Griffin v. Police Officer Standards and Training Commission

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

ANTHONY GRIFFIN, )
)
Appellant, )
)
v. ) C.A. No. K24A-04-006 NEP
)
POLICE OFFICER STANDARDS )
AND TRAINING COMMISSION, )
)
Appellee. )

Submitted: November 6, 2024
Decided: January 31, 2025

OPINION

Upon Appeal from the Decision of the Police Officer Standards and Training
Commission

AFFIRMED

James E. Liguori, Esquire, and Gregory A. Morris, Esquire, Liguori & Morris,
Dover, Delaware, Attorneys for the Appellant.

Joseph C. Handlon, Deputy Attorney General, Department of Justice, Wilmington,
Delaware, Attorney for the Appellee.

Primos, J.
Former Dover Police Department corporal Anthony Griffin appeals the
decision of the Police Officer Standards and Training Commission (“POST”) to
revoke his certification as a law enforcement officer. Griffin argues that this case
should be remanded because the record is insufficient for this Court’s review and
that, if the Court nonetheless considers the substance of the appeal, POST’s decision
should be reversed because it violated his due process rights. The Court today holds
that the record is sufficient for appellate review and that POST did not violate
Griffin’s due process rights. Because Griffin’s procedural arguments fail, the Court
considers the merits of POST’s decision and concludes that it was supported by
substantial evidence and did not rest on any errors of law. Therefore, the Court
AFFIRMS POST’s decision to decertify Griffin.

2
I. BACKGROUND 1
A. The Decertification Process
Title 11, Chapter 92 of the Delaware Code, commonly called the “Law
Enforcement Officer’s Bill of Rights” (“LEOBOR”), generally requires an
administrative hearing before an officer may be suspended or terminated.2 If an
officer has received a LEOBOR hearing and has been “discharged from employment
with a law-enforcement agency for a breach of internal discipline,” POST 3 must, by
statute, either suspend or revoke that officer’s certification.4 An officer whose

1
Citations in the form of “D.I. ___” refer to docket items. Citations in the form of “B.D. ___”
refer to the March 5, 2024, written decision of the three-member hearing board appointed by POST
(the “Board”). Citations in the form of “Ex. ___” refer to exhibits introduced by either Griffin or
the City of Dover before the Board. At the Board hearing, the City of Dover initially produced
exhibits marked A–G, which are inaccurately lettered in the Certification of Record’s table of
contents because one exhibit (Exhibit D, labeled “Notice of Disciplinary Action”) is omitted from
the list of exhibits. See Certification of Record (D.I. 4); Police Officer Standards and Training
Comm’n Board Hearing Audio Recording (hereinafter “Board Audio”) at 0:15. For purposes of
this Opinion, the Court uses the exhibit letters and numbers used by the hearing Board (rather than
those in the Certification), which are, with one exception, accurately stated in an exhibit list
prepared by Stephanie J. Ballard, Esq., counsel for the City of Dover. This exhibit list is attached
to the Certification. The one omission from Ms. Ballard’s list is Exhibit H, Griffin’s disciplinary
history, which was admitted at the hearing but not previously designated. See Board Audio at
52:25. At the Board hearing, Griffin presented three exhibits, numbered 1–3, see Board Audio at
0:45. These exhibits were, respectively, a November 16 Notice of Disposition of Complaint, a
February 13 employment offer letter from the Cheswold Police Department, and an October 27
letter from DELJIS informing Griffin that his access to that system had not been revoked. Though
not referenced as defense exhibits in the Certification of Record, each of these documents is
reproduced therein. With the exception of the letter from the Cheswold Police Department
(appended to the LEOBOR board’s decision), each of Griffin’s Board exhibits is identically
reproduced in the appendix to his Opening Brief.
The Court is cognizant that this is only the second appeal from a POST decertification. However,
it should be noted that the Court’s review process would have been substantially aided had it been
furnished with a usable transcript, had the record been bound together and consecutively paginated
for easier reference in this Opinion, and had the exhibits presented to the Board been marked and
presented in order with accurate and complete identification in the Certification’s table of contents.
2
See 11 Del. C. § 9203.
3
POST is a seventeen-member administrative body with broad authorities to, among other things,
establish and certify the requirements for police officers in the State of Delaware. See generally
11 Del. C. § 8402–8404.
4
See 11 Del. C. § 8404(a)(4)e.
3
certification has been revoked has “no authority to enforce the laws of the State.” 5
The Delaware Code also sets forth the process by which POST shall determine
that an officer has received a LEOBOR hearing and been discharged, and by which
POST shall thereafter decide between decertification and suspension of that officer.6
Per the Code, the chairperson selects three members of POST to sit as a board and
hear evidence.7 This hearing is conducted in accordance with the Delaware
Administrative Procedures Act. 8 Upon conclusion of the board hearing, the board
submits its written findings and recommendations to the full POST for consideration
and a vote.9 Adverse rulings may be appealed to this Court. 10 This case concerns
such an appeal.
B. Statement Of Facts
The material facts underlying this appeal are undisputed.
On August 26, 2020, Anthony Griffin and other Dover Police Department
officers responded to a domestic violence call in the city.11 Griffin drove the female
participant in the incident to the police station for processing. 12 The woman was
considered both a victim and a suspect because the violence was apparently
reciprocal. 13 After the woman was released, Griffin drove her home, and she
volunteered her phone number. 14

