State v. Wright
2013 Del. LEXIS 256
| Del. | 2013Background
- Wright convicted of first-degree murder from 1991 Hi-Way Inn robbery; sentenced to death in 1992 and direct appeal affirmed.
- Superior Court granted multiple Rule 61 motions, vacating Wright’s sentence and later allowing bail after the fourth motion.
- The fourth Rule 61 motion alleged Miranda violation and a Brady violation based on a BVLS attempted robbery nearby; trial court vacated convictions and granted bail during appeal.
- On review, the Court held the trial court erred in sua sponte reviewing admissibility of the confession and in finding a Brady violation; the bail determination was improper; the case is remanded with instructions to reinstate Wright’s convictions.
- The Supreme Court reversed the Superior Court’s judgment, remanded for reinstatement of the convictions, and stated jurisdiction would not be retained.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether bail can be granted pending appeal in a capital case | Wright argues for bail pending appeal | State argues capital-conviction defendants remain in custody pending appeal | No; Wright remains in custody pending appeal. |
| Whether the Superior Court properly reviewed the confession's admissibility sua sponte | Wright contends the review was proper and warranted remedy | State contends issues already resolved should not be revisited | Erroneous for the court to review admissibility sua sponte. |
| Whether the BVLS evidence constituted a Brady violation prejudice Wright | BVLS evidence was exculpatory and suppression prejudiced Wright | State contends no prejudice and evidence was not suppressible | No prejudice proven; no Brady violation established. |
| Whether Wright’s convictions should be reinstated after Brady error | Brady violation entitles new trial and reinstatement of convictions | State disputes materiality and prejudice of the Brady evidence | Judgment reversed; remanded for reinstatement of convictions. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (due process requires disclosure of exculpatory evidence)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (prosecution must learn favorable evidence held by investigators)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985) (materiality depends on probability of different outcome with disclosure)
- Jackson v. State, 770 A.2d 506 (Del. 2001) (Brady analysis applied to Delaware case; prejudice assessment essential)
- Starling v. State, 882 A.2d 747 (Del. 2005) (cited for Brady framework and prejudice/likelihood of impact)