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IMO the Petition of Devearl Bacon for a Writ of Mandamus

2026-08-27

Summary

Holding. The petition for a writ of mandamus is dismissed because Bacon failed to establish the prerequisites for mandamus relief—specifically, he did not show a clear right to a transcript at state expense or that the Superior Court arbitrarily refused to provide one—and he has adequate alternative remedies available.

Devearl Bacon, an incarcerated litigant, filed a petition for a writ of mandamus seeking to compel the Superior Court to provide him with a docket sheet and a transcript of a hearing in his civil lawsuit. Bacon claimed he needed these materials to determine service status and prepare an appeal. Before the Supreme Court could rule, the Superior Court issued a letter order providing the docket sheet and clarifying that Bacon's request for a transcript at state expense required him to file a proper in forma pauperis motion that included a certified copy of his inmate account statement, which he had failed to provide.

The Supreme Court dismissed the petition, finding that mandamus relief was not warranted. The docket sheet request became moot because the Superior Court had already supplied it. Regarding the transcript, Bacon had not demonstrated a clear right to obtain it at state expense or that the court arbitrarily refused his request. The Court noted that Bacon had an adequate alternative remedy: he could refile his in forma pauperis motion with the required financial documentation, and he could raise any transcript denial in an appeal from a final judgment in the underlying case.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Prerequisites for issuance of a writ of mandamus in Delaware
  • Right to obtain court transcripts at state expense for incarcerated litigants
  • Proper procedures for in forma pauperis motions by incarcerated persons
  • Mootness when relief is provided before appellate decision

Procedural posture

Bacon filed a petition for a writ of mandamus in the Delaware Supreme Court's original jurisdiction seeking to compel the Superior Court to provide a docket sheet and hearing transcript.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

IN THE MATTER OF THE § No. 321, 2026

PETITION OF DEVEARL L. §

BACON FOR A WRIT OF §

MANDAMUS

Submitted: August 20, 2026

Decided: August 27, 2026

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

ORDER

After consideration of the petition for a writ of mandamus and the Superior

Court docket, it appears to the Court that:

(1) The petitioner, Devearl L. Bacon, seeks to invoke the original

jurisdiction of this Court, under Supreme Court Rule 43, to issue a writ of mandamus

to the Superior Court. The relief he seeks relates to a civil lawsuit that Bacon filed

against Mark Purnell and Herbert W. Mondros, Esquire. The civil complaint alleges

that Bacon assisted Purnell with postconviction proceedings that resulted in the

reversal of Purnell’s murder conviction. It alleges that Purnell agreed to pay Bacon

a portion of any funds that Purnell received to resolve a civil claim against the State

arising from his conviction, but Purnell has not done so despite receiving a

settlement payment.

(2) In November 2025, the Superior Court granted Mondros’s motion to

dismiss Bacon’s claims against him. In January 2026, Bacon filed a motion for

default judgment against Purnell. At a hearing on the motion on March 4, 2026, a Superior Court Commissioner denied the motion for default judgment on the ground

that Bacon had not perfected service on Purnell. Bacon then filed a motion seeking

a copy of the order denying the motion for default judgment and a transcript of the

March 4 hearing. The court sent Bacon a copy of the order and directed him that his

transcript request must be accompanied by a motion and affidavit to proceed in

forma pauperis (an “IFP motion”). Bacon filed an IFP motion on March 27, 2026.

On May 6, 2026, Bacon filed a letter requesting a copy of the docket sheet.

(3) In his petition for a writ of mandamus, filed July 27, 2026, Bacon asks

this Court to order the Superior Court to provide him with a copy of the docket sheet

and a transcript of the March 4 hearing on the motion for default judgment. He states

that a docket sheet will help him determine what attempts the sheriff made to serve

Purnell and enable him to seek “other attempts/remedies if [Purnell] has not been

severed [sic].” He further states that he wants a copy of the transcript to support an

appeal once the Superior Court case concludes.

(4) On July 29, 2026, the Superior Court issued a letter order

acknowledging receipt of the mandamus petition. The letter order stated that the

court believed that court staff had previously sent a docket sheet to Bacon but, “in

an abundance of caution,” enclosed a copy of the docket sheet. It further explained

that the IFP motion should have been rejected for filing because it did not include

the necessary financial information. Specifically, the court stated that, because

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Bacon is incarcerated, he was required to include with his IFP motion a certified

copy of his inmate account statement. The court denied Bacon’s IFP motion without

prejudice to his refiling with the required information.

(5) After careful review, we conclude that the petition for a writ of

mandamus is without merit and must be dismissed. A writ of mandamus will issue

only if the petitioner can show: (i) a clear right to the performance of a duty; (ii) that

no other adequate remedy is available; and (iii) that the Superior Court has arbitrarily

failed or refused to perform its duty.1 “[I]n the absence of a clear showing of an

arbitrary refusal or failure to act, this Court will not issue a writ of mandamus to

compel a trial court to perform a particular judicial function, to decide a matter in a

particular way, or to dictate the control of its docket.”2

(6) There is no basis for the issuance of a writ of mandamus here. To the

extent that Bacon seeks a copy of the docket sheet, the matter is moot because the

Superior Court has provided it to him.3 To the extent that he seeks a transcript of the

March 4 hearing, he has not shown that he has a clear right to a copy of the transcript

at state expense or that the Superior Court arbitrarily refused or failed to provide it

1

In re Bordley, 545 A.2d 619, 620 (Del. 1988).

2

Id.

3

See In re Browne, 2002 WL 31106353, at *1 (Del. Sept. 16, 2002) (“To the extent that the Superior Court already has afforded Browne the relief he requests [in his petition for a writ of mandamus], the matter is moot.”).

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to him.4 Nor has he shown that no other adequate remedy is available. He can file

another IFP motion with all required information, as directed by the Superior Court.

And if the court denies his request for the transcript and Bacon is ultimately

unsuccessful in the lawsuit, he can raise the transcript denial in an appeal from the

Superior Court’s final judgment.5

NOW, THEREFORE, IT IS ORDERED that the petition for the issuance of a

writ of mandamus is DISMISSED.

BY THE COURT:

/s/ Collins J. Seitz, Jr.

Chief Justice

4

See id. (“To the extent that Browne seeks a writ of mandamus compelling the Superior Court to provide additional transcripts, he has failed to invoke the original jurisdiction of this Court. Because even an indigent appellant in a civil case does not have an absolute right to transcripts at State expense and the Superior Court had discretion to deny any such request, Browne has failed to demonstrate a clear right to the performance of a duty which the Superior Court has failed or refused to perform.” (footnotes omitted)).

5

In re Stanford, 2019 WL 494456, at *2 (Del. Feb. 7, 2019).

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