Tucker v. State

CourtSupreme Court of Delaware
DecidedJanuary 23, 2025
Docket150, 2024
StatusPublished

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

Bluebook
Tucker v. State, (Del. 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

OSCAR TUCKER, § § No. 150, 2024 Defendant Below, § Appellant, § Court Below–Superior Court § of the State of Delaware v. § § Cr. ID No. K2211005937 STATE OF DELAWARE, § § Appellee. §

Submitted: November 6, 2024 Decided: January 23, 2025

Before SEITZ, Chief Justice; VALIHURA, TRAYNOR, LEGROW, and GRIFFITHS, Justices, constituting the Court en Banc.

ORDER

On this 23rd day of January 2025, after careful consideration of the parties’

briefs and the record on appeal, and after oral argument, it appears to the Court that:

(1) A jury convicted the appellant, Oscar Tucker, of one count of

continuous sexual abuse of a child and three counts of unlawful sexual contact. The

convictions stemmed from years of sexual abuse that Tucker committed against his

wife’s minor daughter. In the six-month period between the grand jury’s original

indictment of Tucker and his trial in the Superior Court, the indictment was modified

four times, twice by re-indictment and twice by amendment during Tucker’s trial.

Thus, the jury’s verdict was returned on the fifth iteration of Tucker’s indictment. (2) Tucker challenges his convictions on appeal based primarily on the

serial errors in the indictment. As explained below, we have concluded that the

manner in which the State continuously—and, in some instances erroneously—

revised the indictment was sufficiently prejudicial as to warrant reversing Tucker’s

three unlawful-sexual-contact convictions. Because that prejudice did not extend to

the continuous-sexual-abuse count, we affirm that conviction.

(3) In 1996, Tucker met and married his wife.1 After the couple married,

they moved into a home in Dover, Delaware with Tucker’s wife’s four children. 2

When the family first started to reside together, one of the children—T.A.—was

twelve years old.3 T.A. testified that, during the time she lived in the home, Tucker

touched her vaginal area and “kiss[ed] her breasts” on multiple occasions.4 He also

“rubb[ed] his erect penis” and “ejaculated” on her “numerous” times. 5 The alleged

abuse began when T.A. was twelve or thirteen years old and continued until she was

in tenth or eleventh grade.6

1 App. to Opening Br. at A159–61. 2 Id. at A143–45. 3 Id. at A144–45. T.A.’s birthday is April 21, 1984. Id. at A159. 4 Id. at A145–47. 5 Id. at A148. 6 Id.

2 (4) Decades later, T.A. reported the sexual abuse to the police. Tucker was

arrested and a New Castle County grand jury returned the initial indictment in April

2023.7 It contained seven counts, which can be summarized as follows:

Count 1: Continuous sexual abuse of a child in violation of 11 Del. C. § 778(a), alleging that between September 1, 1996 through April 21, 1998, Tucker intentionally engaged in three or more acts of sexual conduct with T.A., who was under the age of fourteen, and the acts occurred over a period of time greater than three months in duration.

Count 2: Rape in the fourth degree in violation of 11 Del. C. § 770(a)(3), alleging that on or about September 1, 1998, Tucker intentionally engaged in sexual penetration with T.A., who had not yet reached her sixteenth birthday “and/or the penetration occurred without T.A.’s consent” by digitally penetrating T.A.’s vagina without her consent.

Count 3: Unlawful sexual contact in the first degree in violation of 11 Del. C. § 769 (a)(3), alleging that, on or about September 1, 1996, Tucker had sexual contact with T.A, who had not yet reached her thirteenth birthday, by intentionally touching her vagina with his hand.

Counts 4 and 5 both charged unlawful sexual contact in the first degree and mirrored Count 3, except that Count 4 alleged that Tucker intentionally touched T.A.’s breasts with his lips and mouth, and Count 5 alleged that Tucker rubbed his erect penis on T.A.’s body until he ejaculated.8

Count 6: Unlawful sexual contact in the second degree in violation of 11 Del. C. § 768, alleging that, on or about April 21, 1997, Tucker intentionally had sexual contact with T.A., who was less than eighteen years of age, by rubbing his erect penis on T.A.’s body until he ejaculated.

