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Wright v. State
570, 2016
| Del. | May 12, 2017
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Background

  • Clifford Wright was convicted in 2010 by a Superior Court jury of four counts of first‑degree murder and related offenses and sentenced to life imprisonment.
  • This Court affirmed Wright’s convictions and sentences on direct appeal after the Superior Court addressed a post‑trial motion for new trial.
  • Wright pursued Rule 61 postconviction relief: appointed counsel filed an amended motion in 2015 raising only an ineffective‑assistance claim about failure to rebut two witnesses on the murder weapon; the Superior Court denied relief and this Court affirmed.
  • In July 2016 Wright filed a second Rule 61 motion raising five pro se claims he had earlier attempted to bring (speedy trial, insufficiency re: murder weapon, insufficiency re: burglary, prosecutorial misconduct, trial counsel ineffective for certain actions) and alleging his postconviction counsel was ineffective for not adopting those pro se claims in the first Rule 61 proceeding.
  • The Superior Court denied the second Rule 61 motion as procedurally barred under Rule 61(i) (time, prior filing, failure to raise earlier, and former adjudication) and also found the claims lacked merit; this Court affirmed, adopting the Superior Court’s reasoning.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Speedy trial violation Wright: delay denied his right to speedy trial State: claim is procedurally barred and lacks merit Barred by Rule 61(i); no merit
Sufficiency — murder weapon Wright: evidence insufficient to prove the murder weapon as indicted State: claim was raised or could have been raised earlier; procedurally barred Barred by Rule 61(i); also previously adjudicated
Sufficiency — burglary Wright: evidence insufficient to prove he burglarized victim's home State: claim is procedurally barred and evidence was sufficient circumstantially Barred by Rule 61(i); merits rejected—sufficient circumstantial evidence
Prosecutorial misconduct & trial counsel ineffective Wright: prosecutor improperly buttressed witness; counsel erred re telephone records and introducing bat State: claims procedurally barred and lack merit Barred by Rule 61(i); no reversible merit
Ineffective assistance of postconviction counsel Wright: postconviction counsel failed to raise his five pro se claims State: claim is procedurally barred and substantively lacks merit for same reasons as underlying claims Barred by Rule 61(i); fails on the merits for same reasons

Key Cases Cited

  • Chavous v. State, 953 A.2d 282 (Del. 2008) (a represented defendant’s pro se filings are a legal nullity unless counsel endorses them)
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Case Details

Case Name: Wright v. State
Court Name: Supreme Court of Delaware
Date Published: May 12, 2017
Docket Number: 570, 2016
Court Abbreviation: Del.