Supreme Court of Delaware

Swan v. State

March 1, 2021

Summary

The Supreme Court of Delaware affirmed the Superior Court’s denial of Ralph Swan’s latest motion for postconviction relief and motion to recuse. The Court held that Swan’s numerous ineffective-assistance, Brady, prosecutorial-misconduct, jury-related, evidentiary, actual-innocence, and appellate-review claims were procedurally barred or failed on the merits, including because he could not establish deficient performance, prejudice, or a constitutional miscarriage of justice. The Court also held that the Superior Court acted within its discretion in limiting the evidentiary hearings and denying recusal.