Medley v. State

Summary

The Delaware Supreme Court affirmed the Superior Court’s denial of Wilbur Medley’s motion to modify his sentence. The court held that Medley was entitled to credit only for 13 days attributable to the specific offense and rejected his claim that the sentencing judge improperly delegated authority to court or Department of Correction personnel. The court also found no plain error in amending the sentence without a hearing because the amendment corrected the credit calculation without changing the imposed term or supervision conditions.

Holdings

1. The Superior Court did not improperly delegate sentencing authority because the record established that Medley was entitled to only 13 days of credit on the burglary case, and the sentencing judge's orders satisfied the statutory credit requirement.
2. The amendment of Medley's sentence without a hearing did not constitute plain error requiring a new sentencing because the amendment corrected the credit to the undisputedly correct 13 days and did not alter the incarceration term or supervision conditions.

Questions Presented

1. Whether the Superior Court improperly delegated its sentencing authority to court administrative staff and Department of Correction personnel when it amended Medley's credit for time served.
2. Whether the Superior Court violated Medley's right to be present with counsel by amending the sentence order without a hearing.

Disposition

affirmed