A Delaware court has dismissed a fourth motion for postconviction relief filed by Michael D. Broomer, who was convicted in connection with a 2015 shooting that resulted in the death of Raekwan Mangrum. The court's decision, issued on October 15, 2026, means Broomer will not have the opportunity to challenge his conviction based on claims of newly discovered evidence or to conduct forensic testing on evidence from the case.
The ruling affects Broomer, who has been seeking to overturn his conviction for Murder in the Second Degree and related charges. The court's decision emphasizes the procedural bars that limit the ability of defendants to file successive motions for postconviction relief without new and compelling evidence.
Background
Broomer was charged alongside co-defendant Atiba Mayfield for the shooting death of Mangrum on April 4, 2015. The prosecution argued that Broomer was the driver of the vehicle used in a drive-by shooting, while Mayfield was the shooter. Broomer did not dispute his role as the driver but claimed he lacked the intent to commit murder.
Following separate trials, Mayfield was convicted of Murder in the First Degree, while Broomer was found guilty of Murder in the Second Degree. Since his conviction, Broomer has filed multiple motions for postconviction relief, with his latest being the fourth such motion. In this motion, he claimed that the discovery of a new witness, Tyrie Burton, could prove his actual innocence.
The Ruling
The court ruled that Broomer's fourth motion for postconviction relief should be summarily dismissed. The court stated, "The actual innocence exception cannot be satisfied by new testimony that only bolsters a defendant’s justification and/or self-defense claims." The court noted that Broomer could not prove that someone other than himself or his co-defendant committed the crime.
Additionally, the court denied Broomer's request to transport evidence for forensic testing, specifically gunshot residue (GSR) testing on the victim's clothing. The court emphasized that the lack of GSR testing was known to Broomer at the time of his trial and did not constitute newly discovered evidence.
Impact
This ruling signifies a continued emphasis on procedural requirements in postconviction motions. Defendants must provide compelling evidence to overcome the barriers of successive motions. Broomer's case serves as a reminder that claims of newly discovered evidence must demonstrate actual innocence, not merely challenge intent or state of mind.
The court's decision may discourage future motions based on similar claims unless defendants can present substantial new evidence that meets the stringent criteria set forth by the court. This ruling reinforces the importance of procedural rules in the criminal justice system.
What's Next
Broomer has limited options for appeal, as the court has dismissed his motions based on procedural grounds. There are no related cases pending that would affect this ruling. Further legal action would require new evidence or a significant change in circumstances.