State v. Hudson

CourtSuperior Court of Delaware
DecidedApril 30, 2025
Docket1104009274
StatusPublished

This text of State v. Hudson (State v. Hudson) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Hudson, (Del. Ct. App. 2025).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

STATE OF DELAWARE, ) ) Plaintiff, ) ) ) v. ) Crim. ID. No. 1104009274 ) ) WILLIAM HUDSON, ) ) Defendant. )

Submitted: January 30, 2025 Decided: April 30, 2025

COMMISSIONER’S REPORT AND RECOMMENDATION THAT DEFENDANT’S MOTION FOR POSTCONVICTION RELIEF SHOULD BE SUMMARILY DISMISSED

Annemarie Hayes, Esquire, Deputy Attorney General, Department of Justice, Wilmington, Delaware, Attorney for the State.

William Hudson, James T. Vaughn Correction Center, Smyrna, Delaware, pro se.

SALOMONE, Commissioner This 30th day of April, 2025, upon consideration of Defendant’s Second

Motion for Postconviction Relief and the record in this case, it appears to the Court

as follows:

BACKGROUND AND PROCEDURAL HISTORY

Defendant William Hudson (“Hudson” or “Defendant”) was arrested on April

12, 2011, and charged with multiple offenses relating to allegations of sexual abuse

of a minor (“the minor”).1 Hudson was initially indicted on August 1, 2011,2 and

then reindicted on October 24, 20113 and charged with the following offenses: (i)

one (1) count of Endangering the Welfare of a Child; (ii) one (1) count of Continuous

Sexual Abuse of a Child; (iii) two (2) counts of Invasion of Privacy; and (iv) twenty-

five (25) counts of First Degree Sexual Abuse of a Child by a Person in a Position

of Trust. These charges stemmed from allegations of sexual abuse which occurred

from approximately 2008 to 2011.4

A jury trial was held over a six-day period from January 31, 2012 to February

7, 2012.5 At its conclusion, the jury found Hudson guilty of all counts.6 Prior to

1 Docket Index 1, Adult Complaint and Warrant. For purposes of this Report and Recommendation, all docket item references relate to Superior Court Criminal Docket, State v. Hudson, Case No. 1104009274 (hereinafter, “D.I. __”). The phrase “the minor” will be used throughout this Report and Recommendation in lieu of the victim’s name. 2 D.I. 3. 3 D.I. 12. 4 D.I. 1, Adult Complaint and Warrant, Ex. B. 5 D.I. 23. 6 D.I. 23.

1 sentencing, Hudson moved to dismiss fifteen (15) of the convictions for First Degree

Sexual Abuse of a Child by a Person in a Position of Trust, arguing that the statute,

11 Del. Code § 778, was not enacted until June 30, 2010 and, therefore, those charges

as set forth in Counts II-XVI of the indictment occurring prior to June 30, 2010 could

not stand.7 This Court held argument on the motion on October 31, 2012,8 and the

State provided a supplemental response on January 28, 2013.9

On January 30, 2013, Hudson was sentenced to a total of 122 years of

unsuspended prison time on the charges that were unrelated to the Motion to

Dismiss.10 The Court deferred sentencing on Counts II-XVI.11 Trial counsel was

substituted and appellate counsel entered his appearance at Hudson’s sentencing.12

On February 19, 2013, this Court wrote to appellate counsel requesting his position

on Counts II-XVI in regard to the Motion to Dismiss.13 On March 22, 2013, the

State entered nolle prosequis on Counts II-XVI of the indictment.14

Hudson filed a direct appeal to the Delaware Supreme Court on February 21,

2013.15 On March 24, 2014, the Delaware Supreme Court affirmed the judgment of

7 D.I. 27, 54. 8 D.I. 29, 30. 9 D.I. 31. 10 Id. 11 Id. 12 D.I. 54. 13 D.I. 33. 14 D.I. 35. 15 D.I. 34.

2 the Superior Court.16 On January 20, 2015, Defendant filed a pro se Motion for

Postconviction Relief (the “First Motion”).17 Then, on April 30, 2015, Defendant

filed a Motion for Appointment of Counsel, which was granted on June 9, 2015.18

The State filed their response to Defendant’s First Motion on April 28, 2015.19

On August 15, 2016, postconviction counsel filed a Motion to Withdraw as

Counsel accompanied by an Appendix.20 Defendant responded to the Motion to

Withdraw and filed a Memorandum of Law in Support of his First Motion on

October 13, 2016.21 Due to a clerical error, Hudson’s trial counsel was not properly

