Broadnax v. State

Summary

The Delaware Supreme Court affirmed James A. Broadnax's convictions and habitual-offender sentences following his guilty pleas to second-degree assault and possession of a deadly weapon during the commission of a felony. The court rejected claims concerning ineffective assistance of counsel, involuntariness of the guilty plea, and procedural defects in habitual-offender sentencing, concluding that the appeal lacked any arguably meritorious issue.

Holdings

1. The Court may grant counsel's motion to withdraw and affirm when counsel has conscientiously examined the record and law, and the Court's independent review shows that the appeal is devoid of any arguably appealable issue.
2. The Court generally will not consider an ineffective-assistance-of-counsel claim raised for the first time on direct appeal.
3. An involuntary-guilty-plea claim not raised in the Superior Court is reviewed only for plain error; the record here did not establish plain error or involuntariness.
4. A separate hearing on habitual-offender status was not required where the motion was addressed before sentencing, without objection, and defense counsel stipulated to the defendant's qualifying prior convictions and eligibility.

Questions Presented

1. Whether appellate counsel satisfied Delaware Supreme Court Rule 26(c) and whether the appeal presented any arguably appealable issue.
2. Whether Broadnax's ineffective-assistance claim could be considered for the first time on direct appeal.
3. Whether Broadnax's guilty plea was involuntary because of coercion or psychiatric medication.
4. Whether the Superior Court was required to hold a separate hearing on Broadnax's habitual-offender status.
5. Whether the Superior Court improperly reviewed the habitual-offender motion for the first time at sentencing.

Disposition

affirmed