Summary
This Delaware Supreme Court per curiam order affirms the Superior Court’s denial of Waymond Wright’s second motion for postconviction relief. Wright argued that his trial counsel’s concurrent representation of another client created a conflict of interest that prevented effective cross-examination of a codefendant witness. The Court held that Wright failed to satisfy the procedural requirements for a successive motion under Superior Court Rule of Criminal Procedure 61(d)(2) and did not present new evidence creating a strong inference of actual innocence. Consequently, the appeal was dismissed and the lower court’s judgment was affirmed.
Topics
Practice areas
Questions Presented
- Whether the appellant’s second postconviction relief motion satisfies the "actual innocence" exception to summary dismissal under Superior Court Rule of Criminal Procedure 61(d)(2).
Holdings
- The motion does not satisfy the actual innocence exception; the alleged evidence is merely credibility‑related and does not create a strong inference of actual innocence, so the Superior Court’s denial is affirmed.
Key quotations
““Satisfying the actual innocence test is, by design, a heavy burden, and such meritorious claims are exceedingly rare.””
“Evidence that goes only to the weight or credibility of evidence that was presented to the jury is “almost never adequate” to satisfy the actual innocence test.”
Factual background
Waymond Wright and co‑defendants Natasha Mahaley and Steven Huff were charged with two robberies on August 18, 2012. Huff and Mahaley pleaded guilty to the second robbery and testified against Wright, who was convicted of second‑degree robbery and conspiracy. After sentencing, Wright filed successive postconviction motions alleging that his trial counsel’s representation of another client, Izzy Whitehurst, prevented effective cross‑examination of Mahaley.
Procedural history
Wright was convicted of second-degree robbery and conspiracy. The Superior Court affirmed the conviction on direct appeal in 2016. Wright's first postconviction relief motion was denied in 2018 and affirmed by this Court. In July 2024 Wright filed a second postconviction motion alleging ineffective assistance of counsel due to a conflict of interest, which the Superior Court denied. The Supreme Court reviewed the denial.