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Brittingham v. State

Supreme Court of Delaware
Jan 23, 1998
705 A.2d 577 (Del. 1998)

Summary

holding narrow purpose of Rule 35 is correcting an illegal sentence, not re-examining errors in pre-sentence proceedings

Summary of this case from Dupree v. State

Opinion

Nos. 228 and 336, 1997.

Submitted: January 13, 1998.

Decided: January 23, 1998.

Upon appeal from the Superior Court. AFFIRMED.

Court Below — Superior Court of the State of Delaware, in and for New Castle County, Cr.A. No. 91-01-1009.

Edward A. Brittingham, pro se.

Sam Glasscock, III, of the Department of Justice, for appellee.

Before WALSH, HOLLAND, and HARTNETT, JJ.


The defendant-appellant, Edward A. Brittingham ("Brittingham"), was found guilty of Burglary in the Second Degree by a New Castle County jury on September 18, 1991. He was declared to be an habitual criminal and sentenced to fifteen years of incarceration. Brittingham's conviction and sentence were affirmed on appeal by this Court. Brittingham v. State, Del.Supr., No. 486, 1991, Veasey, C.J., 1992 WL 219205 (July 31, 1992) (ORDER). Brittingham filed a motion for postconviction relief. This Court affirmed the Superior Court judgment denying that motion. Brittingham v. State, Del.Supr., No. 25, 1995, Berger, J., 1995 WL 715837 (Nov. 8, 1995)(ORDER).

Brittingham then sought further review of the determination that he is an habitual criminal by filing two Motions to Correct an Illegal Sentence with the Superior Court. See Super.Ct.Crim.R. 35(a) ("Rule 35(a)"). These motions were denied by the Superior Court on April 28, 1997, and July 16, 1997. Brittingham has appealed from those judgments. This Court has consolidated the appeals.

Relief is Limited Criminal Rule 35(a)

Rule 35(a) permits the Superior Court to correct an illegal sentence "at any time." Cf. Super.Ct.Crim.R. 61(i)(1). The "narrow function of Rule 35 is to permit correction of an illegal sentence, not to re-examine errors occurring at the trial or other proceedings prior to the imposition of sentence." Hill v. United States, 368 U.S. 424, 430, 82 S.Ct. 468, 472, 7 L.Ed.2d 417 (1962). "A proceeding under Rule 35 presupposes a valid conviction." Whitfield v. United States, 9th Cir., 401 F.2d 480, 483 (1968). Accord Evans v. State, Wyo.Supr., 892 P.2d 796, 797 (1995): State v. Meier; N.D.Supr., 440 N.W.2d 700, 703 (1989). Relief under Rule 35(a) is available "when the sentence imposed exceeds the statutorily-authorized limits, [or] violates the Double Jeopardy Clause. . . ." United States v. Pavlico, 4th Cir., 961 F.2d 440, 443 (1992). A sentence is also illegal if it "is ambiguous with respect to the time and manner in which it is to be served, is internally contradictory, omits a term required to be imposed by statute, is uncertain as to the substance of the sentence, or is a sentence which the judgment of conviction did not authorize." United States v. Dougherty, 10th Cir., 106 F.3d 1514, 1515 (1997).

Brittingham was found guilty of Burglary in the Second Degree, a felony. The Superior Court then determined that Brittingham had at least three prior felony convictions. Accordingly, Brittingham was found to be an habitual offender. As an habitual offender, he was eligible by statute for a sentence of up to life imprisonment. 11 Del. C. § 4214(a). Brittingham was sentenced to fifteen years imprisonment.

Brittingham does not contend that this sentence was outside of the statutory authorization or constituted double jeopardy. The only contentions in his Rule 35(a) motions involved the validity of his felony convictions in 1983 and 1986. Because those claims would require an examination of "errors occurring at . . . other proceedings prior to the imposition of the sentence," no relief is available to Brittingham under Rule 35(a). Hill v. United States, 368 U.S. at 430, 82 S.Ct. at 472-73.

Law of Case Illegal Sentences

The proceedings leading to Brittingham's conviction, including the validity of the Superior Court's determination of his habitual criminal status, were reviewed by this Court and rejected in Brittingham's direct appeal. Brittingham v. State, Del.Supr., No. 486, 1991, Veasey, C.J., 1992 WL 219205 (July 31, 1992) (ORDER). Thereafter, in his first motion for postconviction relief under Superior Court Criminal Rule 61 ("Rule 61"), Brittingham raised the same challenges to his habitual offender status that he advanced in the Rule 35(a) motions which are the subject of this appeal: (1) the alleged invalidity of his 1986 conviction based on trial judge's supposed conflict of interest; and (2) the alleged invalidity of his 1983 conviction based on the supposed coercion of his guilty plea. This Court affirmed the Superior Court's denial of Brittingham's Rule 61 motions, finding that his claims were procedurally barred and that Brittingham had failed to demonstrate that he was entitled to relief on the merits in the interest of justice. Brittingham v. State, Del.Supr., No. 25, 1995, Berger, J., 1995 WL 715837 (Nov. 8, 1995)(ORDER).

