Wood v. State

CourtSupreme Court of Delaware
DecidedDecember 22, 2025
Docket518, 2024
StatusPublished

This text of Wood v. State (Wood 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
Wood v. State, (Del. 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

BRUCE WOOD, § § No. 518, 2024 Defendant Below, § Appellant, § Court Below–Superior Court § of the State of Delaware v. § § Cr. ID No. 0512020169 (N) STATE OF DELAWARE, § § Appellee. §

Submitted: October 10, 2025 Decided: December 22, 2025

Before SEITZ, Chief Justice; VALIHURA and GRIFFITHS, Justices.

ORDER

After consideration of the parties’ briefs and the Superior Court record, it

appears to the Court that:

(1) Bruce Wood appeals the Superior Court’s denial of his motion for the

correction of an illegal sentence. After careful review of the parties’ arguments, we

affirm the Superior Court’s judgment.

(2) In 2007, a Superior Court jury found Wood guilty of eight counts of

first-degree rape (rape where the victim, CG, 1 had not reached her twelfth birthday

and the defendant was over the age of eighteen) (the “CG Counts”), eight counts of

first-degree rape (rape where the victim, SP, had not reached her sixteenth birthday

1 For ease of reference, we refer to the victims by their initials as we did in Wood’s direct appeal. and the defendant stood in a position of trust) (the “SP Counts”), and two counts of

continuous sexual abuse of a child (“CSAC”)—one count for each victim.

Following a presentence investigation, the Superior Court sentenced Wood to 290

years of incarceration. We affirmed Wood’s convictions and sentence on direct

appeal. 2

(3) Between 2009 and 2017, Wood filed three unsuccessful motions for

postconviction relief.3 Wood also unsuccessfully sought federal habeas relief and a

reduction of sentence. 4

(4) In 2024, Wood filed a motion for the correction of an illegal sentence

under Superior Court Criminal Rule 35(a), arguing his sentence is illegal because:

(i) his sentences for first-degree rape and CSAC violate the Double Jeopardy Clause;

(ii) his sentences for CSAC are “excessive” and premised on false information; (iii)

the Superior Court’s sentencing order does not cite any aggravating factors; and (iv)

the Superior Court sentenced him with a closed mind. The Superior Court denied

the motion, and this appeal followed.

2 Wood v. State, 956 A.2d 1228 (Del. 2008). 3 See Wood v. State, 2010 WL 4735003 (Del. Nov. 22, 2010) (affirming the denial of Wood’s first motion for postconviction relief); Wood v. State, 2011 WL 4396996 (Del. Sept. 21, 2011) (affirming the denial of Wood’s second motion for postconviction relief); Wood v. State, 2018 WL 2383020 (Del. May 24, 2018) (affirming the denial of Wood’s third motion for postconviction relief). 4 See Wood v. Pierce, 2015 WL 308150 (D. Del. Jan. 22, 2015) (denying Wood’s petition for a writ of habeas corpus); Wood v. May, 2021 WL 827186 (D. Del. Mar. 4, 2021) (construing Wood’s petition to reopen as a second petition seeking habeas relief and denying it for lack of jurisdiction). 2 (5) We review the denial of a motion for correction of illegal sentence for

abuse of discretion.5 To the extent a claim involves a question of law, we review

the claim de novo.6 A sentence is illegal if it exceeds statutory limits, violates the

Double Jeopardy Clause, is ambiguous with respect to the time and manner in which

it is to be served, is internally contradictory, omits a term required to be imposed by

statute, is uncertain as to its substance, or is a sentence that the judgment of

conviction did not authorize.7

(6) In his opening brief on appeal, Wood argues: (i) his sentences for first-

degree rape and CSAC violate the Double Jeopardy Clause; (ii) his sentences for

CSAC are illegal because they are “based on demonstrably false 16 counts of rape,”

they exceed the sentencing guidelines recommended by the Sentencing and

Accountability Commission (“SENTAC”), and the sentencing order does not cite

any aggravating factors; (iii) the Superior Court sentenced him with a closed mind;

(iv) the jury instructions were inaccurate and confusing; (v) there was insufficient

evidence to support his convictions; and (vi) trial counsel was ineffective for failing

to file a bill of particulars.

(7) After Wood filed his opening brief, the State moved to affirm the

Superior Court’s judgment on the ground that it was manifest on the face of Wood’s

5 Fountain v. State, 2014 WL 4102069, at *1 (Del. Aug. 19, 2014). 6 Id. 7 Brittingham v. State, 705 A.2d 577, 578 (Del. 1998). 3 opening brief that his appeal was without merit. The Court denied the State’s motion

to affirm and asked the State to address apparent errors in the grand jury’s indictment

because when Wood committed the conduct that formed the basis of the CG Counts:

(i) there was not an offense entitled “first-degree rape” in the criminal code; (ii) then-

extant 11 Del. C. § 773, cited in the indictment, defined the offense of third-degree

unlawful sexual intercourse, a class B or class C felony; and (iii) then-extant Section

775 defined the offense of first-degree unlawful sexual intercourse, a class A

felony.8 In its answering brief, the State concedes that the grand jury’s indictment

contained citation errors as to the CG Counts but argues that Wood was nevertheless

legally convicted and sentenced for first-degree unlawful sexual intercourse of CG.

We agree and briefly elaborate.

(8) Between September 1, 1996, and June 30, 1998, when the jury found

that Wood had sexually abused CG, the criminal conduct commonly referred to as

“rape,” was defined as “first-degree unlawful sexual intercourse” and was codified

at then-extant Section 775. The grand jury indictment incorrectly referred to first-

degree rape (an offense that did not exist when Wood abused CG) and cited Section

773 (which defined the offense of third-degree unlawful sexual intercourse until

September 9, 1998, when it was amended to define the offense of first-degree rape).

8 The General Assembly amended the criminal code before 2000, when Wood began committing the conduct that formed the basis of the SP Counts, and the indictment correctly cited Section 773, which had been amended to define the offense of first-degree rape, for the SP Counts. 4 We conclude that these errors were as to form, however, because the indictment

correctly detailed and put Wood on notice of the essential facts that the State was

required to (and ultimately did) prove to convict him of first-degree unlawful sexual

intercourse under the statutory framework in effect between September 1, 1996, and

June 30, 1998—specifically, that (i) Wood intentionally engaged in sexual

intercourse with CG, (ii) CG was less than 12 years old, and (iii) Wood was older

than 18.9 It follows that, despite the errors in the charging document, the jury found

Wood guilty of eight counts of first-degree unlawful sexual intercourse of CG under

then-extant Section 775 and it was not error for the Superior Court to sentence him

for those convictions.

(9) We turn now to the arguments Wood makes on appeal. As noted above,

we review those claims that Wood raises for the first time before this Court (namely,

that the jury instructions were confusing, that there was insufficient evidence to

support his convictions, and that trial counsel was ineffective) for plain error. There

is no error, plain or otherwise error here—these arguments, which do not concern

9 See Robinson v.

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Related

Mayes v. State
604 A.2d 839 (Supreme Court of Delaware, 1992)
Robinson v. State
600 A.2d 356 (Supreme Court of Delaware, 1991)
Wood v. State
956 A.2d 1228 (Supreme Court of Delaware, 2008)
Wood v. State
29 A.3d 247 (Supreme Court of Delaware, 2011)
Brittingham v. State
705 A.2d 577 (Supreme Court of Delaware, 1998)
Wood v. State
9 A.3d 477 (Supreme Court of Delaware, 2010)
Brochu v. State
133 A.3d 558 (Supreme Court of Delaware, 2016)

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