Brooks v. Denn

Summary

The Supreme Court of Delaware affirmed dismissal of Brooks’s civil complaint seeking mandamus and declaratory relief to obtain records allegedly withheld in violation of Brady. The Court held that a claim seeking documents for the purpose of overturning criminal convictions must be brought exclusively under Rule 61, and Brooks could not use a civil action to avoid Rule 61’s requirements. The Court granted the State’s motion to affirm because the appeal was plainly without merit on the face of the opening brief.