Reese v. State

Summary

The Delaware Supreme Court affirmed the Superior Court’s denial of Allen Reese’s motion for postconviction relief. The Court rejected his claims of ineffective assistance of counsel, involuntary guilty plea, and Brady violations arising from his Delaware sexual-abuse convictions and related plea proceedings.

Holdings

1. Reese's claims relating to the arraignment are without merit. Counsel entered Reese's plea of not guilty and waived reading of the charges, which was all that was required at that stage. Reese failed to show a breakdown in the adversarial process under Cronic or prejudice under Strickland.
2. Reese has not demonstrated ineffectiveness or prejudice. His claim that Counsel was unfamiliar with the evidence is belied by his own statement that he discussed GPS data and inconsistencies in the child's statements with Counsel before pleading guilty. The strong presumption that Counsel's advice was professionally reasonable is not overcome.
3. Reese is bound by his representations during the plea colloquy that he had not been promised anything not stated in the written plea agreement. He has not provided clear and convincing evidence to the contrary.
4. A knowing and voluntary guilty plea waives a defendant's right to challenge pre-plea errors, including alleged Brady violations. Reese acknowledged being aware of the GPS data and inconsistencies before pleading guilty, and his plea was knowing, intelligent, and voluntary. He cannot claim prejudice after intentionally bypassing the Delaware discovery process.

Questions Presented

1. Whether counsel's conduct at arraignment constituted ineffective assistance by failing to notify the court of Reese's desire to withdraw from the plea deal and failing to object to a $1 million cash bond request.
2. Whether counsel was ineffective for advising Reese to plead guilty without sufficiently investigating the case or pursuing defense strategies.
3. Whether counsel misinformed Reese about his prospects for commutation to induce his guilty plea.
4. Whether the State violated Brady v. Maryland by not producing favorable evidence before Reese pleaded guilty.

Disposition

affirmed