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subpoenaappealhearingtrialmotionprobationpublic defender
subpoenaappealhearingtrialaffidavitprobation

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Guinn v. State, 882 A.2d 178

Facts

During the evening of July 27, 2002, police officer Paul D. Kuntzi and probation officer Douglas Watts observed Nathan Guinn walking with his brother, Samuel Ingram, and stopped him for being out past his probation curfew. Guinn was arrested after being found in possession of cash and suspected crack cocaine. He was represented by public defenders during his trials, ultimately being convicted of multiple drug offenses and sentenced to thirty-six years, suspended after sixteen years and nine months for probation. Guinn later filed a motion for postconviction relief alleging ineffective assistance of counsel, among other claims.

During the evening of July 27, 2002, police officer Paul D. Kuntzi and probation officer Douglas Watts were on patrol in the vicinity of Reed and South New Streets in Dover, Delaware, when they observed Guinn walking toward their car. Guinn was in the company of his brother, Samuel Ingram. Kuntzi and Watts stopped Guinn, who was out past his probation curfew and was wanted for an outstanding capias. The officers placed Guinn in handcuffs and searched him, seizing $424 cash, a piece of suspected crack cocaine and a small screwdriver. Guinn was then placed under arrest and was later charged with Possession with Intent to Deliver, Possession within 300 Feet of a Church, Possession of Cocaine, and Possession of Drug Paraphernalia.

Issue

Did Guinn's defense counsel render ineffective assistance by failing to interview or subpoena certain witnesses and by not seeking a continuance at a suppression hearing?

Did Guinn's defense counsel render ineffective assistance by failing to interview or subpoena certain witnesses and by not seeking a continuance at a suppression hearing?

Rule

To prevail on a claim of ineffective assistance of counsel, a movant must show that his counsel's representation fell below an objective standard of reasonableness, and that but for his counsel's errors, the outcome of the trial would have been different.

To prevail on a claim of ineffective assistance of counsel, a movant must show that his counsel's representation fell below an objective standard of reasonableness, and that but for his counsel's errors, the outcome of the trial would have been different.

Analysis

The court analyzed Guinn's claims of ineffective assistance of counsel by reviewing the record and the actions taken by his defense counsel. It found that Guinn had not shown that his counsel's decisions were unreasonable or that they prejudiced his case. Specifically, the court noted that Guinn had previously indicated he did not want his brother to testify, and that the absence of the police officer at the suppression hearing did not affect the outcome.

Guinn has not demonstrated that Dean was unreasonable and unprofessional or that he was prejudiced as a result Dean's alleged ineffectiveness. The record, specifically a file memorandum written by Harpster that Dean attached to her affidavit, reflects that Ingram spoke to Harpster prior to Guinn's first trial and denied having any 'knowledge of the cocaine found in the shorts Mr. Guinn was wearing.' Moreover, Harpster's memorandum reflects that Guinn 'indicated he did not want Mr. Ingram to testify and wanted to proceed with the defense that the drugs found on his possession was consistent with simple possession.'

Conclusion

The Supreme Court affirmed the judgment of the Superior Court, concluding that Guinn's appeal was without merit and that the claims of ineffective assistance of counsel did not warrant relief.

It is manifest on the face of Guinn's opening brief that the appeal is without merit. The issues presented on appeal are controlled by settled Delaware law.

Who won?

State of Delaware; the state prevailed because the court found that Guinn's claims of ineffective assistance of counsel were without merit and did not demonstrate any prejudice.

The State of Delaware; the state prevailed because the court found that Guinn's claims of ineffective assistance of counsel were without merit and did not demonstrate any prejudice.

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