5
11 Del C. § 8410(a).
6
See 11 Del. C. § 8404A (“In all situations where the provisions of § 8404(a)(4) or § 8410(b) of
this title are to be applied to or invoked against any agency or individuals, that agency or individual
shall be entitled to a hearing in the manner prescribed herein[.]”).
7
11 Del. C. § 8404A(1).
8
11 Del. C. § 8404A(4).
9
11 Del. C. § 8404A(2).
10
11 Del. C. § 8404A(3).
11
B.D. 3; LEISS report 50-20-21210 – 8/6/20 Domestic Incident (hereinafter “Domestic Incident
Rep.) (Ex. F).
12
B.D. 3; Domestic Incident Rep. (Ex. F).
13
B.D. 6, Domestic Incident Rep. (Ex. F).
14
B.D. 3; Decision of Crim. Just. Council Hearing Bd. (hereinafter “LEOBOR Bd. Decision”)
(Ex. C) at 3.
4
Shortly before the end of Griffin’s shift on August 26, the woman texted him
for the first time.15 Per the Board, “the text messages became sexually explicit”
almost immediately, and featured “a video of the woman dancing suggestively
(‘twerking’) and . . . a photograph of [Griffin’s] . . . genitalia.”16
Griffin’s texts with the woman also directly implicated her pending criminal
prosecution. The woman expressed concerns that the prosecution would hinder her
career.17 Griffin assured the woman that her case would be dropped. 18
In February 2023, Griffin’s photograph was included in a Dover Police
Department Facebook post recognizing the Department’s school resource officers.19
The man involved in the August 26, 2020, domestic violence incident (the
“Complainant”) became aware of this post (and Griffin’s continued employment)
and complained to the Department.20 As a result, Dover Police Lieutenant Kevin
Streadwick (the “I.A. Investigator”) conducted an internal affairs investigation into
the incident.21 In the course of this investigation, the I.A. Investigator interviewed
both the Complainant and the woman.22 The woman confirmed the exchange of
texts and photographs.23
Griffin was fully cooperative with the I.A. Investigator’s work, and in fact
provided copies of the texts at issue. 24 However—in anticipation of questioning
from the I.A. Investigator—Griffin accessed the Delaware Criminal Justice
Information System (“DELJIS”) to obtain information on both the woman and the

15
B.D. 3; Text messages from Anthony Griffin To M.J. (hereinafter “Text Messages”) (Ex. E).
16
B.D. 3; Text Messages (Ex. E).
17
B.D. 3; Text Messages (Ex. E).
18
B.D. 3; Text Messages (Ex. E).
19
B.D. 4.
20
Id.
21
Id.
22
Id.
23
Id.
24
Id.
5
Complainant.25 Although DELJIS ultimately decided not to revoke Griffin’s access
to its system,26 the Board found that Griffin accessed the system without a
departmental purpose. 27
The investigation of the August 26, 2020, incident was not the first time that
Griffin’s interactions with women had resulted in discipline. Griffin had previously
received a 480-hour suspension, a demotion from corporal to patrolman first class,
and imposition of a two-year probationary period for repeatedly visiting a particular
woman’s home in his patrol car while on duty. 28 Griffin was romantically involved
with this woman for two years, and his supervisors had specifically told him not to
visit her in this way. 29
Despite his disciplinary history, there is evidence that two Delaware police
departments have offered to employ Griffin. 30 These offers are conditional on
Griffin’s retaining his certification.31
C. Procedural History
On October 12, 2023, a three-member panel appointed by the Criminal Justice
Council held a hearing (the “LEOBOR Hearing”) addressing eight counts of alleged
misconduct brought by the Dover Police Department.32 The panel released a written

