Farrow v. State

Summary

The Delaware Supreme Court affirmed the denial of James M. Farrow’s motion for credit against his Delaware sentence. The court held that, under the Interstate Agreement on Detainers, Farrow’s Delaware sentence did not begin until he completed his Maryland sentence and that time credited against the Maryland sentence was not also creditable against the Delaware sentence.

Holdings

1. Farrow's Delaware sentence did not begin to run until he completed his Maryland sentence because, while temporarily in Delaware under the Interstate Agreement on Detainers, he remained in the custody of and subject to the jurisdiction of Maryland.
2. Farrow was not entitled to additional credit against his Delaware sentence for the time spent in Delaware answering the charges because that time had already been credited against his Maryland sentence.
3. The appeal was manifestly without merit on the face of the opening brief because the issues were controlled by settled Delaware law, and the Superior Court's judgment was affirmed.

Questions Presented

1. Whether Farrow's Delaware sentence began to run while he was temporarily in Delaware under the Interstate Agreement on Detainers before completing his Maryland sentence.
2. Whether Farrow was entitled to additional credit against his Delaware sentence for time spent in Delaware answering the Delaware charges when that time had already been credited against his Maryland sentence.
3. Whether the appeal was manifestly without merit under Supreme Court Rule 25(a).

Disposition

affirmed