Holmes v. State

Summary

The Supreme Court of Delaware affirmed Marvin Holmes’s conviction for escape after conviction and his eight-year habitual-offender sentence. The Court held that Holmes’s asserted justification was legally unavailable and that the excluded evidence, requested lesser-included-offense instruction, double-jeopardy claim, sufficiency challenge, and fair-trial claims lacked merit; other challenges were waived or procedurally improper. The Court also declined to consider ineffective-assistance claims on direct appeal and rejected Holmes’s vindictive-prosecution claim.