notified of the Court’s scheduling order.22 As a result, trial counsel’s affidavit was

not filed until February 10, 2017.23 The State filed its response to Defendant’s

Memorandum of Law on April 13, 2017,24 and Defendant filed his reply on May 3,

2017.25 Hudson’s First Motion was denied by this Court on September 29, 2017.26

On October 2, 2017, a Superior Court Judge issued a scheduling order for

submissions by Hudson, appellate counsel, and the State regarding claims made in

16 D.I. 42. 17 D.I. 44. 18 D.I. 45, 48. Defendant was assigned Rule 61 counsel on March 24, 2016. D.I. 51. 19 D.I. 46. 20 D.I. 54, 55. 21 D.I. 59, 60. 22 D.I. 62. 23 D.I. 63. 24 D.I. 67. 25 D.I. 68. 26 D.I. 69.

3 Hudson’s Memorandum of Law asserting ineffective assistance of appellate

counsel.27 Shortly thereafter, Hudson filed a pro se supplemental memorandum to

his First Motion elaborating on his claims of ineffective assistance of appellate

counsel.28 On November 20, 2017, appellate counsel filed an affidavit in response

to Defendant’s ineffective assistance of counsel claims, and the State subsequently

responded on January 12, 2018.29 Defendant filed his reply on February 14, 2018.30

On April 25, 2018, a Superior Court Commissioner filed her Report and

Recommendation advising that Defendant’s First Motion should be denied as it

related to his supplemental appellate claims.31 Defendant filed an appeal on

November 1, 2017 after his First Motion was denied, but the Supreme Court

dismissed the appeal without prejudice and instructed Defendant that an appeal

could be filed once the Superior Court had issued its final order.32 On May 7, 2018,

Defendant appealed the Commissioner’s recommendation.33 On July 10, 2018, the

Superior Court adopted the Commissioner’s Report and Recommendation that

Defendant’s First Motion should be denied as to his supplemental appellate claims.34

27 D.I. 70. The Superior Court also found Rule 61 counsel’s motion to withdraw to be moot. D.I. 71. 28 D.I. 72. 29 D.I. 73, 74. 30 D.I. 79. 31 D.I. 81. 32 D.I. 82. 33 D.I. 83. 34 D.I. 85.

4 Defendant filed a notice of appeal of that decision to the Delaware Supreme

Court on July 25, 2018.35 On January 22, 2020, the Delaware Supreme Court

affirmed the judgment of the Superior Court.36 On April 21, 2021, Defendant filed

a Motion for Discovery/Production of Brady Materials, which the Superior Court

denied on October 5, 2021.37 On January 10, 2025, Hudson filed a second Motion

for Postconviction Relief (the “Second Motion”) as well as a Memorandum of Law

in support of that motion.38 The Second Motion was referred to this Commissioner

for a Report and Recommendation on January 30, 2025.39

FACTS

The facts of this case were set forth over the course of a six-day trial and

evidence a disturbing pattern of sexual abuse by the Defendant that occurred over

several years. On April 11, 2011, the minor reported to the Division of Family

Services (“DFS”) that she had been inappropriately touched by Defendant for the

past two years.40 Upon learning this information, a New Castle County police officer

transported the minor to the department to be formally interviewed.41 A New Castle

County detective met with the minor and learned that about two years prior, when

35 D.I. 102. 36 D.I. 105. 37 D.I. 106, 107. 38 D.I. 108, 109. 39 D.I. 112. 40 D.I. 1, Adult Complaint and Warrant, Ex. B. 41 Id.

5 the minor was 12 years old, Hudson bought her a vibrator.42 The minor explained

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State v. Hudson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hudson-delsuperct-2025.