Clark v. State

Summary

The Supreme Court of Delaware affirmed Clark’s convictions and habitual-offender sentence after independently reviewing the record under Rule 26(c). It held that an unpreserved prosecutorial misstatement about the DNA evidence did not constitute reversible plain error, that ineffective-assistance claims would not be considered for the first time on direct appeal, and that the remaining challenges lacked merit. The Court also held that counsel’s decision to admit the DNA report without requiring foundational expert testimony was a permissible strategic choice. No separate opinions were filed.