Boyce v. State

CourtSupreme Court of Delaware
DecidedJanuary 15, 2026
Docket343, 2025
StatusPublished

This text of Boyce v. State (Boyce v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Boyce v. State, (Del. 2026).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

NICHOLAS C. BOYCE, § § No. 343, 2025 Defendant Below, § Appellant, § Court Below—Superior Court § of the State of Delaware v. § § Crim. ID No. 1911011368 (K) STATE OF DELAWARE, § § Appellee. §

Submitted: November 25, 2025 Decided: January 15, 2026

Before SEITZ, Chief Justice; VALIHURA and TRAYNOR, Justices.

ORDER

After consideration of the appellant’s opening brief, the State’s motion to

affirm, the appellant’s motion for leave to reply, and the record on appeal, it appears

to the Court that:

(1) The appellant, Nicholas C. Boyce, filed this appeal from the Superior

Court’s order, dated July 29, 2025, denying his motion for correction of an illegal

sentence. The State has moved to affirm the judgment below on the ground that it

is manifest on the face of Boyce’s opening brief that his appeal is without merit. We

agree and affirm.

(2) In 2021, Boyce pleaded guilty to third-degree burglary and theft of

$1,500 or more. The Superior Court sentenced him as follows: for third-degree burglary, three years of imprisonment with credit for six days previously served,

suspended for one year at Level III probation; for theft of $1,500 or more, two years

of imprisonment, suspended for one year of Level III probation. Since then, Boyce

has been found in violation of probation (“VOP”) several times. Most recently, on

April 4, 2025, the Superior Court found that Boyce had violated probation and

sentenced him as follows: for third-degree burglary, one year, two months, and four

days at Level V, suspended after one year for one year of Level III probation with

GPS monitoring; and for theft, two years at Level V, suspended after one year for

one year of Level III probation with GPS monitoring. The court ordered that the

Level V time for each offense is to be served under 11 Del. C. § 4204(k).

(3) Boyce did not appeal from the VOP adjudication and sentence. In July

2025, however, he filed a motion for correction of illegal sentence. The Superior

Court denied the motion on the grounds that it was barred by the ninety-day time

limitation in Delaware Superior Court Rule of Criminal Procedure 35(b). Boyce has

appealed to this Court.

(4) We review the denial of a motion for sentence correction for abuse of

discretion.1 To the extent the claim involves a question of law, we review the claim

de novo.2 A sentence is illegal if it exceeds statutory limits, violates double jeopardy,

1 Fountain v. State, 2014 WL 4102069, at *1 (Del. Aug. 19, 2014). 2 Id. 2 is ambiguous with respect to the time and manner in which it is to be served, is

internally contradictory, omits a term required to be imposed by statute, is uncertain

as to its substance, or is a sentence that the judgment of conviction did not authorize.3

(5) Boyce contends that the Superior Court illegally enhanced his sentence

by requiring that the nonsuspended portion of the VOP sentence be served day-for-

day under Section 4204(k).4 As to this claim, we agree with Boyce that the Superior

Court erroneously denied his motion as time-barred. A motion for correction of an

illegal sentence is not subject to the time limitation in Rule 35(b).5 Nevertheless, we

affirm the Superior Court’s denial of Boyce’s motion on the basis that the Superior

Court’s imposition of the Section 4204(k) requirement did not make the sentence

illegal.6

(6) When sentencing a defendant for a VOP, the trial court may impose any

period of incarceration up to and including the balance of the Level V time remaining

to be served on the original sentence.7 This Court has held that when the Superior

Court reimposes a suspended sentence or portion thereof following a VOP, the court

3 Brittingham v. State, 705 A.2d 577, 578 (Del. 1998). 4 See 11 Del. C. § 4204(k)(1) (“[T]he court may direct as a condition to a sentence of imprisonment to be served at Level V or otherwise that all or a specified portion of said sentence shall be served without benefit of any form of early release, good time, furlough, work release, supervised custody or any other form of reduction or diminution of sentence.”). 5 See DEL. SUPER. CT. R. CRIM. PROC. 35(a) (“The court may correct an illegal sentence at any time . . . .”). 6 See Unitrin, Inc. v. Am. Gen. Corp., 651 A.2d 1361, 1390 (Del. 1995) (stating that “this Court may affirm on the basis of a different rationale than that which was articulated by the trial court”). 7 11 Del. C. § 4334(c). 3 may require that the sentence be served under Section 4204(k).8 The Superior Court

did not illegally enhance Boyce’s sentence by requiring that he serve it day-for-day,

where the nonsuspended portion of the new VOP sentence did not exceed the term

left suspended in Boyce’s previous sentence.9

(7) Boyce also argues that his sentence violates 11 Del. C. § 3901(d)

because the Superior Court did not state on the record at sentencing that the

sentences for the two offenses would run consecutively. Rather, the sentence order

provided that the sentences are to be served consecutively. We conclude that this

claim is barred by the ninety-day time limitation in Rule 35(b). Section 3901(d)

provides that the Superior Court “shall direct whether the sentence of confinement .

. . shall be made to run concurrently or consecutively with any other sentence of

confinement imposed on such criminal defendant.”10 The statute does not explicitly

provide that the court must state on the record at sentencing whether the sentences

are consecutive or concurrent.11 The VOP sentence order directed that the sentences

8 Ingram v. State, 567 A.2d 868 (Del. 1989). 9 See Woods v. State, 2018 WL 1677240, at *1 (Del. Apr. 5, 2018) (stating that VOP sentence “[r]equiring Woods to serve the six months of unsuspended incarceration in its entirety [under Section 4204(k)] was authorized by statute and was a proper use of the Superior Court’s discretion,” and citing Ingram). On December 15, 2025, Boyce filed a motion for leave to reply to the State’s motion to affirm. The motion is granted to the extent that the Court has considered the arguments in the motion. Boyce argues that invoking Section 4204(k) in a VOP sentence increases the original sentence without the defendant’s having had notice of that possibility when his original sentence was imposed. That argument is unavailing. Ingram was decided more than three decades before Boyce committed his crimes and received his original sentence in this case. 10 11 Del. C. § 3901(d). 11 Until 2014, consecutive sentences were the default—indeed, Section 3901(d) prohibited concurrent terms of imprisonment. See id. (effective to July 8, 2014) (“No sentence of confinement 4 are to be served consecutively, and Boyce did not appeal from the imposition of the

sentence. Boyce’s contention amounts to a claim that the sentence was imposed in

an illegal manner, which was required to be raised within ninety days of

sentencing.12 Boyce has not identified extraordinary circumstances warranting

consideration of this claim outside the ninety-day period.13

(8) Finally, Boyce contends that he should have received credit for time

that he served at Level V and Level IV on charges that were dismissed. Because

Boyce did not raise this issue in his motion in the Superior Court, the record as to

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Related

Ingram v. State
567 A.2d 868 (Supreme Court of Delaware, 1989)
Unitrin, Inc. v. American General Corp.
651 A.2d 1361 (Supreme Court of Delaware, 1995)
Brittingham v. State
705 A.2d 577 (Supreme Court of Delaware, 1998)

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Boyce v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/boyce-v-state-del-2026.