Jackson v. State

Summary

The Supreme Court of Delaware affirmed the denial of Anthony Jackson’s request for credit against his Delaware sentence for the period he was mistakenly at liberty after New York released him without returning him to Delaware. The court held that credit for erroneous liberty requires negligence by the incarcerating authority, and the record showed no negligence by Delaware officials because New York had custody and made the release. The court did not decide the broader scope of the erroneous-liberty doctrine because the limited briefing and record made that unnecessary.