Supreme Court of Delaware
Clark v. State
April 24, 2018
Summary
The Court affirmed the denial of Clark's request for conflict counsel to pursue sentence modification under 11 Del. C. § 4214(f). It held that Clark's fifteen-year habitual-offender sentence did not qualify because the statute applies to a minimum sentence at least equal to the violent felony's statutory maximum, while his sentence exceeded that mandatory minimum through judicial discretion. The Court also held that, because Clark was ineligible for sentence modification, the Superior Court properly denied appointment of counsel.