Wright v. State
91 A.3d 972
| Del. | 2014Background
- In 1992 Jermaine Wright was convicted of first‑degree murder, robbery, and weapons offenses for the Hi‑Way Inn clerk killing and sentenced to death; conviction rested chiefly on a videotaped confession and testimony of a prison informant (Gerald Samuels).
- No physical forensic evidence (fingerprints, shell casings, murder weapon) or eyewitness identifications tied Wright to the scene; defense presented an alibi and an alternative perpetrator theory implicating Kevin Jamison and Norman Curtis.
- At trial Samuels testified as a surprise rebuttal witness that Wright admitted the killing; Wright later contested voluntariness of confession (he was heroin‑addicted and intoxicated during interrogation).
- Postconviction proceedings uncovered nondisclosed evidence the defense said was Brady material: (1) an attempted robbery at Brandywine Village Liquor Store (BVLS) ~40 minutes earlier involving suspects with similar descriptions; (2) Samuels’ prior plea/cooperation arrangement; and (3) impeachment information showing Jamison was jointly charged with Curtis shortly before trial.
- The Superior Court (2012) vacated the convictions and death sentence based on Miranda and Brady (BVLS) errors, but this Court reinstated the conviction in 2013 (Miranda held procedurally barred; BVLS alone insufficient given the confession). On remand Wright pursued remaining claims; the Court here finds cumulative Brady violations requiring reversal and a new trial.
Issues
| Issue | Plaintiff's Argument (Wright) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether undisclosed evidence about Samuels, Jamison, and BVLS violated Brady | Suppressed evidence (Samuels’ cooperation/plea agreement, Jamison’s indictment/arrest timing, BVLS links) was favorable, suppressed, and cumulatively material | Claims waived or procedurally barred; individually the items lacked materiality and were not likely to change verdict | Court: Nondisclosure of cumulative impeachment/exculpatory evidence violated Brady; reasonable probability the verdict would differ; reverse and remand for new trial |
| Whether Rule 61 or cross‑appeal rules bar Wright from litigating his unresolved claims after State’s §9902(d) appeal | Wright argues he could not cross‑appeal under §9902 and thus did not waive these claims; court retains jurisdiction now that final judgment exists | State argues Wright waived issues by failing to cross‑appeal when State appealed the 2012 vacatur | Court: No jurisdictional bar; defendant was not required to cross‑appeal under §9902(d); Wright’s claims preserved for this appeal |
| Whether the Samuels‑related Brady claim was barred by Rule 61(i) (formerly adjudicated or defaulted) | Wright: claim falls within Rule 61(i)(5) miscarriage‑of‑justice exception because Brady strikes at trial fairness | State: claim was previously adjudicated or waived and should be barred under Rule 61(i)(4) | Court: Not barred; prior appellate briefing did not adjudicate Samuels issue on the merits; miscarriage‑of‑justice exception applies |
| Whether suppressed evidence would have affected penalty phase (death sentence) | Wright: suppression limited his residual‑doubt and mitigation arguments and thus affected sentencing outcome | State: suppression not shown to be material to penalty | Court: Suppression was material to penalty phase; cumulative evidence could have materially bolstered residual‑doubt allocution; sentence vacated along with conviction |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor must disclose evidence favorable to accused that is material to guilt or punishment)
- Miranda v. Arizona, 384 U.S. 436 (1966) (police must give warnings before custodial interrogation; waiver must be knowing and intelligent)
- Kyles v. Whitley, 514 U.S. 419 (1995) (materiality under Brady assessed cumulatively; government must learn and disclose favorable info known to others acting on its behalf)
- Bagley v. United States, 473 U.S. 667 (1985) (reasonable probability standard for materiality under Brady)
- Giglio v. United States, 405 U.S. 150 (1972) (impeachment evidence and witness deals are Brady/Giglio material)
- Strickler v. Greene, 527 U.S. 263 (1999) (elements of Brady: favorable, suppressed, prejudicial)
- Wright v. State, 67 A.3d 319 (Del. 2013) (prior Delaware appellate consideration reversing the Superior Court’s Miranda/Brady vacatur in part)
- State v. Cooley, 457 A.2d 352 (Del. 1983) (Delaware limits on cross‑appeals where State appeals under statutory §9902(d))