State v. Woodlin
0709033390
| Del. Super. Ct. | Sep 12, 2017Background
- Defendant Howard E. Woodlin was convicted by a jury (Nov. 17, 2008) of multiple sexual offenses including First‑Degree Rape and was sentenced to life plus additional years with a significant minimum mandatory term. The Delaware Supreme Court affirmed on direct appeal (July 22, 2010).
- A recorded Children's Advocacy Center (CAC) interview of the then‑7‑year‑old victim was played at trial; there was no cross‑examination of that recording at trial. A SANE examination suggested possible vaginal and anal penetration.
- Woodlin filed a timely pro se Rule 61 postconviction motion alleging ineffective assistance of counsel; counsel was later appointed and filed an amended Rule 61 motion raising three ineffective‑assistance grounds (failure to seek a bill of particulars; failure to introduce the SANE report/consult an expert; failure to move for judgment of acquittal on timing elements).
- The Commissioner reviewed the record, trial transcripts, and counsel’s affidavit explaining strategic choices; recommended denial of relief because counsel’s choices were reasonable and Woodlin failed to show prejudice under Strickland.
- The Superior Court adopted the Commissioner’s Report and Recommendation and denied the amended Rule 61 motion (Sept. 12, 2017).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to request a Bill of Particulars | Woodlin: counsel’s omission prevented differentiation of charges and impaired defense | State/Trial counsel: counsel had access to CAC interview and other materials, so a bill was unnecessary | Denied — counsel reasonably declined and no prejudice shown |
| Failure to introduce SANE report / consult expert | Woodlin: counsel should have used physical exam results or an expert to challenge prosecution evidence | State/Trial counsel: withholding the SANE report was a strategic choice because the report contained findings that could support penetration allegations | Denied — strategic decision reasonable and no prejudice shown |
| Failure to move for judgment of acquittal (timing of offenses) | Woodlin: counsel’s alleged failure to move for acquittal (due to no evidence on when offenses occurred) undermined verdict reliability | State: transcript shows counsel did move for judgment of acquittal and court denied it applying standard favoring State | Denied — counsel did move and there was sufficient evidence for trial |
| Procedural sufficiency under Rule 61 | Woodlin: ineffective‑assistance claims excuse procedural default and entitle relief | State: claims must satisfy Strickland (cause and prejudice); movant must make concrete showing of prejudice | Denied — claims fail Strickland; no cause/prejudice to overcome Rule 61 bars |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong test for ineffective assistance: deficient performance and prejudice)
- Murray v. Carrier, 477 U.S. 478 (1986) (ineffective assistance can establish cause for procedural default)
- Albury v. State, 551 A.2d 53 (Del. 1988) (Delaware adoption of Strickland framework)
- Woodlin v. State, 3 A.3d 1084 (Del. 2010) (appellate decision affirming conviction and discussing admission of CAC interview)
- Bailey v. State, 588 A.2d 1121 (Del. 1991) (procedural requirements for postconviction relief under Rule 61)
- Outten v. State, 720 A.2d 547 (Del. 1998) (need for concrete allegations of prejudice in ineffective‑assistance claims)