Supreme Court of Delaware

Calhoun v. State

October 7, 2020

Summary

The Court affirmed Calhoun’s convictions and sentences after independently reviewing the record under the applicable withdrawal procedure. It held that the Superior Court had no obligation to conduct a competency hearing because the record provided no reasonable basis to doubt Calhoun’s competence, and that Calhoun knowingly, intelligently, and voluntarily waived his jury-trial right. The Court also rejected Calhoun’s unpreserved judicial-bias claim under plain-error review because the verdict and record did not demonstrate bias or require recusal.