Supreme Court of Delaware
Washington v. State
August 26, 2014
Summary
The Court affirmed the summary dismissal of Washington’s second postconviction motion and the denial of appointed counsel. It held that Washington had no automatic right to counsel for a second postconviction proceeding, and his speculative and procedurally barred ineffective-assistance claims did not establish good cause for discretionary appointment of counsel. The Court also held that Washington waived any argument that the miscarriage-of-justice exception applied because he failed to develop that argument in his opening brief.