Ezra Pendleton, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The court affirmed Pendleton’s conviction, holding that a probation officer substantially complied with departmental requirements for an administrative search even though he did not complete a physical pre-search checklist. The officer orally considered the checklist factors, obtained supervisory approval, and had reasonable suspicion based on Pendleton’s prior positive drug tests and probation violations. The court declined to invalidate the search for a technical deficiency. No separate opinions were issued.