25
Id.; accord DELJIS Web Portal User Data (Ex. G).
26
Letter from Alyssa Huenke, DELJIS Security Manager, Delaware Criminal Justice Information
System, to James Liguori, Esq. (Oct. 27, 2023) (Ex. 3).
27
B.D. 4.
28
B.D. 6; Disciplinary History of Anthony Griffin (Ex. H).
29
B.D. 6. It is unclear from the record why Griffin had been so warned, and the Board made no
factual finding regarding this issue. Griffin’s testimony suggests that, while he was on duty, the
woman repeatedly visited him to give him food and money. See Board Audio at 55:30.
30
B.D. 5; Letter from Christopher Workman, Chief, Town of Cheswold Police Dep’t, to Anthony
Griffin (hereinafter “Cheswold Job Offer”) (Ex. 2).
31
Cheswold Job Offer (Ex. 2) (“Your appointment . . . is contingent upon the retention of your
certification . . . and resignation from your current employer.”). A department that hired Griffin
as a police officer despite his decertification would lose eligibility for state funds. 11 Del. C. §
8410(b).
32
See generally LEOBOR Bd. Decision (Ex. C).
6
summary of its findings on November 13, 2023. Of the eight counts, the panel found
that four were substantiated. 33 Citing the outcome of the LEOBOR Hearing, Dover
Police Department Chief Thomas A. Johnson Jr. terminated Griffin by written notice
on November 16, 2023.34 Also on November 16, 2023, POST’s predecessor body,
the Council on Police Training (“COPT”), 35 notified Griffin that his termination had
triggered review of his certification, and that he had a right to a hearing consistent
with the state Administrative Procedures Act. 36
POST appointed a three-member hearing board (the “Board”), and the Board
heard evidence on February 21, 2024.37 The two sworn witnesses at this hearing
were the I.A. Investigator and Griffin. 38 On March 5, 2024, the Board issued a
written decision laying out its factual findings and unanimously recommending that
Griffin be decertified as a Delaware police officer.
The full POST took up the issue of Griffin’s decertification at its quarterly
meeting on April 12, 2024. Griffin was allowed to speak on his own behalf and to
present five character witnesses—two officers, a family friend, a local small
business owner, and his mother. After some discussion and deliberation, POST
voted to adopt the Board’s recommendation.39 POST formally notified Griffin of

33
Id. The substantiated charges were a violation of the “Standard of Conduct,” “Compromising
Criminal Cases,” and two counts related to “Computer Access.” Id.; Notice of Disposition of
Complaint of Misconduct (Ex. B).
34
Notice of Disposition of Complaint of Misconduct (Ex. B).
35
On August 7, 2023 POST inherited “all powers and duties formerly vested in the Delaware
Council on Police Training[.]” 11 Del. C. § 8411; see also 84 Del. Laws ch. 149 § 1 (2023). It is
unclear why the letter was on COPT letterhead several months after this transition.
36
Letter from Captain Kerry Reinbold, Admin., Council on Police Training, to Anthony Griffin
(Nov. 16, 2023) (“If you timely request a hearing, you will be notified of the date, time, and place
of the hearing. Hearings are conducted pursuant to the Administrative Procedures Act, 29 Del. C.
ch. 101. You will have the right to be represented by counsel, to present evidence, and to cross-
examine witnesses.”).
37
B.D. 1.
38
Id.; see also generally Board Audio.
39
The motion carried by a voice vote of nine in favor, none opposed, and three abstentions. See
Commission Video at 1:35:24. The abstentions included Chief Johnson of the Dover Police
7
this decision and his right to appeal to this Court within 15 days by a letter dated
April 15, 2024.40 Griffin timely filed his notice of appeal on April 29, 2024.41
II. ANALYSIS
A. Standard Of Review
Unless otherwise directed by statute, administrative appeals are subject to
substantial evidence review. 42 Under this standard, the Court’s “function is limited
to a determination of whether there was substantial evidence sufficient to support
the [administrative body’s] findings, and whether they are free from legal error.” 43
“Substantial evidence means ‘such relevant evidence that a reasonable mind might
accept as adequate to support a conclusion.’” 44 If substantial evidence exists, the
Court will affirm the body’s decision, even if the Court might have reached different
factual conclusions.45 In other words, “when conducting substantial evidence
review on appeal, ‘this Court will not weigh the evidence, determine questions of
credibility, or make its own factual findings.’”46
Issues of statutory construction and interpretation are reviewed de novo. 47 When

