Gibbs v. State

Summary

The Supreme Court of Delaware affirmed the denial of Gibbs's second motion for postconviction relief. It held that the Supreme Court's decision concerning counsel in initial-review collateral proceedings did not entitle Gibbs to appointed counsel to relitigate claims already rejected, and that his ineffective-assistance claim remained barred as formerly adjudicated. The court also found no basis to invoke the narrow interest-of-justice exception because Gibbs identified no subsequent legal development, new evidence, or actual-innocence showing.