Delaware v. Flowers

The State appealed the grant of post-conviction relief to defendant-appellee Damone Flowers. The Superior Court recognized that Flowers post-conviction motion was untimely under Criminal Rule 61(i)(1) because he filed it three years after his conviction became final. However, the Superior Court invoked an exception to the procedural bars as a basis for addressing Flowers' motion on the merits. At the time of Flowers' second motion for relief, the bars to relief in Rule 61(1)(1)-(3) did not apply "to a colorable claim that there was a miscarriage of justice because of a constitutional violation that undermined the fundamental legality, reliability, integrity or fairness of the proceedings leading to the judgment of conviction." After its review, the Supreme Court concluded Flowers' second motion for relief was indeed untimely and that the exception was improperly invoked by the Superior Court. Accordingly, the Court reversed the Superior Court.