William T. Johnson, Jr. v. State of Delaware

Summary

The Delaware Supreme Court affirmed the Superior Court’s summary dismissal of William T. Johnson, Jr.’s third postconviction motion as procedurally barred under Delaware Superior Court Criminal Rule 61. The Court held that Johnson failed to plead particularized facts showing either newly discovered evidence creating a strong inference of actual innocence or a retroactive new rule of constitutional law.

Holdings

1. A successive motion for postconviction relief is procedurally barred unless the defendant pleads with particularity either new evidence creating a strong inference of actual innocence or a new retroactive constitutional rule rendering the convictions invalid. Johnson's petition did not satisfy either requirement.
2. The Superior Court properly summarily dismissed Johnson's third postconviction motion as procedurally barred.

Questions Presented

1. Whether Johnson's third successive petition for postconviction relief satisfied the pleading exceptions to Rule 61's procedural bar.
2. Whether the Superior Court properly summarily dismissed the successive petition.

Disposition

affirmed