Department.
40
Letter from Sean E. Moriarty, Ex. Dir., Police Officer Standards and Training Comm’n, to
Anthony Griffin (Apr. 15, 2024).
41
Notice of Appeal (D.I. 1).
42
Maurer v. Council on Police Training, 2007 WL 625903, at *3 (Del. Super. Jan. 26, 2007)
(conducting substantial evidence review of a COPT decertification decision).
43
Thompson v. Christiana Care Health Sys., 25 A.3d 778, 781–82 (Del. 2011) (citing
Unemployment Ins. Appeal Bd. v. Duncan, 337 A.2d 308, 308 (Del. 1975); Straley v. Advance
Staffing, Inc., 984 A.2d 124, 2009 WL 3451913, at *2 (Del. Oct. 27, 2009) (TABLE)) (cleaned
up).
44
Noel-Liszkiewics v. La-Z-Boy, 68 A.3d 188, 191 (Del. 2013) (quoting Street v. State, 669 A.2d
9, 11 (Del. 1995)).
45
Hudson v. Beebe Med. Ctr., 2024 WL 36063, at *5 (Del. Super. Jan. 3, 2024) (citing Guiterrez
v. Jamestown Painting, 2019 WL 972161, at *3 (Del. Super. Feb. 26, 2019)).
46
Canterbury Crossing Homeowners’ Ass’n, Inc. v. Canterbury Crossing MHC, LLC, 2024 WL
4824777, at *5 (Del. Super. Nov. 6, 2024) (quoting Zayas v. State, 273 A.3d 776, 785 (Del. 2022)).
47
Sandhill Acres MHC, LC v. Sandhill Acres Home Owners Ass’n., 210 A.3d 725, 728 (Del. 2019)
(citing Bon Ayre Land, LLC v. Bon Ayre Community Ass’n (Bon Ayre II), 149 A.3d 227, 233 (Del.
2016)).
8
conducting de novo review of an agency’s statutory interpretation, the Court’s
purpose is to “determine and give effect to the legislature’s intent.” 48
B. Sufficiency Of The Record
1. The Court may not remand this appeal to supplement the record
with a POST meeting transcript.
Griffin contends that this matter must be remanded because the record below
is insufficient. 49 Per Griffin, the record is “inadequate to comprehend what
transpired before” POST. 50 Specifically, even though POST has provided the Court
with an audio recording of the Board hearing and a video recording of POST’s
quarterly meeting, Griffin objects to the automatically-generated transcript of the
latter, which “is hard to comprehend and understand as to who was speaking and
what was being said by the Board Members and others.”51 Even if Griffin is correct
on this front, remand is not an avenue open to this Court for the reasons that follow.
“To the extent that this Court has appellate jurisdiction from certain boards
and commissions, that jurisdiction is specifically conferred by the statute creating
the board and/or commission . . . or by the Administrative Procedures Act[.]”52
Accordingly, the Court may not remand a case to supplement the record unless such
remand is specifically authorized by statute. 53

