Womack v. State
CourtSupreme Court of Delaware
Date FiledOctober 1, 2026
Docket94, 2026
StatusPublished
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Full Opinion
IN THE SUPREME COURT OF THE STATE OF DELAWARE
RAQUAN WOMACK, §
§ No. 94, 2026
Defendant Below, §
Appellant, § Court Below–Superior Court
§ of the State of Delaware
v. §
§ Cr. ID No. 2006006269
STATE OF DELAWARE, §
§
Appellee. §
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.
2