## Facts

- A request was made for a case summary of a decision identified only by the name “Smith v. State.”
- The case name “Smith v. State” was identified as recurring across many jurisdictions and years, describing different criminal-law subjects and outcomes.
- The available record provided no facts about the defendant’s conduct, charges, trial proceedings, evidentiary rulings, or sentencing.
- The available record provided no identifying case attributes such as the deciding court, jurisdiction, date, reporter citation, docket number, or doctrinal issue.
- Multiple, distinct “Smith v. State” examples were referenced as potentially intended targets, including decisions addressing insanity, self-defense/provocation, prior-acts evidence, and post-conviction procedure.
- The record indicated that, without at least a jurisdiction/year, a reporter citation, or a doctrinal topic, it was not possible to determine which “Smith v. State” decision was at issue.
- The record requested additional identifying information so that a fact-specific case brief could be prepared.

## Issues

1. Whether a court (or legal analyst) can produce a reliable merits summary of a case when the record identifies it only by an extremely common caption without jurisdiction, court, year, citation, or subject matter.
2. What minimum identifiers are necessary to select the correct precedent among multiple decisions sharing the same party names.
3. Whether, absent a uniquely identified decision, any statement of facts, procedural posture, holding, or reasoning would be speculative and therefore improper.

## Decision

- The matter could not be resolved on the merits because the record did not uniquely identify which “Smith v. State” decision was being referenced.
- The decision-maker required additional information—such as jurisdiction and approximate year, a reporter citation, or the legal topic—to select the correct case.
- The request for a substantive, fact-specific summary was effectively denied without prejudice to renewal upon submission of adequate identifiers.
- Examples of different “Smith v. State” cases were noted only to show that multiple, inconsistent candidates existed and that selection could not be made reliably on the existing record.

## Legal Principles

- A case caption alone is not a sufficient identifier when the caption is common and used across many jurisdictions and time periods.
- Reliable legal analysis requires a determinable source decision; without court, year, or citation, a purported “holding” risks being attributed to the wrong case.
- When the record is insufficient to identify the controlling or referenced authority, the proper course is to require clarification rather than infer facts or reasoning.
- Minimum identifiers commonly required to select the correct precedent include: (a) jurisdiction and approximate date, (b) reporter citation, or (c) a distinctive doctrinal issue tied to a known decision.

## Conclusion

Because “Smith v. State” is not uniquely identifying and the record lacked jurisdiction, court, year, citation, and subject matter, no merits-based summary could be provided; clarification was required to determine which distinct “Smith v. State” decision governed.


Smith v. State, 999 A.2d 986 (Del. 2010)