Background
Daquan J. Watson appealed from a Delaware Superior Court order denying his motion for postconviction relief. His conviction became final in October 2023.
Watson did not file his postconviction motion until March 2026. On March 13, 2026, the Superior Court denied the motion as time-barred under Superior Court Criminal Rule 61(i)(1), which imposes a one-year procedural bar.
The Court’s Holding
The Delaware Supreme Court granted the State’s motion to affirm and affirmed the Superior Court’s judgment on the basis of its March 13, 2026 order.
The court concluded that Watson’s March 2026 motion was untimely because his conviction had become final in October 2023. It also determined that Watson had not pleaded any circumstances that would overcome Rule 61(i)(1)’s one-year procedural bar.
Key Takeaways
- A motion for postconviction relief filed more than one year after the conviction became final is subject to Rule 61(i)(1)’s procedural bar.
- The movant must plead circumstances sufficient to overcome the one-year bar.
- The Supreme Court affirmed because Watson’s motion was untimely and alleged no basis for avoiding the bar.
Why It Matters
The order underscores the importance of Rule 61’s filing deadline in Delaware postconviction proceedings. Defendants filing outside the one-year period must plead circumstances that overcome the procedural bar or risk denial without review of the motion’s merits.