Victor Rodriguez, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The Supreme Court of Delaware affirmed the denial of Rodriguez’s postconviction motion, holding that none of his ineffective-assistance claims satisfied the required deficiency-and-prejudice standard and that the Superior Court did not abuse its discretion in denying funding or evidentiary hearings. The court rejected challenges concerning testimony about the fires, the timing of counsel’s opening statement, the failure to seek a mistrial or suppress evidence, and the State’s arson experts. Chief Justice Strine, concurring, agreed that Rodriguez failed to show prejudice and that affirmance was proper, but disagreed that counsel’s unexplained delay in making an opening statement could be characterized as a reasonable strategic decision.