State v. Wright
91004136DI
| Del. Super. Ct. | Jul 14, 2016Background
- Defendant Jermaine Wright filed a motion (Feb 19, 2016) seeking a new "proof positive" bail hearing after earlier proceedings denying bail in 1991 and subsequent appellate activity.
- A proof positive hearing assesses whether the State has "proof positive or presumption great" in a capital case such that bail should be denied.
- At the Original Hearing (1991) the court denied bail, relying primarily on (1) a witness who came to the store shortly after the crime, (2) barmaid Debra Milner’s indication of multiple voices, and (3) a taped confession implicating Wright.
- Wright argues changed circumstances and injustice warranting a new hearing: alleged coercion and drug-influenced confession, later statements by Detective Mayfield minimizing corroboration, investigative lapses (unrecorded interview), and scientific developments about confession reliability.
- The State contends the motion is barred by the law-of-the-case doctrine because the Original Hearing fully adjudicated bail and no materially new evidence exists.
- The Superior Court held a hearing and denied Wright’s motion, concluding the law-of-the-case doctrine bars reopening the proof positive determination.
Issues
| Issue | Wright's Argument | State's Argument | Held |
|---|---|---|---|
| Whether the law-of-the-case doctrine bars a new proof positive hearing | The Original Hearing lacked critical information (coercion/drug influence, misleading testimony, unrecorded interview, lack of corroboration); science undermines confession weight | Original Hearing was fully briefed and decided; no new facts that qualify as changed circumstances | Doctrine bars a new hearing; Motion denied |
| Whether alleged unreliability of the confession constitutes a changed circumstance | Confession was coerced or given under drug influence; recent science affects confession reliability | Confession admissibility and weight are for trial; reliability attacks go to weight, not changed circumstances | Not a changed circumstance; admissibility previously upheld and remains part of the case |
| Whether alleged Detective Mayfield misstatements or lack of corroboration require reopening | Misleading testimony and weaker corroboration would alter the proof positive calculus | Such issues affect weight; proof positive is preliminary and did not require proof beyond a reasonable doubt | Not a changed circumstance; original decision relied on multiple bases beyond Milner’s account |
| Whether Wright’s post-overturn conduct (not fleeing) supports bail now | Wright’s conduct when released shows low flight risk and supports reconsideration | Proof positive focuses on strength of State’s case, not defendant’s flight history; statute limits bail in capital cases | Not a changed circumstance; defendant’s conduct does not overcome law-of-the-case bar |
Key Cases Cited
- State v. Wright, 131 A.3d 310 (Del. 2016) (articulates two-step law-of-the-case analysis and limits on changed circumstances)
- State v. Wright, 67 A.3d 319 (Del. 2013) (addressed admissibility of Wright’s confession and appellate constraints on bail pending appeal)
- Cede & Co. v. Technicolor, Inc., 884 A.2d 26 (Del. 2005) (describes law-of-the-case as a self-imposed restriction promoting finality)
- Hoskins v. State, 102 A.3d 724 (Del. 2014) (law-of-the-case remains constant through subsequent litigation)
- In re Steigler, 250 A.2d 379 (Del. 1969) (establishes proof positive standard and purpose of bail inquiry in capital cases)