Parham v. State

Summary

The Supreme Court of Delaware affirmed the denial of George Parham's motion to correct his sentence. The court held that his challenge to the manner in which his sentence was imposed was time-barred, could not be reviewed without the sentencing transcript, and lacked merit because his alcohol-related reckless-driving convictions counted as prior offenses for felony DUI sentencing. The court also found no plain error in the alleged failure to conduct a separate repeat-offender hearing because Parham had notice of the State's intent to seek fifth-offense sentencing.