Richardson v. State

Summary

The Supreme Court of Delaware affirmed the denial of Richardson’s third motion for postconviction relief, but on a different ground than the Superior Court. The Court held that the motion was procedurally barred because it was successive, repeated a previously adjudicated claim, and did not satisfy any exception for new evidence, a retroactive constitutional rule, or lack of jurisdiction. The Court did not decide whether post-sentence sex-offender registration constitutes custody or a collateral legal disability, and noted that Richardson’s later conviction made the challenged registration requirement effectively without consequence.