State v. Wright
0801010328
| Del. Super. Ct. | Nov 2, 2016Background
- Defendant Clifford Wright was convicted by a jury of four counts of first-degree murder and multiple related offenses; sentenced to life without parole on the murder convictions in March 2010.
- Wright pursued direct appeal; the Delaware Supreme Court remanded for a ruling on his motion for a new trial, the Superior Court denied that motion, and the Supreme Court later affirmed the convictions on direct appeal.
- Wright filed an initial pro se Rule 61 postconviction motion, received appointed counsel, and filed an amended Rule 61 motion; the Superior Court denied relief and the Delaware Supreme Court affirmed.
- Wright filed a second pro se Rule 61 motion raising six grounds: ineffective assistance by postconviction counsel for failing to press issues Wright proposed; violation of his speedy trial right; claim that deadly-weapon evidence was improperly derived from the indictment; insufficient evidence of entry into the female victim’s house; prosecutorial vouching for a witness; and trial counsel’s failure to obtain phone records and alleged error in presenting a baseball bat as a possible weapon.
- The Superior Court evaluated procedural bars under Superior Court Criminal Rule 61(i) and Strickland for ineffective-assistance claims, and denied the second Rule 61 motion as procedurally barred and without merit; related motions for appointed counsel, to participate with counsel, and to preserve issues were also denied.
Issues
| Issue | Plaintiff's Argument (Wright) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Speedy trial violation | Trial scheduling and delay violated Wright’s right to a speedy trial | Wright’s counsel repeatedly waived speedy-trial rights and requested continuances for a complex case | Denied — procedurally barred and meritless; counsel waived time at scheduling conferences |
| Deadly-weapon evidence derived from indictment | Evidence at trial (e.g., baseball bat) was inconsistent with indictment listing hammer/pry bar/crowbar | Indictment’s “or other similar tool” encompassed a bat; issue was litigated previously | Denied — procedurally barred and meritless; indictment adequately informed defendant |
| Sufficiency of evidence that Wright entered victim’s house | No sufficient evidence proving Wright entered the female victim’s house | Circumstantial evidence supports entry; murders occurred at the house and jury found guilt beyond reasonable doubt | Denied — procedurally barred and meritless; circumstantial evidence sufficient |
| Ineffective assistance (postconviction/trial counsel failures: not raising proposed issues, failing to obtain phone records, introducing baseball bat) | Counsel failed to pursue issues Wright proposed, failed to get telephone records, and opened door to bat as weapon | Many claims were previously adjudicated or not timely; where not barred, Wright made only conclusory allegations and did not show prejudice under Strickland | Denied — claims are procedurally barred or fail Strickland’s deficient-performance and prejudice prongs; no appointment of counsel warranted |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two-pronged test for ineffective assistance of counsel)
- Ayers v. State, 802 A.2d 278 (Del. 2002) (Rule 61 procedural framework)
- Flamer v. State, 585 A.2d 736 (Del. 1990) (Strickland adopted and applied in Delaware)
- Cooke v. State, 977 A.2d 803 (Del. 2009) (requirement for concrete allegations of prejudice in postconviction claims)
- Wright v. State, 31 A.3d 77 (Del. 2011) (direct-appeal disposition of Wright’s convictions)