State v. Tingle

CourtSuperior Court of Delaware
DecidedSeptember 16, 2024
Docket2304008374, 2306001803
StatusPublished

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

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

STATE OF DELAWARE : Def. I.D. No.: 2304008374, : 2306001803 vs. : : DALLAS TINGLE, : : Defendant. : :

OPINION & ORDER

Submitted: August 21, 2024 Decided: September 16, 2024

Defendant’s Motion for Postconviction Relief – DENIED.

CONNER, J. On February 7, 2024, Dallas Tingle (“Defendant”) pled guilty to Carrying a

Concealed Deadly Weapon, Aggravated Menacing, and Strangulation. The State

entered a nolle prosequi on the remaining eleven charges. The Defendant was

sentenced to five years at Level V, followed by decreasing levels of subsequent

incarceration and probation. There was no direct appeal to the Delaware Supreme

Court.

On May 23, 2024, the Defendant timely filed his first Superior Court Criminal

Rule 61 petition. It stated four grounds for relief: (1) ineffective assistance of

counsel; (2) “forced” truth in sentencing plea and/or “misunderstood options”; (3)

“inability to confront witnesses and credibility”; and (4) lack of physical evidence.

On June 18, 2024, defense counsel, Jefferey P. McLane, Esq. (“Mr. McLane”),

filed an affidavit in response to the motion for postconviction relief. On July 8,

2024, the Department of Justice (DOJ) filed a response in opposition to the motion

for postconviction relief. On August 21, 2024, the Defendant filed a reply letter.

Before assessing claims for relief, the Court must address the four procedural

bars to relief under Rule 61. First, “[a] motion for postconviction relief may not be

filed more than one year after the judgment of conviction is final.”1 The Defendant

entered a guilty plea on February 7, 2024. Thirty days later, on March 08, 2024, the

1 Super. Ct. Crim. R. 61(i)(1).

2 conviction became final. The motion for postconviction relief was filed May 5,

2024, well within the one-year period required under Rule 61(i)(1). Therefore, the

motion is not barred by the one year limitation.

Second, “[n]o second or subsequent motion is permitted under this Rule

unless that second or subsequent motion satisfies” certain requirements.2 This is the

first motion for postconviction relief, therefore the motion is not barred by this

provision.

Third, grounds for relief “not asserted in the proceedings leading to the

judgment of conviction” are barred unless the movant shows both “(A) [c]ause for

relief from the procedural default and (B) [p]rejudice from violation of the movant's

rights.”3 This provision bars the third and fourth grounds for postconviction relief.

The Defendant failed to assert in the proceedings leading to the guilty plea either

that insufficient evidence existed to convict or that the State’s witnesses against the

Defendant were incredulous. Therefore, these claims are barred.

Finally, “[a]ny ground for relief that was formerly adjudicated, whether in the

proceedings leading to the judgment of conviction, in an appeal, in a postconviction

proceeding, or in a federal habeas corpus proceeding, is thereafter barred.”4 As

2 Super. Ct. Crim. R. 61(i)(2). 3 Super. Ct. Crim. R. 61(i)(3). 4 Super. Ct. Crim. R. 61(i)(4).

3 stated above, the Defendant accepted a plea deal, therefore no trial occurred for the

adjudication of issues raised in this motion. As such, the motion is not barred by this

The first ground for postconviction relief is ineffective assistance of defense

counsel, Mr. McLane. Delaware courts assess ineffective assistance of counsel

claims under the two-part standard established in Strickland v. Washington.5 Under

Strickland, the Defendant must show that Mr. McLane’s representation (1) “fell

below an objective standard of reasonableness”6, and (2) that his “deficient

performance prejudiced the defense.”7 Additionally, under Strickland, the Court

“indulge[s] a strong presumption that counsel's conduct falls within the wide range

of reasonable professional assistance….”8 Further, “[t]he defendant’s

representations at the plea colloquy, as well as any findings made by the judge

accepting the plea, constitute a ‘formidable barrier in any subsequent collateral

proceedings.’”9

The thrust of the ineffective assistance of counsel claim is that Mr. McLane

did not have “proper time to prepare.” This claim contradicts the Defendant’s

5 466 U.S. 668, 687-688 (1984). 6 Id. at 688. 7 Strickland, 466 U.S. at 687. 8 Id. at 689. 9 State v. Melendez, 2003 WL 23095688 at *3 (Del. Super. Dec. 19, 2003) (quoting Blackledge v. Allison, 431 U.S. 63, 73-74, 97 S.Ct. 1621, 52 L.Ed.2d 136 (1977)).

4 representations to the Court during the plea colloquy where the Defendant affirmed

that he had enough time to talk to Mr. McLane about his cases. In the reply brief,

the Defendant makes the conclusory allegation that had Mr. McLane filed a

suppression motion, the charges would have been dropped.10 This allegation is

purely speculative and contradicts the representations to the Court during the plea

colloquy that he was satisfied with Mr. McLane’s representation.11 Additionally,

raising new issues in the reply brief is not permitted without leave of the court and

therefore barred.12

The Court’s inquiry into defense counsel’s performance must consider

“whether counsel’s assistance was reasonable considering all the circumstances.”13

Before Mr. McLane was assigned to the Defendant’s cases, his prior attorney at the

Office of Defense Services requested a continuance in his cases. Mr. McLane

became the Defendant’s attorney on January 4, 2024, the same day that the

continuance motion was denied. While it is not contested that Mr. McLane first met

with the Defendant on January 30, 2024, eight (8) days before the Defendant entered

the plea, this alone does not mean that he did not have adequate time to prepare.

10 Pet’r Reply Br. at 1. 11 Tr. at 6. 12 Super Ct. Crim. R. 61(b)(2) and 61(b)(6); State v. Whittington, 2022 WL 1740764 at *2 (Del. Super. May 27, 2022). 13 Strickland, at 688 (emphasis added).

5 As for prong one, the arguments that Mr. McLane’s representation fell below

an objective standard of reasonableness are inadequate. He did not represent the

Defendant for one week but one month. By the time he took the Defendant’s cases,

prior counsel’s continuance motion had been denied and Mr. McLane was bound to

operate within the confines of that denial. During that time frame, he met with the

Defendant twice to discuss the cases. He made a strategic decision to not file a

suppression motion. A decision that falls within the wide range of reasonable

professional assistance. A decision that may have prevented the plea bargain,

negotiated by the Defendant’s prior counsel, from being taken off the table.

As for the second prong, the Defendant provides no support that Mr. McLane’s

performance prejudiced the defense. For Defendant’s crimes, he was facing up to

21 years of incarceration at level V. Mr. McLane maintained a plea bargain,

negotiated by prior counsel, wherein the defendant was only required to serve five

years at level V. This is indicative of an adequate defense and demonstrates that

Defendant was not prejudiced by Mr. McLane’s representation. Considering the

totality of the circumstances surrounding Mr. McLane’s representation, including

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Related

Blackledge v. Allison
431 U.S. 63 (Supreme Court, 1977)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)

Cite This Page — Counsel Stack

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