typographical error (Delaware) · Go Syfert
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typographical error in Delaware

10 Delaware opinions name it 3 courts 2012–2025 5 in the last five years

The cases below were cited by Delaware courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Nationwide Emerging Managers, LLC v. Northpointe Holdings, LLCgreen
del · 2015 · cited in 2 Delaware opinions naming this issue, 2020–2020
2 sentences

2020The decision to fix a typographical error in a contract “is tantamount to reforming a contract when it has material consequences.” Nationwide Emerging Managers, LLC. v. Northpointe Holdings, LLC, 112 A.3d 878, 890 (Del. 2015).

2020The decision to fix a typographical error in a contract “is tantamount to reforming a contract when it has material consequences.” Nationwide Emerging Managers, LLC. v. Northpointe Holdings, LLC, 112 A.3d 878, 890 (Del. 2015).

22
Ultimore, Inc. v. Bucala (In re Bucala)green
nysb · 2012 · cited in 1 Delaware opinions naming this issue, 2025–2025
2 sentences

2025See In re Bucala, 464 B.R. 626, 631 (Bankr.

2025Answering Br. 12–14. 179 Id. at 14 (emphasis in original). 180 Id. 181 See id. at 12–14 (citing Bucala, 464 B.R. at 631 (holding that a typographical error in description of collateral still produced a valid security interest). 65 that “[t]he difference between the almost right word and the right word is really a large matter—‘tis the difference between the lightning bug and the lightning.”182 But in this case, the description of the Warrant as being for 1,000,000 shares is not even close.

11
Dahl v. Stategreen
del · 2007 · cited in 1 Delaware opinions naming this issue, 2024–2024
2 sentences

2024“The purpose of an indictment is to put the accused on full notice on what he is called to defend, and to effectively preclude subsequent prosecution for the same offense.”117 The Court is unconvinced that a typographical error in the indictment would have provided a basis for Smith to withdraw his guilty plea.118 Rather, Smith’s statements during the plea colloquy would have provided a much stronger argument for keeping the plea in place.119 As correctly stated by the 116 Appeal to the Commissioner’s Findings of Facts and Recommendations at 2-3. 117 White v. State, 243 A.3d 381 , 408 (Del. 20

2024“The purpose of an indictment is to put the accused on full notice on what he is called to defend, and to effectively preclude subsequent prosecution for the same offense.”117 The Court is unconvinced that a typographical error in the indictment would have provided a basis for Smith to withdraw his guilty plea.118 Rather, Smith’s statements during the plea colloquy would have provided a much stronger argument for keeping the plea in place.119 As correctly stated by the 116 Appeal to the Commissioner’s Findings of Facts and Recommendations at 2-3. 117 White v. State, 243 A.3d 381 , 408 (Del. 20

11
Norman v. Stategreen
del · 2009 · cited in 1 Delaware opinions naming this issue, 2016–2016
1 sentence

2016There was no evidence that a female was present during the 18 Norman v. State, 968 A.2d 27, 30 (Del. 2009) (citing Atkinson, 778 A.2d at 1063). 19 Opening Br.

11
Dishmon v. Fuccigreen
del · 2011 · cited in 1 Delaware opinions naming this issue, 2012–2012
1 sentence

2012It appears that the Superior Court’s use of the word "purchasers” was a typographical error, since the Galantinos were the sellers, not the buyers, of the property. .GMG Capital Investments, LLC v. Athenian Venture Partners I, L.P., 36 A.3d 776, 779 (Del.2012); Dishmon v. Fucci, 32 A.3d 338, 341-42 (Del.2011). .25 Del.

11
GMG Capital Investments, LLC v. Athenian Venture Partners Igreen
del · 2012 · cited in 1 Delaware opinions naming this issue, 2012–2012
1 sentence

2012It appears that the Superior Court’s use of the word "purchasers” was a typographical error, since the Galantinos were the sellers, not the buyers, of the property. .GMG Capital Investments, LLC v. Athenian Venture Partners I, L.P., 36 A.3d 776, 779 (Del.2012); Dishmon v. Fucci, 32 A.3d 338, 341-42 (Del.2011). .25 Del.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Delaware. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Chapman v. California red
scotus · 1967
1 sentence

2025Having carefully considered the context in which the sentence was written, including the Court’s ruling, we are satisfied that the omission of “not” in the reported order was a typographical error. 53 Id. 54 We note, however, that the Pierce court did not apply the standard, adopted in Chapman v. California, 386 U.S. 18 (1967) and discussed in greater length later, for determining whether an error is harmless beyond a reasonable doubt. 23 challenged evidence.

12025–2025
Hall v. State green
del · 1981
1 sentence

2024His first Rule 61 motion, decided in 1988, complained about the jury instructions, the charges, a typographical error and four claims of ineffective 1 Hall v. State, 431 A.2d 1258 (Del. 1981). 1 assistance of counsel.2 That motion was denied in its entirety, which denial was also affirmed on appeal.3 3.

12024–2024
Vinton v. Grayson green
delsuperct · 2018
1 sentence

2023In the spirit of Delaware practice, counsel for Movants appropriately withdrew this claim once Plaintiff counsel clarified this was a typographical error and that the date this occurred should 10 Id. (quoting Cent.

12023–2023
Turner v. State green
del · 2011
1 sentence

2020Id. at A32. 34 commit “Drug Dealing as set forth in Count Sixteen.”133 The State concedes this error, but alleges it is “at best a typographical error of no consequence.”134 Although the written jury instructions stated that Count Sixteen incorporates “planning or commission of Drug Dealing- Cocaine, as alleged in Count 16,”135 when instructing the jury and reading the list of charges, the trial court addressed the typographical errors as follows: “COUNT SIXTEEN is CONSPIRACY SECOND DEGREE, and it reads that DWAYNE WHITE and ERIC LLOYD, on or between the 1st day January 2015, and the 8th day o

12020–2020

Where else courts name it

TX 173 (1907–2025) NY 127 (1910–2026) CA 99 (1941–2026) PA 81 (1931–2026) OH 77 (1958–2026) IL 63 (1951–2026) LA 46 (1941–2025) GA 37 (1900–2021) MO 27 (1913–2025) IA 24 (1931–2025) IN 22 (1955–2025) WI 22 (1956–2025) FL 22 (1937–2024) NM 20 (1992–2022) WA 19 (1965–2025) CT 19 (1985–2025) OK 18 (1910–2024) NJ 18 (1982–2024) VA 16 (1932–2026) AL 16 (1917–2018) MI 16 (1978–2026) OR 16 (1990–2026) TN 16 (1901–2021) MA 14 (1970–2024) AR 14 (1941–2021) KS 13 (1904–2019) ID 13 (1949–2026) NC 13 (1896–2018) MD 13 (1997–2026) AZ 12 (1994–2023) WV 10 (1996–2024) DE 10 (2012–2025) MS 9 (1997–2016) NE 7 (1896–2025) KY 7 (1966–2026) UT 7 (1950–2026) AK 7 (1968–2024) RI 7 (1984–2024) MT 6 (1994–2009) CO 6 (1979–2020) HI 5 (1968–2026) ME 5 (2010–2020) MN 5 (1986–2016) DC 4 (1976–2006) SC 4 (1930–2005) WY 4 (1983–2011) SD 3 (1934–2015) ND 2 (1979–1987) NH 2 (1953–2007) NV 2 (2004–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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