Supreme Court of Delaware

Grim v. State

August 5, 2019

Summary

The Supreme Court of Delaware affirmed the Superior Court's order imposing a two-year Level V sentence followed by six months of Level IV home confinement for Grim's probation violation. The court held that Grim's conflict-of-interest claims could not be reviewed without the VOP-hearing transcript and were waived because they were not fairly presented below. It also held that the statutory six-month transition period could be added to the maximum Level V sentence available on the underlying offense.