Chauncey S. Starling, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The Delaware Supreme Court reversed Starling’s denial of postconviction relief and remanded for a new trial. It held that trial counsel provided ineffective assistance by failing to elicit critical exculpatory eyewitness evidence and by failing to challenge the admission of a potentially coerced statement, and that the State violated its disclosure obligations by inaccurately representing that its principal witness’s charges remained pending. The cumulative effect of these errors undermined confidence in the verdict. Justice Vaughn, concurring, agreed that the disclosure violation warranted a new trial but rejected the majority’s conclusions concerning the eyewitness examination and the statement.