State v. Lashley

CourtSuperior Court of Delaware
DecidedOctober 29, 2024
Docket1709005240
StatusPublished

This text of State v. Lashley (State v. Lashley) 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
State v. Lashley, (Del. Ct. App. 2024).

Opinion

THE SUPERIOR COURT OF THE STATE OF DELAWARE

STATE OF DELAWARE, ) ) v. ) ID No. 1709005240 ) SANDY D. LASHLEY, ) ) Defendant. )

Submitted: May 23, 20241 and May 30, 20242 Decided: October 29, 2024

ORDER DENYING POSTCONVICTION RELIEF AND SENTENCE MODIFICATION

Upon consideration of Sandy D. Lashley’s pro se motions for sentence

modification and postconviction relief, Superior Court Criminal Rules 35(b) and 61,

statutory and decisional law, and the record, it appears that:

BACKGROUND

On September 7, 2017, Sandy D. Lashley shot Allen Melton during a quarrel

at the corner of Cedar and Anchorage Streets in Wilmington, Delaware.3 Melton

died from his injuries.4 Lashley fled the scene, was apprehended in New York, and

1 Defendant’s Rule 35(b) motion was filed on May 23, 2024. Docket Item (“D.I.”) 46. 2 Defendant’s Rule 61 motion was filed on May 30, 2024. D.I. 47. 3 D.I. 45 at 2. This recitation of the factual and legal background is taken from this Court’s June 21, 2021 Order (D.I. 45) adopting a Commissioner’s Report and Recommendation (D.I. 43) to deny Lashley’s June 18, 2020 motion for postconviction relief (D.I. 35). 4 D.I. 45 at 2.

1 extradited back to Delaware.5

On March 26, 2018, the State indicted Lashley for Murder First Degree

(“Murder 1st”) and Possession of a Firearm During the Commission of a Felony

(“PFDCF”) for Melton’s death.6 Had Lashley been convicted of both, he would

have faced a mandatory term of life imprisonment for the Murder 1st charge and a

minimum–mandatory of 3, up to 25, years in prison on the PFDCF charge.7

On May 23, 2019, Lashley elected to plead guilty to Murder Second Degree

(“Murder 2nd” (as a lesser-included offense of Murder 1st)) and PFDCF,

substantially limiting his total potential incarceration.8 When he tendered his guilty

plea, Lashley understood he faced at least 15 years for the Murder 2nd conviction

and 3 years for the PFDCF conviction—a total minimum-mandatory sentence of 18

years at Level V.9 He also acknowledged that the judge could sentence him in

excess of what was recommended on the plea agreement10 Sentencing was deferred

so the parties could submit sentencing memoranda in support of their respective

5 D.I. 45 at 2. 6 D.I. 1. 7 D.I. 43 at 1. 8 As part of the plea agreement, the State also agreed to cap its recommendation of total unsuspended prison time at 25 years. 9 D.I. 44 at 5:4–6:18. 10 Id. at 4:10–13.

2 positions.11

On July 19, 2019, this Court sentenced Lashley on the charge of Murder 2nd

to 25 years at Level V, with 15 of those years being minimum-mandatory, followed

by lesser levels of incarceration and probation.12 On the PFDCF conviction, the

Court sentenced Lashley to three years minimum-mandatory at Level V.13 In total,

Lashley’s unsuspended Level V time was 23 years, with 18 of those years being

minimum-mandatory Level V-time.14 Lashley did not file a direct appeal.

On October 19, 2019, counsel for Lashley timely moved for sentence

modification (“First Rule 35(b) Motion”) offering additional character evidence.15

This Court denied that motion by Order dated December 12, 2019.16

On June 18, 2020, counsel for Lashley timely moved for postconviction relief

(“First Rule 61 Motion”) raising four claims: (1) his rights were violated when he

was sentenced outside SENTAC guidelines; (2) his rights were violated because the

State failed to take his mental health and past abuse into account in sentencing; (3)

his counsel was ineffective because he coerced Lashley, who was purportedly

11 Id. at 8:7–9:19. 12 D.I. 29. 13 Id. 14 Id. 15 D.I. 31. 16 D.I. 32.

3 illiterate and incompetent at the time, to accept the guilty plea; and (4) his counsel

was ineffective for coercion and not understanding Lashley’s claim of actual

innocence.17 By Order dated June 21, 2021, this Court adopted the Commissioner’s

Report and Recommendation to deny the First Rule 61 Motion.18 Specifically, this

Court held the claims raised in the motion were all waived upon the entry of

Lashley’s guilty plea, the first two claims were also procedurally barred, and all the

claims were without merit.19

On May 23, 2024, Lashley filed pro se his second Rule 35(b) Motion (“Second

Rule 35(b) Motion”).20 Six days later, on May 30, 2024, Lashley filed pro se his

second Rule 61 Motion (“Second Rule 61 Motion”).21 This is the Court’s decision

denying both motions.