48
Wild Meadows MHC, LLC v. Weidman, 250 A.3d 751, 756 (Del. 2021); accord Bon Ayre II,
149 A.3d at 233 & n.21 (Del. 2016).
49
Appellant’s Opening Br. at 9.
50
Id.
51
Id.
52
Haden v. Bethany Beach Police Dep’t, 2014 WL 2964081, at *4 (Del. Super. June 30, 2014).
53
See Dalphon v. Nazario, 1995 WL 562159, at *5 n.2 (Del. Super. Aug. 23, 1995) (“This is not
a remand to expand the record. [The relevant statute] does not empower this Court to remand to
expand or add to the record. In that instance, there can be no remand.”) (citing Wilmington Vitamin
& Cosmetic Corp. v. Tigue, 183 A.2d 731, 746–47 (Del. Super. 1962)); cf. Collins v. Eichler, 1991
WL 53447, at *4 (Del. Super. Mar. 25, 1991) (“This Court may not remand a case brought on an
appeal pursuant to 31 Del. C. § 520 since the statute does not grant the Court that power.”) (internal
citation omitted); Robinson v. Mroz, 433 A.2d 1051, 1053 (Del. Super. 1981) (citing Searles v.
Darling, 83 A.2d 96 (Del. 1951); Tigue).
9
No statute gives the Court authority to remand the instant appeal for purposes
of supplementing the record. POST’s enabling statute, Title 11, Chapter 84 of the
Delaware Code, contains no such provision. 11 Del. C. § 8404A(3) merely provides
that “any ruling adverse to any party participating in the hearing may be appealed to
the Superior Court within 15 days of receipt of written notification of said finding.”
11 Del. C. § 8404A(4) does require that “[a]ll hearings shall be conducted in
accordance with the Administrative Procedures Act.” Similarly, 1 Del. Admin. C. §
801–19.2.4, which governs POST, provides that “all hearings shall be conducted in
accordance with the Administrative Procedures Act of the Delaware Code.”
However, an appeal to this Court is not a POST hearing, so these provisions are
inapposite.54
Even if the current procedural posture could be characterized as a “hearing,”
the APA provision granting this Court a power of remand to supplement the
record—29 Del. C. § 10142(c)—is inapplicable because POST is not one of the
specifically enumerated agencies to which the power pertains.55 29 Del. C. §
10161(b) provides that, if an agency is not one of those listed in § 10161(a), the
agency is “only subject to subchapters I and II of [Title 29, Chapter 101, which
comprises the APA], and §§ 10141, 10144, and 10145 of [Title 29].” POST is not

54
11 Del. C. §8404A(2) references “the [singular] hearing provided for in this section.” The
apparent referent is the Board hearing. Compare 11 Del. C. § 8404A(1) (“[A] board . . . will hear
evidence . . .”) with 11 Del. C. § 8404A(2) (“Upon conclusion of the hearing provided for in this
section, the board shall submit its findings and recommendation to the full commission in writing
for consideration and vote.”) (emphasis supplied). Similarly, 1 Del. Admin. C. § 801–19.2
provides that officers are entitled only “to a [singular] hearing.” § 801–19.2.2 likewise references
“the [singular] hearing provided for in this Section.” In other words, the applicable statutory and
regulatory framework anticipates that only one APA-compliant hearing will be held: the hearing
before the Board. Neither POST’s consideration and vote upon the Board’s recommendation nor
the appeal to this Court is a “hearing” for APA purposes.
55
See 29 Del. C. § 10142(c) (“The appeal shall be on the record without a trial de novo. If the
Court determines that the record is insufficient for its review, it shall remand the case to the agency
for further proceedings on the record.”); 29 Del. C. § 10161(a)–(b) (limiting the application of §
10142(c) to certain enumerated agencies).
10
an agency listed in § 10161(a), and § 10142(c) is not one of the statutory provisions
listed in § 10161(b).
Nor does LEOBOR, contained in Title 11, Chapter 92, of the Delaware Code,
empower the Court to remand this case. Indeed, LEOBOR does not contain any
provision for appellate process.56
“The goal of statutory construction is to determine and give effect to
legislative intent.”57 On their face, and without ambiguity, the relevant statutes do
not give this Court a power of remand under these circumstances, and the Court
should not, therefore, read such an authority into the law. 58 To the extent that 11
Del. C. § 8404A(4)’s reference to the APA creates any ambiguity, that ambiguity
does not extend to the issue of remand. A comprehensive understanding of the
statutory scheme accords with the plain meaning of the text. “If a statute is
ambiguous, it should be construed in a way that will promote its apparent purpose
and harmonize with other statutes.”59 Construing § 8404A(4) to give this Court a
power of remand to supplement the record would inappropriately and

