Supreme Court of Delaware

Curtis v. State

September 2, 2025

Summary

The Court affirmed the finding that Curtis violated probation because his admissions, GPS records, and other evidence satisfied the preponderance-of-the-evidence standard applicable at a probation-violation hearing. It held that the subsequently enacted probation amendments were not yet effective and did not apply to Curtis. The Court nevertheless remanded for correction because the probation term imposed for CCDI exceeded the applicable one-year statutory limit.