DeAngelo v. State

Summary

The Delaware Supreme Court affirmed the denial of James Christopher DeAngelo’s first motion for postconviction relief following his conviction for second-degree murder. The Court held that his ineffective-assistance claims lacked support, his due process claims concerning the weapon charge were procedurally barred, and there was no objective basis to question the trial judge’s impartiality.

Holdings

1. The ineffective-assistance-of-counsel claims failed because DeAngelo's allegations concerning his 2000 criminal trial lacked support in the record.
2. The due process claims related to prosecution of the weapon charge were procedurally barred under Superior Court Criminal Rule 61(i)(3) because DeAngelo failed to raise them on direct appeal.
3. Recusal was not required because there was no objective basis for a reasonable person to question the trial judge's impartiality.

Questions Presented

1. Whether the Superior Court properly denied DeAngelo's ineffective-assistance-of-counsel claims because the record did not support them.
2. Whether DeAngelo's due process claims concerning prosecution of the weapon charge were procedurally barred under Superior Court Criminal Rule 61(i)(3) because they were not raised on direct appeal.
3. Whether the trial judge should have recused himself because of alleged subjective or objective bias.

Disposition

affirmed