Bradley v. Delaware
Earl Bradley petitioned the Supreme Court for postconviction relief. He was convicted on fourteen counts of first-degree rape, five counts of second-degree assault and five counts of sexual exploitation of a child. Bradley was sentenced to fourteen mandatory life sentences and 164 years at Level V imprisonment. In a 2012 direct appeal, Bradley argued that the search warrant for his former medical practice, BayBees Pediatrics, P.A., was defective because the affidavit in support of the search warrant application did not allege facts establishing probable cause that the medical files of certain patients would be found in a white outbuilding on the BayBees Pediatrics property, would be contained in digital format, or would relate to the crimes described in the search warrant application. Bradley also asserted that the police exceeded the scope of the search warrant by proceeding with a general search to locate and seize evidence without probable cause. The Delaware Supreme Court rejected those claims.
Bradley raised three issues in this appeal: (1) the Superior Court erred when it denied his request for an evidentiary hearing and held that State action did not deprive him of his right to choice of counsel; (2) the Superior Court erred when it held that his trial and appellate counsel were not ineffective when they failed to object to the presentation of evidence outside of the four corners of the search warrant; and (3) the Superior Court erred in finding that his trial and appellate counsel litigated, in an effective and professionally reasonable manner, the claim that the police had performed an unrestricted search of his property in violation of the federal and state Constitutions. Finding no reversible error, the Supreme Court affirmed the Superior Court's denial of postconviction relief. View "Bradley v. Delaware" on Justia Law