Supreme Court of Delaware

Woody v. State

September 23, 2019

Summary

The Court affirmed the convictions, holding that the search-warrant affidavit established probable cause under the four-corners and totality-of-the-circumstances tests, including because the older incidents remained within the stalking statute of limitations and electronic evidence was likely to remain available. It also held that the statutory exemption for firearms manufactured before 1973 was an affirmative defense that the defendants had to prove. The Court further upheld the admission of redirect expert testimony concerning the unlikelihood of secondary DNA transfer and rejected the challenge to the denial of judgment of acquittal. No separate opinions were filed.