The "law of the case" doctrine is well established in Delaware. See, e.g., Bailey v. State, Del.Supr., 521 A.2d 1069, 1093 (1987); Hughes v. State, Del.Supr., 490 A.2d 1034, 1048 (1985); State v. Halko, Del.Super., 188 A.2d 100, 107-08 (1962). That doctrine bars relitigation, under Rule 35(a), of an "illegal sentence" where that issue has been previously decided by this Court.

The doctrine of law of the case is flexible (unlike res judicata, which is both inflexible and inapplicable to many post-conviction motions, including those based on grounds of double jeopardy . . .). It will not be enforced where doing so would produce an injustice. But it does apply to Rule 35 unless some reason is shown for not applying it, and none was here.
United States v. Mazak, 7th Cir., 789 F.2d 580, 581 (1986) (citations omitted). Brittingham cannot continue to litigate previously decided issues by changing the number of the Superior Court rule under which he seeks postconviction relief. See Super.Ct.Crim.R. 61(i)(1),(3),(4); Bailey v. State, 521 A.2d at 1095. See also Trans World Airlines, Inc. v. Hughes, Del. Ch., 317 A.2d 114, 119 (1974), aff'd, Del.Supr., 336 A.2d 572 (1975). The prior decisions by this Court on any adjudicated issue involving Brittingham's claims became the law of the case in all subsequent stages of his continuing criminal proceedings. State v. Halko, 188 A.2d at 107-08.

Conclusion

The Superior Court properly held that Brittingham could not utilize Rule 35(a) to challenge the predicate convictions that were the basis for the determination of his habitual offender status. The judgments of the Superior Court are affirmed.


Summaries of

Brittingham v. State

Supreme Court of Delaware
Jan 23, 1998
705 A.2d 577 (Del. 1998)

holding narrow purpose of Rule 35 is correcting an illegal sentence, not re-examining errors in pre-sentence proceedings

Summary of this case from Dupree v. State

holding that a motion under Rule 35 may not be used to re-examine errors occurring prior to the imposition of sentence

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holding that a motion under Rule 35 may not be used to re-examine errors occurring prior to the imposition of sentence

Summary of this case from Lake v. State

holding that a motion under Rule 35 may not be used to re-examine errors occurring prior to the imposition of sentence

Summary of this case from Lake v. State

holding that the narrow function of a Rule 35 motion is to determine the legality of the sentence not to reexamine errors occurring in proceedings, including habitual offender hearings, prior to the imposition of sentence

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holding that a defendant cannot continue to litigate previously decided issues simply by changing the number of the court rule pursuant to which he seeks relief

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holding that law of the case doctrine bars relitigation, under Rule 35, of an "illegal sentence" where that issue has been previously decided

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holding that correction of a sentence is available, among other situations, "when the sentence imposed exceeds statutorily authorized limits"

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concluding that challenges to validity of convictions were outside scope of Rule 35

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concluding that challenges to validity of convictions were outside scope of Rule 35

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concluding that challenges to validity of convictions were outside scope of Rule 35

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concluding that challenges to validity of convictions were outside scope of Rule 35

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recognizing narrow function of Rule 35 is to correct illegal sentence, not to re-examine errors at trial

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stating that a sentence is illegal if it exceeds statutory limits, violates double jeopardy, is ambiguous with respect to the time and manner in which it is to be served, is internally contradictory, omits a term required to be imposed by statute, is uncertain as to its substance, or is a sentence that the judgment of conviction did not authorize

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explaining the narrow function of Rule 35 and that it is "not to re-examine errors occurring at the trial or other proceedings prior to the imposition of sentence"

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providing that relief under Rule 35 is available when the sentence imposed violates the double jeopardy clause

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providing that Rule 61 provides the exclusive remedy for a collateral attack upon a criminal conviction

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describing purpose of rule as to permit correction of illegal sentence, not to reexamine errors before imposition of sentence

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describing purpose of rule as to permit correction of illegal sentence, not to reexamine errors before imposition of sentence

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discussing the “law of the case” doctrine in the context of a Rule 35 claim

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discussing "law of the case" doctrine

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providing when relief is available under Rule 35

Summary of this case from Russ v. State

noting that relitigation of an issue is precluded when the appellate court previously has decided the issue

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discussing the limited circumstances where relief is available under Rule 35

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noting that "`the narrow function of Rule 35 is to permit correction of an illegal sentence, not to re-examine errors occurring at the trial or other proceedings prior to the imposition of sentence.'"

Summary of this case from STATE v. SERFUDDIN EL
Case details for

Brittingham v. State

Case Details

Full title:Edward BRITTINGHAM, Defendant Below, Appellant, v. STATE of Delaware…

Court:Supreme Court of Delaware

Date published: Jan 23, 1998

Citations

705 A.2d 577 (Del. 1998)

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