State of New Jersey v. Samuel Woody
A-0171-23
N.J. Super. Ct. App. Div.Mar 11, 2025Background
- Samuel Woody, a Plainfield police officer, was convicted of second-degree official misconduct and fourth-degree criminal sexual contact for coercing K.C. into exposing herself in exchange for resolving pending criminal charges against her.
- The incident was recorded by the victim, and the recording was used as evidence at trial.
- Woody argued that he had a consensual relationship with K.C., but the jury rejected this defense.
- After unsuccessful direct appeals, Woody's first petition for post-conviction relief (PCR), alleging ineffective assistance of counsel, was denied without an evidentiary hearing and subsequently affirmed on appeal.
- Woody filed a second PCR petition, again alleging ineffective assistance regarding his counsel's failure to investigate and call certain witnesses to support his consensual relationship defense.
- The trial court denied the second PCR petition as time-barred and lacking merit, and this denial was appealed.
Issues
| Issue | State's Argument | Woody's Argument | Held |
|---|---|---|---|
| Timeliness of second PCR petition | Petition was untimely under rules | Exceptional circumstances justified relaxation of one-year limit due to ongoing appellate process | Petition time-barred under Rule 3:22-12 |
| Ineffective assistance: failure to investigate/call witnesses | No new evidence; verdict unchanged | Trial and PCR counsel were ineffective for not calling witnesses and further investigating defense | Claim without merit; no reasonable probability of different outcome |
| Entitlement to evidentiary hearing | No sufficient showing to require | The factual basis for ineffective assistance required a hearing | No hearing required; discretion not abused |
| Application of newly recognized constitutional right | N/A | Claimed entitlement under new constitutional right standards | No new right asserted; rule not relaxed |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance requires showing of deficient performance and prejudice)
- State v. Fritz, 105 N.J. 42 (adopts Strickland standard for New Jersey)
- State v. Jackson, 454 N.J. Super. 284 (clarifies time limits for PCR petitions and grounds for exception)
- State v. Aburoumi, 464 N.J. Super. 326 (standard for review when no evidentiary hearing is held)