56
See Mock v. Div. of State Police, Dep’t of Safety and Homeland Sec., 2022 WL 1744439, at *4
(Del. Ch. May 31, 2022) (“[LEOBOR] does not make any provision for judicial appellate
review[.]”) (citing Haden, 2014 WL 2964081, at *2 (“[T]his Court has clearly held in prior
precedent that it does not have jurisdiction over appeals from decisions rendered pursuant to
LEOBOR.”)); accord Smith v. Dep’t of Public Safety of State, 1999 WL 1225250, at *11 (Del.
Super. Oct. 26, 1999) (“This Court has previously held that it does not have jurisdiction to hear
appeals from decisions rendered by an appeal panel pursuant to LEOBOR because such
jurisdiction has not been conferred by either the Constitution or statutes of this State.”) (citing
Westcott v. City of Milford Police, 1995 WL 465188, at *4 (Del. Super. July 31, 1995)).
57
Eliason v. Englehart, 733 A.2d 944, 946 (Del. 1999) (citing Street, 669 A.2d at 12).
58
See Taylor v. Diamond State Port Corp., 14 A.3d 536, 538 (Del. 2011) (“If it is unambiguous,
then we give the words in the statute their plain meaning.”) (citing Dewey Beach Enters., Inc. v.
Bd. of Adjustment, 1 A.3d 305, 307 (Del. 2010)).
59
Eliason, 733 A.3d at 946 (citing E.I. Du Pont De Nemours & Co. v. Clark, 88 A.2d 436 (1952);
Hamilton v. State, 285 A.2d 807 (Del. 1971)); accord Canterbury Crossing, 2024 WL 4824777,
at *10 n.177 (quoting Bon Ayre II, 194 A.3d at 233 n.10 (Del. 2016); Taylor, 14 A.3d at 538 (Del.
2011)).
11
disharmoniously read out of the APA 29 Del. C. § 10161(a)’s exclusive 60 list of the
agencies to which the Court may remand.
Persuasive in the instant appeal is this Court’s opinion in Maurer v. Council
on Police Training, which interpreted the same apparent conflict between COPT’s
enabling statute (which used identical language to incorporate the APA’s hearing
provisions by reference) and 29 Del. C. § 10161’s exclusion of that body from the
full panoply of APA provisions. 61 The Maurer Court harmonized the two statutes
by concluding that the enabling act intended to incorporate the APA’s hearing
provisions—Subchapter III of the APA—but no others. 62 Specifically, the Court
noted that Subchapter V, which governs judicial review, did not apply, because
Subchapter V does not concern the conduct of hearings. 63 29 Del. C. § 10142(c),
the only APA provision that mentions a judicial power of remand, is contained
within Subchapter V, and therefore inapplicable to POST appeals under Maurer’s
reasoning.
2. The record before the Court is sufficient for substantial
evidence review.
Since the Court may not remand this case to expand the record, it must
determine whether any inadequacies of the record prevent it from performing its
function in this appeal. Griffin is correct that the computer-generated transcript of