DISCUSSION

Lashley’s motions fail on multiple fronts. Sentence modification and

postconviction relief are available only to those who overcome the procedural

hurdles of Rules 35 and 61 and substantively merit such relief. For the reasons

explained below, this Court finds Lashley’s motions are untimely, repetitive, and

17 See D.I. 35. 18 D.I. 43, 45. 19 D.I. 45 at 4–5. 20 D.I. 46. 21 D.I. 47.

4 meritless.

I. Rule 35(b)

Superior Court Criminal Rule 35(b) permits this Court to “reduce a sentence

of imprisonment on a motion made within 90 days after the sentence is imposed.”22

Rule 35(b) provides the “sentencing judge a second chance to consider whether the

initial sentence is appropriate”23 and gives the Court broad discretion to decide if it

should alter its judgment.24 The Court may consider reducing the term or conditions

of confinement or probation at any time.25 The movant bears the burden to establish

cause to modify a lawfully imposed sentence.26 While the rule does not set forth

specific criteria necessary to sustain this burden of proof, “common sense dictates

that the Court may modify a sentence if present circumstances indicate that the

previously imposed sentence is no longer appropriate.”27

22 Super. Ct. Crim. R. 35(b). 23 Johnson v. State, 234 A.2d 447, 448 (Del. 1967) (per curiam); State v. Reed, 2014 WL 7148921, at *2 (Del. Super. Dec. 16, 2014) (explaining time limitation and purpose of then- existent sentence reduction provision of Fed. R. Crim. P. 35, the federal analogue to current Criminal Rule 35(b) (citing United States v. Ellenbogen, 390 F.2d 537, 541–43 (2d. Cir. 1968))). 24 Hewett v. State, 2014 WL 5020251, at *1 (Del. Oct. 7, 2014) (“When, as here, a motion for reduction of sentence is filed within ninety days of sentencing, the Superior Court has broad discretion to decide whether to alter its judgment.” (first citing Del. Super. Ct. R. 35(b); and then citing Rondon v. State, 2008 WL 187964 (Del. Jan. 15, 2008))). 25 Id. 26 State v. Evans, 2024 WL 36518, at *2 (Del. Super. Jan. 3, 2024) (citation omitted). 27 Id. (citing State v. Bailey, 2017 WL 8787504, at *1 (Del. Super. Oct. 3, 2017)).

5 Rule 35(b) motions that are not filed within 90 days are generally time-barred;

the Court will only consider such motions under “extraordinary circumstances” or

under 11 Del. C. § 4217.28 Delaware law places a heavy burden on the movant to

establish “extraordinary circumstances” to “uphold the finality of judgments.”29 An

untimely Rule 35(b) motion may be excused when there are circumstances that

“specifically justify the delay, are entirely beyond a petitioner’s control, and have

prevented the applicant from seeking the remedy on a timely basis.”30

Lashley’s Second Rule 35(b) Motion argues he is entitled to sentence

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Related

United States v. Herbert A. Ellenbogen
390 F.2d 537 (Second Circuit, 1968)
Younger v. State
580 A.2d 552 (Supreme Court of Delaware, 1990)
State v. Sturgis
947 A.2d 1087 (Supreme Court of Delaware, 2008)
Somerville v. State
703 A.2d 629 (Supreme Court of Delaware, 1997)
Shelton v. State
744 A.2d 465 (Supreme Court of Delaware, 2000)
United States v. LaMorte
940 F. Supp. 572 (S.D. New York, 1996)
State v. Culp
152 A.3d 141 (Supreme Court of Delaware, 2016)
Johnson v. State
234 A.2d 447 (Supreme Court of Delaware, 1967)
Ploof v. State
75 A.3d 811 (Supreme Court of Delaware, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Lashley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lashley-delsuperct-2024.