State v. York-James
1408017362
| Del. Super. Ct. | Mar 8, 2017Background
- In August 2014, then-16-year-old Obediah York-James robbed Cutrona's Liquors, pointed a gun at clerk Navin Patel and shot him twice; surveillance video captured the robbery and shooting.
- Indicted December 8, 2014 on Attempted Murder (1st), two counts of Possession of a Firearm During the Commission of a Felony (PFDCF), Robbery (1st), and Conspiracy (2nd).
- On April 22, 2015 York-James pled guilty pursuant to a plea agreement: Assault (1st) (reduced from Attempted Murder), Robbery (1st), and two PFDCF counts; the State dismissed the Conspiracy count.
- The plea exposed a minimum mandatory sentence of 11 years Level V (with a recommended sentence of that minimum) rather than the higher exposure (15 years minimum or life) if convicted of Attempted Murder at trial.
- York-James was sentenced immediately to the agreed minimum; he did not file a direct appeal and later filed a Rule 61 postconviction motion on October 11, 2016 asserting the plea was coerced/uninformed, PFDCF counts should merge, and counsel was ineffective.
- The Commissioner recommends denial: the motion was untimely and procedurally barred, claims were waived by the voluntary plea, and the substantive claims fail on the merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness / Procedural bar under Super. Ct. Crim. R. 61(i) | Rule 61 requires motions within one year of final judgment; York-James’s judgment became final May 22, 2015 so the Oct. 11, 2016 motion is untimely. | York-James challenged plea-related matters and counsel effectiveness and filed after one year. | Motion is untimely and procedurally barred; no Rule 61(i)(5) exception applies. |
| Waiver by guilty plea | A knowing, voluntary plea waives pre-plea claims and most constitutional defects. | York-James contends plea was coerced/uninformed and counsel misadvised him. | Plea colloquy and plea form show knowing, voluntary plea; claims waived. |
| Ineffective assistance of counsel (plea context) | State: counsel advised client, discussed options, and recommended plea given strong evidence; no deficient performance or prejudice under Strickland/Premo. | York-James says counsel failed to secure a better plea and misled him. | No deficient performance shown; York-James failed to show reasonable probability he would have rejected plea and gone to trial. |
| Double jeopardy / merging PFDCF counts | State: two PFDCF counts were tied to two distinct predicate felonies (robbery and shooting) so separate convictions permissible. | York-James argues the two PFDCF convictions should merge into one. | Two PFDCF convictions may stand; charging PFDCF for each firearm possession tied to each felony is proper. |
Key Cases Cited
- Younger v. State, 580 A.2d 552 (Del. 1990) (finality of judgment and postconviction timing rule)
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong standard for ineffective assistance of counsel)
- Somerville v. State, 703 A.2d 629 (Del. 1997) (plea waives pre‑plea claims absent clear showing)
- Premo v. Moore, 131 S. Ct. 733 (2011) (deference to counsel’s strategic decisions in pleading context)
- Nance v. State, 903 A.2d 283 (Del. 2006) (PFDCF charging principles and related jurisprudence)
- Washington v. State, 844 A.2d 293 (Del. 2004) (no constitutional right to a plea bargain)