public confidence | Court directed President Judge to assign the case to a different judge |
Key Cases Cited
- Wright v. State, 633 A.2d 329 (Del. 1993) (direct appeal affirming convictions and discussing suppression issues)
- Wright v. State, 67 A.3d 319 (Del. 2013) (Delaware Supreme Court ruling that reconsideration of Miranda adequacy in fourth postconviction motion was barred by Rule 61(i)(4))
- Wright v. State, 91 A.3d 972 (Del. 2014) (Delaware Supreme Court finding cumulative Brady violations required reversal and remand for new trial)
- Cede & Co. v. Technicolor, Inc., 884 A.2d 26 (Del. 2005) (explaining law of the case: earlier legal rulings control later stages absent changed facts)
- Nationwide Emerging Managers, LLC v. Northpointe Holdings, LLC, 112 A.3d 878 (Del. 2015) (application of law of the case when facts unchanged and no clear error)
- Hoskins v. State, 102 A.3d 724 (Del. 2014) (describing exceptions to law of the case for clear error, injustice, or changed circumstances)
- Skinner v. State, 607 A.2d 1170 (Del. 1992) (cited for Rule 61(i)(4) procedural bar authority)