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Womack v. State

IN THE SUPREME COURT OF THE STATE OF DELAWARE

RAQUAN WOMACK,

Defendant Below, Appellant,

STATE OF DELAWARE,

Appellee.

§ No. 94, 2026 §

§ Court Below-Superior Court § of the State of Delaware §

§ Cr. ID No. 2006006269 §

Submitted: September 23, 2026 Decided: October 1, 2026 Before TRAYNOR, GRIFFITHS, and ZURN, Justices.

ORDER

After careful consideration of the parties' briefs and the record on appeal, we find it evident that the judgment below should be affirmed on the basis of and for the reasons stated in the Superior Court's Amended Order dated February 4, 2026.¹

1 We clarify that Cronic applies only in narrow circumstances—when the adversarial process has actually broken down such that prejudice is presumed. United States v. Cronic, 466 U.S. 648, 658-59 (1984). In Cooke, we explained that Cronic applies in three situations: (1) the complete denial of counsel; (2) counsel's total failure to subject the State's case to meaningful adversarial testing; and (3) representation under circumstances in which even competent counsel likely could not provide effective assistance. Cooke v. State, 977 A.2d 803, 848 (Del. 2009) (citing Cronic, 466 U.S. 648, 659-62). In Cooke, we addressed the second circumstance. Trial counsel pursued an "independent and inconsistent strategy" of conceding Cooke's guilt and seeking a guilty-but-mentally-ill verdict. We held that this strategy caused a breakdown in the adversarial process because counsel: (1) did not advance Cooke's stated objective of a not-guilty verdict and (2) in pursuing counsel's own

NOW, THEREFORE, IT IS ORDERED that the judgment of the Superior Court is AFFIRMED.

BY THE COURT:

/s/ N. Christopher Griffiths Justice

inconsistent objective, failed to subject the State's case to meaningful adversarial testing. Id. at 849-50.

We therefore do not read Cooke or Cronic to require a defendant to show that counsel

"completely [went] against [his wishes] and plead[ed] him guilty . . . on every charge." State v. Coleman, 341 A.3d 508, 2024 WL 3413459, at *8 (Del. Super. Ct. July 15, 2024) (TABLE). Although we affirmed the Superior Court's judgment in Coleman, we did not adopt its broader articulation of when Cronic applies. The controlling inquiry remains whether counsel's conduct produced the kind of actual breakdown of the adversarial process that Cronic contemplates.

Womack v. State

Womack v. State

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