Submitted: January 14, 2015.
Case Closed February 10, 2015.
Court Below: Superior Court of the State of Delaware, in and for New Castle County. Cr. ID 1110018439.
Michael C. Heyden, Esquire (argued), Wilmington, Delaware, for Appellant.
Andrew J. Vella, Esquire (argued), Department of Justice, Wilmington, Delaware, for Appellee.
Before STRINE, Chief Justice; HOLLAND, RIDGELY, VALIHURA, and VAUGHN, Justices (constituting the Court en banc).
STRINE, Chief Justice:
The defendant-appellant, Ira Brown, filed this appeal from a Superior Court order denying his first motion for postconviction relief under Superior Court Criminal Rule 61 (" Rule 61" ). Brown raises two issues on appeal. First, he contends that he is entitled to a new trial based on newly discovered evidence of misconduct at the Office of the Chief Medical Examiner (" OCME" ). Although Brown did not raise this claim in his Rule 61 motion (because the problems at the OCME did not come to light until almost a year after Brown filed his Rule 61 motion), we nonetheless consider this issue on appeal in the interests of justice. Brown's second issue on appeal challenges the Superior Court's 2012 denial of both his oral motion and his written motion to withdraw his guilty plea. Brown could have raised this argument in his Rule 61 motion (or in a timely direct appeal) but did not. This argument thus is waived and procedurally barred, and we do not consider it here.
We find that Brown's first claim has no merit. Under United States v. Ruiz, a court may accept a guilty plea, with its accompanying waiver of various constitutional rights (including the right to a fair trial), even when the defendant does not have full knowledge of the relevant circumstances. A defendant has no constitutional right to receive material impeachment evidence before deciding to plead guilty, and Brown's knowing, intelligent, and voluntary guilty plea waived any right he had to test the strength of the State's evidence against him at trial, including the chain of custody of the drug evidence that he claims he was entitled to receive. When, as here, a defendant like Brown admits that he committed the crime of which he is accused in a valid plea colloquy, Ruiz prevents him from reopening his case to make claims that do not address his actual guilt.
That precedent has sensible application here. The situation at the OCME is, to be sure, disturbing and regrettable. But to date, the investigation has yielded no indication that the OCME scandal involved the planting of false evidence to wrongly convict criminal defendants. Rather, it has mostly consisted of instances where employees stole evidence that they knew to be illegal narcotics for resale and personal use. That is, that misconduct occurred because the drugs tested by the OCME were in fact illegal drugs desired by users. When a defendant like Brown has admitted in his plea colloquy that he possessed heroin and intended to sell it, the OCME investigation provides no logical or just
basis to upset his conviction. We therefore affirm the Superior Court's denial of ...