State v. D. Wood

Summary

The court reversed Danielle Wood’s deliberate-homicide conviction and remanded for a new trial. It held that the State lacked sufficient evidence to submit an alternative accountability theory to the jury and that the general verdict form did not allow the jury to identify unanimously and unambiguously which theory supported its guilty verdict. The combined instructional and verdict-form errors were not harmless because they impaired reliable determination of whether Wood personally caused the death or aided another in doing so.