Smith v. State

CourtSuperior Court of Delaware
DecidedFebruary 11, 2025
Docket1602012206
StatusPublished

This text of Smith v. State (Smith v. State) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. State, (Del. Ct. App. 2025).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

ROBERT L. SMITH, ) ) Defendant Below, ) Appellant, ) ) v. ) No. 179, 2024 ) STATE OF DELAWARE, ) Cr. ID No. 1602012206 ) Appellee. )

Analysis of Scarborough Factors Upon Remand

Submitted: November 15, 2024 Decided: February 11, 2025

Andrew J. Vella, Esquire, Chief of Appeals, Delaware Department of Justice, Wilmington, Delaware, Attorney for the State.

Edward C. Gill, Esquire, Law Offices of Edward C. Gill, P.A., Wilmington, Delaware, Rule 61 Counsel for Defendant Robert Smith.

JURDEN, P.J. I. INTRODUCTION

On December 31, 2023, the Commissioner filed a Report recommending that

the Superior Court deny Smith’s Motion for Postconviction Relief. 1 Smith objected

to the Commissioner’s Report in a timely manner.2 On April 11, 2024, the Superior

Court adopted the findings set forth in the Commissioner’s Report and denied

Smith’s Motion for Postconviction Relief. 3 On May 2, 2024, Smith appealed the

Superior Court’s decision. 4

Now on appeal, the Delaware Supreme Court remanded the case back to the

Superior Court so that a complete Strickland v. Washington 5 analysis could be

conducted to determine if Smith was prejudiced by his Trial Counsel’s failure to

withdraw his Guilty But Mentally Ill plea (“GBMI plea”). 6

II. STRICKLAND STANDARD IN PLEA WITHDRAWAL CONTEXT

To prevail on a claim of ineffective assistance of counsel, the movant must

1 D.I. 89. 2 D.I. 90. 3 State v. Smith, 2024 WL 1577183, at *1 (Del. Super. Apr. 11, 2024). 4 D.I. 94. On appeal, Smith argues that the Superior Court erred in two respects. First, he contends that “[w]hile the Superior Court correctly found that trial counsel’s performance in representing [] Smith was deficient pursuant to Strickland v. Washington, . . . it erred in finding no prejudice to [] Smith as a result of the deficient performance.” Second, Smith argues that he was “denied his right to choose to go to trial and present the viable defenses of extreme emotional distress and self defense when he advised his counsel that [] was his decision and counsel recommended and [] Smith eventually acceded to pleading guilty pursuant to a plea agreement which afforded him no benefit.” See Supreme Court Order, Trans. ID 75013408 (Nov. 15, 2024) (“Supreme Court Order”) ¶ 8. 5 See generally Strickland v. Washington, 466 U.S. 668 (1984). 6 Supreme Court Order at 9. 2 satisfy the two-prong standard set forth in Strickland. 7 Under Strickland, the movant

must prove that (1) his trial counsel’s performance was objectively unreasonable;

and (2) his defense was prejudiced as a result.8 “To satisfy the second prong

of Strickland in the plea withdrawal context, [the defendant] must show a reasonable

probability that, but for his counsel's error, he would have insisted on going to trial

and the trial court would have granted his motion to withdraw [his] plea.” 9

“Following a procedurally proper acceptance of [a] plea, the defendant must,

under Superior Court Criminal Rule 32(d), establish a ‘fair and just’ reason in order

to have a plea withdrawn prior to sentencing.”10 The Delaware Supreme Court in

Scarborough v. State established five factors the trial court must consider in deciding

whether to allow the withdrawal of a guilty plea.11 The Scarborough factors are as

follows:

(1) Was there a procedural defect in taking the plea;

(2) Did defendant knowingly and voluntarily consent to the plea agreement;

(3) Does defendant presently have a basis to assert legal innocence;

(4) Did defendant have adequate legal counsel throughout the proceedings; and

(5) Does granting the motion prejudice the State or unduly 7 Strickland, 466 U.S. at 687. 8 Id. at 687-88, 691-92. 9 Reed v. State, 258 A.3d 807, 829-30 (Del. 2021). 10 Id. at 823. 11 See generally Scarborough v. State, 938 A.2d 644 (Del. 2007).

