Supreme Court of Delaware
Blackwell v. State
August 15, 2024
Summary
The Court held that Blackwell's falsification of checks before submitting them to the Division of Revenue supported misdemeanor liability for offering a false instrument, not felony liability for tampering with public records, because the checks were not yet public records when altered. The Court also upheld admission of the checks and a tax-agency letter, concluding that the checks were party admissions, the agency established sufficient authentication, and the letter was a non-hearsay request offered to explain Blackwell's response. The judgment was reversed as to the two tampering convictions and affirmed on the remaining counts.