Supreme Court of Delaware

Durham v. State

May 2, 2018

Summary

The Court affirmed the denial of Durham’s request to proceed pro se and obtain a certificate of eligibility to seek sentence modification under 11 Del. C. § 4214(f). It held that the statute did not make him eligible because his life sentence was imposed through the sentencing judge’s discretionary authority rather than as a mandatory minimum sentence tied to the statutory maximum for the predicate violent felony.