Supreme Court of Delaware
Bass v. State
June 20, 2023
Summary
The Delaware Supreme Court affirmed denial of Bass’s seventh postconviction motion. It held that the later-disclosed limitations on microscopic hair-comparison testimony constituted new evidence, but that the evidence did not create a strong inference of factual innocence or probably change the trial result when considered with the remaining evidence. The court explained that actual-innocence relief does not require identifying a specific alternative perpetrator, but does require evidence probative of the defendant’s factual innocence.