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HB120 • 2025

AN ACT TO NAME THE HILL ON THE WEST BANK OF MILL CREEK LOCATED ON NEW CASTLE PARCEL NUMBER 0803100018 AS “GENERAL WASHINGTON’S HILL OF DECEPTION”.

AN ACT TO NAME THE HILL ON THE WEST BANK OF MILL CREEK LOCATED ON NEW CASTLE PARCEL NUMBER 0803100018 AS “GENERAL WASHINGTON’S HILL OF DECEPTION”.

Enacted

This bill passed the Legislature and reached final enactment based on the latest official action.

Sponsor
Michael Smith
Last action
2025-08-21
Official status
Signed 8/21/25
Effective date
Not listed

Plain English Breakdown

The bill does not provide specific details on how mapmakers will be required or incentivized to use the new name.

Naming a Historical Hill in Delaware

This act names a hill west of Mill Creek, where an important battle took place during the American Revolution, as 'General Washington's Hill of Deception'.

What This Bill Does

  • Names the hill located on New Castle County parcel number 0803100018 as 'General Washington’s Hill of Deception'.

Who It Names or Affects

  • People who live near or visit the area around Mill Creek in Delaware.
  • Historians and those interested in American history.

Terms To Know

Revolutionary War
A war fought between Great Britain and its thirteen colonies, which declared independence as the United States of America from 1775 to 1783.
Deception
Using tricks or misleading information to confuse someone.

Limits and Unknowns

  • The bill does not specify how maps will be updated to include the new name.
  • It is unclear if there are any penalties for failing to label the hill correctly on maps.
  • There are no details about funding or costs associated with implementing this act.

Bill History

  1. 2025-08-21 Delaware General Assembly

    Signed by Governor

  2. 2025-06-26 Delaware General Assembly

    Passed By Senate. Votes: 21 YES

  3. 2025-06-18 Delaware General Assembly

    Reported Out of Committee (Executive) in Senate with 2 Favorable, 4 On Its Merits

  4. 2025-05-08 Delaware General Assembly

    Passed By House. Votes: 35 YES 6 ABSENT

  5. 2025-05-08 Delaware General Assembly

    Assigned to Executive Committee in Senate

  6. 2025-05-07 Delaware General Assembly

    Reported Out of Committee (Administration) in House with 2 Favorable, 3 On Its Merits

  7. 2025-04-15 Delaware General Assembly

    Introduced and Assigned to Administration Committee in House

Official Summary Text

AN ACT TO NAME THE HILL ON THE WEST BANK OF MILL CREEK LOCATED ON NEW CASTLE PARCEL NUMBER 0803100018 AS “GENERAL WASHINGTON’S HILL OF DECEPTION”.
This bill names the hill west of Mill Creek situated on New Castle County parcel number 0803100018 where the Spring Grove Mill House sits as “General Washington’s Hill of Deception”. This is the site of one of the most impactful combat event that occurred on Delaware soil during the Revolutionary War.

Current Bill Text

Read the full stored bill text
Legislation Document

SPONSOR:

Rep. Michael Smith & Sen. Sturgeon

Reps. Burns, Collins, K. Johnson, D. Short; Sens. Hocker, Mantzavinos, Townsend, Wilson

HOUSE OF REPRESENTATIVES

153rd GENERAL ASSEMBLY

HOUSE BILL NO. 120

AN ACT TO NAME THE HILL ON THE WEST BANK OF MILL CREEK LOCATED ON NEW CASTLE PARCEL NUMBER 0803100018 AS “GENERAL WASHINGTON’S HILL OF DECEPTION”.

WHEREAS, on September 8, 1777, General George Washington and his Continental Army were in pursuit of 16,000 British and Hessian forces who were marching from the area of Cooch’s Bridge towards Philadelphia aiming to seize the colonial capital; and

WHEREAS, General Washington’s force of 11,000 Continental soldiers were positioned along the east banks of the Red Clay Creek, west of Newport, expecting the British to march towards the position and give battle; and

WHEREAS, on that day, the British did not advance to General Washington’s position as anticipated; and

WHEREAS, General Washington needed to determine the precise location of the British march in order to reposition his Continental army advantageously for a battle that could end the war in Washington’s favor; and

WHEREAS, from the position at Red Clay Creek, General Washington ordered Brigadier General George Weedon’s brigade to advance in a northwest direction to locate the British; and

WHEREAS, General Weedon’s brigade marched to a hill along the east banks of Mill Creek known as Lieutenant McMichael’s Hill of Eminence overlooking an area known as Spring Grove, from where they observed British forces positioned on the next hill located on the opposite side of Mill Creek where the historic Spring Grove Mill House stands today; and

WHEREAS, gunfire was exchanged throughout the night between the two hills separated by Mill Creek; and

WHEREAS, this combat event would become known as General Weedon’s Foray at Spring Grove, one of the most impactful event that occurred in Delaware during the Revolutionary War; and

WHEREAS, on July 20, 2023, Delaware Public Archives placed historical marker number NCC-264 next to the driveway entrance of the Spring Grove Mill House at 3200 Stoney Batter Road, Wilmington, Delaware commemorating the location as the “Site of General Weedon’s Foray at Spring Grove”; and

WHEREAS, General Washington, suspected that British General Howe’s mission of the foray was to prevent General Washington from finding the 16,000 British forces encamping west of the foray on Limestone Road; and

WHEREAS, General Washington used the foray as a distraction, to secretly ride to Milltown and confirm the location of the British Army, thereby deceiving General Howe into wrongly believing Washington was not aware of the encampment location of the British Army; and

WHEREAS, General Washington’s use of deception during the foray allowed Washington to make strategical adjustments that enabled his forces to reach Chadds Ford in time to create defensive positions in preparation for the Battle of Brandywine on September 11, thus preventing the British from seizing Philadelphia without the strong resistance imposed by the Continental army in the Battle of Brandywine; and

WHEREAS, this boosted France’s level of confidence in General Washington’s ability to fight the war leading to France’s formal recognition of America as a sovereign nation, and France became fully committed to supporting the American cause in the Revolutionary War; and

WHEREAS, French support was a significant factor in the United States of America winning the Revolutionary War; and

WHEREAS, on July 4, 2026, the State of Delaware and the United States of America will be celebrating the American Semiquincentennial, and the identification of significant Revolutionary War events and locations will enhance the experience for all citizens and future generations;

NOW, THEREFORE:

BE IT ENACTED BY THE GENERAL ASSEMBLY OF THE STATE OF DELAWARE:

Section 1. The hill west of Mill Creek where the Spring Grove Mill House sits on New Castle County Parcel number 0803100018 is hereby named “General Washington’s Hill of Deception”.

Section 2. Where appropriate, maps produced depicting General Washington’s Hill of Deception will be labeled as such.

SYNOPSIS

This bill names the hill west of Mill Creek situated on New Castle County parcel number 0803100018 where the Spring Grove Mill House sits as “General Washington’s Hill of Deception”. This is the site of one of the most impactful combat event that occurred on Delaware soil during the Revolutionary War.