Benson v. State

Summary

The Delaware Supreme Court affirmed the Superior Court’s denial of Sirron Benson’s first motion for postconviction relief. The court held that defense counsel’s alternative argument for lesser-included offenses was a reasonable trial strategy and that Benson failed to establish ineffective assistance of counsel or prejudice under Strickland v. Washington.

Holdings

1. Counsel's decision to argue lesser-included offenses in the alternative was a reasonable trial strategy and did not constitute deficient performance under Strickland.
2. Benson failed to establish prejudice because the evidence that he was the shooter was so one-sided that a different closing-argument strategy did not create a reasonable probability of a different outcome.

Questions Presented

1. Whether trial counsel provided ineffective assistance by arguing that the jury should consider lesser-included offenses after primarily arguing that Benson was not the shooter.
2. Whether counsel's alternative closing argument undermined Benson's presumption of innocence or otherwise created a reasonable probability of a different trial outcome.

Disposition

affirmed