Supreme Court of Delaware

State of Delaware, Plaintiff-Below, Appellant v. Jermaine Wright, Defendant-Below, Appellee

January 11, 20162016 Del. LEXIS 15

Summary

The Supreme Court of Delaware held that the law-of-the-case doctrine barred the Superior Court from reconsidering the adequacy of the Miranda warnings given before Wright's confession. The original judge's determination that Wright knowingly, voluntarily, and intelligently waived his rights necessarily implied that the warnings were adequate, and no exception based on clear error, manifest injustice, or changed circumstances applied. The court reversed the order dismissing the indictment, held the statement admissible, remanded for further proceedings, and directed reassignment to a different judge.