3 inconvenience the Court.12

“These factors are not factors to be balanced; indeed, some of the factors of

themselves may justify relief.”13 It is the movant’s burden to show that he is entitled

to relief under Strickland; however, the trial court has an independent obligation to

examine the Scarborough factors.14

A. ANALYSIS OF THE SCARBOROUGH FACTORS

1. Was there a procedural defect in taking the plea?

a. Law

Title 11 Del. C. § 408(a) sets forth the process for entering a GBMI plea:

Where a defendant's defense is based upon allegations which, if true, would be grounds for a verdict of “guilty, but mentally ill” or the defendant desires to enter a plea to that effect, no finding of “guilty, but mentally ill” shall be rendered until the trier of fact has examined all appropriate reports (including the presentence investigation); has held a hearing on the sole issue of the defendant's mental illness, at which either party may present evidence; and is satisfied that the defendant did in fact have a mental illness at the time of the offense to which the plea is entered. Where the trier of fact, after such hearing, is not satisfied that the defendant had a mental illness at the time of the offense, or determines that the facts do not support a “guilty, but mentally ill” plea, the trier of fact shall strike such plea, or permit such plea to be withdrawn by the defendant. A defendant whose plea is not accepted by the trier of fact shall be entitled to a jury trial, except that if a defendant subsequently waives the right to

12 Id. at 649. 13 Id. (citing Patterson v. State, 684 A.2d 1234, 1239 (Del. 1996)). 14 Supreme Court Order ¶ 14 (citing Reed, 258 A.3d at 830).

4 a jury trial, the judge who presided at the hearing on mental illness shall not preside at the trial. 15

In Taylor v. State, the Delaware Supreme Court acknowledged that “the

statute is ambiguous on how to order the proceedings before adjudicating a

defendant guilty but mentally ill of a crime by plea,” and interpreted the statute as

A defendant can plead guilty but mentally ill to a crime, and the court can accept the plea in the same hearing after finding under Superior Court Criminal Rule 11 that the defendant's plea is made knowingly, intelligently, and voluntarily. But, the court should defer adjudicating the defendant guilty but mentally ill of the crime until after it holds a hearing where the sole issue is the defendant's mental illness. As part of the evidence at the second mental illness hearing, the court should consider the presentence investigation. After the second hearing, if the court is satisfied that the requirements of § 408(a) have been met, the court should adjudicate the defendant guilty but mentally ill of the offense and impose sentence. If the statutory requirements are not met, the court should strike the plea or allow the defendant to withdraw it.16

b. Facts

Smith’s plea hearing (“Hearing”) was held on August 30, 2017. 17 Before the

Court engaged in a plea colloquy with Smith, the Court addressed Smith’s mental

illness with the State and Trial Counsel. 18 The parties had an opportunity to review

the evidence, introduce any new evidence, and provide additional opinions from

15 11 Del. C. § 408(a). 16 Taylor v. State, 213 A.3d 560, n.45 (Del. 2019). 17 D.I. 24. 18 See generally D.I. 36.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Florida v. Nixon
543 U.S. 175 (Supreme Court, 2004)
Scarborough v. State
938 A.2d 644 (Supreme Court of Delaware, 2007)
Cooke v. State
977 A.2d 803 (Supreme Court of Delaware, 2009)
Somerville v. State
703 A.2d 629 (Supreme Court of Delaware, 1997)
Patterson v. State
684 A.2d 1234 (Supreme Court of Delaware, 1996)
Taylor v. State
213 A.3d 560 (Supreme Court of Delaware, 2019)

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Smith v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-state-delsuperct-2025.