Supreme Court of Delaware

Washington v. State

April 22, 2025

Summary

The Court affirmed the denial of Washington’s second motion for postconviction relief. It held that the version of Rule 61 in effect when the motion was filed governed, that federal habeas principles did not excuse Delaware’s procedural bars, and that Washington’s proffered affidavits and statements did not create a strong inference of actual innocence. The Court also upheld the denial of discovery and an evidentiary hearing because Washington showed neither good cause nor an abuse of discretion.