Supreme Court of Delaware

Wheeler v. State

April 11, 2023

Summary

The Supreme Court of Delaware affirmed the denial of Stephen Wheeler’s postconviction motion challenging his waiver of a jury trial. The court deferred to the Superior Court’s credibility findings, concluded that counsel’s advice was not constitutionally deficient, and held that Wheeler failed to show prejudice because the record did not establish that he would have chosen a jury trial absent counsel’s advice. The court also held that the absence of a written waiver did not warrant relief because the argument was procedurally barred and unsupported on the merits.