Jones v. State

Summary

The Delaware Supreme Court affirmed the dismissal of Rule 61 postconviction applications filed by eleven defendants who had pleaded guilty to drug-possession offenses. The Court held that the applications were procedurally barred under the amended Rule 61 and, alternatively, lacked merit because the defendants did not establish grounds to avoid the effect of their knowing and voluntary guilty pleas.

Holdings

1. The Superior Court should have applied the procedural bars in Criminal Rule 61 because the petitions were filed after the amended rule took effect and were subject to its requirements.
2. The defendants' petitions were procedurally barred because none pleaded with particularity that new evidence existed creating a strong inference that the movant was actually innocent.
3. The petitions lacked merit because none of the defendants established a basis to avoid the effect of a voluntary and knowing guilty plea, and none alleged an unjust conviction.

Questions Presented

1. Whether the defendants' Rule 61 applications were procedurally barred because they were filed more than one year after their convictions became final.
2. Whether the applications satisfied Rule 61's requirement that a claim of actual innocence be pleaded with particularity and supported by new evidence creating a strong inference of actual innocence.
3. Whether the defendants' allegations concerning problems at the Office of the Chief Medical Examiner provided a basis to withdraw or overcome their voluntary and knowing guilty pleas.

Disposition

affirmed