Supreme Court of Delaware
Smith v. State
August 14, 2025
Summary
The Court affirmed the denial of Smith’s postconviction motion, holding that he failed to establish prejudice from counsel’s objectively unreasonable failure to move to withdraw his guilty plea. Applying the plea-withdrawal factors, the Court concluded that Smith knowingly and voluntarily pleaded guilty, lacked a supported basis for legal innocence, and therefore did not show a reasonable probability that the trial court would have permitted withdrawal. The Court had already resolved the separate claim concerning counsel’s advice to plead guilty and addressed only the remaining prejudice issue here.