7 See Opening Br. at 1. 8 Count 3 and 4 allege that T.A. was 12 years old at the time of the offense.

3 Count 7 also charges Tucker with unlawful sexual contact in the second degree, and except for the date of the offense—under this count the date is on or about April 21, 1998—is identical to Count 6.

(5) In June 2023, the State sought, and the grand jury returned, a “re-

indictment,” which revised the April indictment by stating in each of the seven

counts that “[t]his count is not based upon repressed memories recovered through

psychotherapy.”9 Then, in July 2023, the State again sought, and the grand jury

returned, another “re-indictment,” this time identifying the offense charged under

Count 2 as unlawful sexual penetration in the third degree, instead of rape in the

fourth degree.10 The first-degree unlawful sexual contact charges in Counts Three,

Four, and Five were also lowered to second-degree unlawful sexual contact.

(6) Issues stemming from the errors in the indictment arose on the first day

of trial. During a plea-rejection colloquy, because of revisions to the Delaware

Criminal Code’s sexual-offense provisions in the nearly three decades since the

charged offenses were allegedly committed, the State could not immediately

determine the minimum mandatory sentence for the unlawful sexual penetration

9 App. to Opening Br. at A6–8. Although the parties do not address the import of the addition of this language, it appears to have been prompted by statute-of-limitations concerns. In 2003, the General Assembly amended 11 Del. C. Section 205 to eliminate time limitations for sexual offenses, except for cases “based upon the memory of the victim that has been recovered through psychotherapy unless there is some evidence of the corpus delicti independent of such repressed memory.” 11 Del. C. § 205, 74 Del. Laws, Ch. 56. 10 App. to Opening Br. at A9–11.

4 charge.11 In another instance, the clerk began reading the charges from the April

indictment until the State interrupted the reading underlying Count Two.12 After

conducting a sidebar with the parties, the court gave the clerk the charges from the

then-current indictment—the July indictment—to read.13

(7) Similar issues arose the following day. After counsel delivered their

opening statements, the trial judge provided research to counsel describing the

legislative history of the statute under which Tucker was charged with unlawful

sexual penetration.14 The trial judge advised counsel that, in 1998, the General

Assembly repealed the unlawful sexual penetration statute, effective September 9,

1998, and replaced it with a fourth-degree rape statute.15 Because the unlawful

sexual penetration count alleged that Tucker committed digital penetration of the

vagina “on or about the 1st day of September 1998”16—a date range that might

include a date after September 9, 1998—the trial judge raised a concern about

whether Count Two was properly charged.

11 Id. at A23–25. 12 Id. at A39. 13 Id. at A39–41. 14 Id. at A136–37. 15 Id.; see also 71 Del. Laws, c. 285, §§ 10, 14 (1998) (replacing unlawful sexual penetration with fourth-degree rape); see also 11 Del. C. § 770 (Revisor’s Note) (“Former §§ 770-772, concerning unlawful sexual penetration in the third, second, first degrees, were repealed by 71 Del. Laws, c. 285, § 10”); see id (“Section 29 of 71 Del. Laws, c.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cruz v. State
990 A.2d 409 (Supreme Court of Delaware, 2010)
Dutton v. State
452 A.2d 127 (Supreme Court of Delaware, 1982)
Keller v. State
425 A.2d 152 (Supreme Court of Delaware, 1981)
State v. Blendt
120 A.2d 321 (Superior Court of Delaware, 1956)
Mayo v. State
458 A.2d 26 (Supreme Court of Delaware, 1983)
Wainwright v. State
504 A.2d 1096 (Supreme Court of Delaware, 1986)
Hoskins v. State
102 A.3d 724 (Supreme Court of Delaware, 2014)
Starling v. State
130 A.3d 316 (Supreme Court of Delaware, 2015)
Stevenson v. State
149 A.3d 505 (Supreme Court of Delaware, 2016)
King v. State
239 A.2d 707 (Supreme Court of Delaware, 1968)
Michaels v. State
970 A.2d 223 (Supreme Court of Delaware, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
Tucker v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tucker-v-state-del-2025.