60
See 10 Del. C. § 10161(a) (“This chapter shall apply only to the following agencies . . . .”)
(emphasis supplied); 10 Del. C. § 10161(b) (“All agencies which are not listed in subsection (a) of
this section shall only be subject to subchapters I and II of this chapter and §§ 10141, 10144 and
10145 of this title.”) (emphasis supplied).
61
2007 WL 625903, at *5 (quoting the applicable statutory provision that “[i]n all situations where
the provisions of § 8404(a)(4) . . . of this title are to be applied to or invoked against any . . .
individual, . . . that individual shall be entitled to a hearing in the manner prescribed herein: . . .
(4) All hearings shall be conducted in accordance with the Administrative Procedures Act.”)
(emphasis supplied).
62
Id. at *6 & n.15.
63
Id. at *6 n.15 (“The COPT statute is adopting the APA’s Cpt. 101 Subchapter III (Case Decision)
and § 10142(b) is part of the APA’s Cpt. 101 Subchapter V (Judicial Review), which the COPT
statute does not adopt.”).
12
POST’s April 12, 2024, meeting is garbled and difficult to follow. The transcript
makes frequent errors as to what was said, and typically does not differentiate
between speakers. The Court agrees that this transcript is unreliable in its current
form and thus does little to supplement the record. However, the record contains
both a video recording of the POST meeting and an audio recording of the prior
Board hearing. Additionally, the record includes copies of a certified letter notifying
Griffin of his potential decertification and right to a Board hearing; every exhibit
submitted into evidence before the Board; the Board’s written decision; and a letter
from POST to Griffin notifying him of his decertification and right of appeal to this
Court.64 This record is sufficient for the Court to determine whether POST’s
decision to decertify Griffin was supported by substantial evidence and whether it
rested on errors of law.
When conducting substantial evidence review, the Court is “require[d]” to
“search the entire record.” 65 This requirement, however, implicates two questions:
what constitutes “the record,” and when is the record insufficient for the Court to
conduct its review on appeal? The Court need not comprehensively answer these
questions to dispose of this case. It is adequate to conclude that the record need not
include a transcript in all cases and that where, as here, a recording of proceedings
is provided in lieu of a transcript, the absence of a reliable transcript does not prevent
the Court from conducting its review. Under these circumstances, a transcript would
not expand the record, but would merely make the case more amenable to speedy
review and disposition by the Court.

64
Certification of Record signed by Gina M. Corona, Administrative Specialist III, Delaware
Police Officer Standards and Training Commission (July 8, 2024) (certifying the paper record filed
with this Court as D.I. 4 and listing the contents thereof).
65
Nat’l Cash Register v. Riner, 424 A.2d 669, 674–75 (Del. Super. 1980); accord Fasano v.
Delaware Dep’t of Nat. Res. & Env’t Control, 2024 WL 469638, at *2 (Del. Super. Feb. 2, 2024);
Hudson, 2024 WL 36063, at *5.
13
Superior Court Civil Rule 72(e) provides that agencies’ custodians of record
shall furnish the Court with “a certified copy of the record of the proceedings below,
including a typewritten copy of the evidence,” unless the parties agree that such a
copy is unnecessary and file a stipulation so indicating with the agency within 10
days from the filing of the notice of appeal.66 29 Del. C. § 10125(d), which is
applicable to POST consistent with Maurer, 67 provides that “[a] record from which
a verbatim transcript can be prepared shall be made of all hearings in all contested
cases” and that “[t]ranscripts shall be made at the request and expense of any
party.”68 Thus, 29 Del. C. § 10125(d) contemplates the preparation of a verbatim
transcript only if a party requests and pays for it.
POST filed a certified copy of the record with this Court on July 8, 2024. That
copy, as noted supra, included an audio recording of the February 21, 2024, Board
hearing, and a video recording of the April 12, 2024, POST meeting, but did not
include a reliable transcript of either proceeding. As noted in footnote 54, supra, the
February 21 Board hearing was the singular hearing contemplated by the relevant
statutes. As such, the April 12 POST meeting was not such a hearing, and therefore
29 Del. C. § 10125(d) did not even require that a record from which a verbatim
transcript could be prepared be made of the April 12 POST meeting—the only
proceeding which Griffin now complains lacks an adequate transcript. Even if it
could be argued that the phrase “typewritten copy of the evidence” in Rule 72(e)
would require a written transcript of the April 12 POST meeting, Griffin at no time
either requested or paid for such a transcript. Thus, he cannot be heard to complain
that the record is incomplete.
Furthermore, the nature of substantial evidence review itself supports the

66
Super. Ct. Civ. R. 72(e).
67
29 Del. C. § 10125(d) is included in Subchapter III of the APA.
68
11 Del. C. § 10125(d) (emphasis supplied).
14
conclusion that the record currently before the Court is sufficient. Substantial
evidence review serves a narrow purpose and imposes certain limitations on this
Court. “Only when there is no satisfactory proof to support a factual finding . . .
may the Superior Court overturn that finding.”69 The Court does not “weigh the
evidence, determine questions of credibility, or make its own factual findings.”70
The evidence supporting POST’s decision need not be such as the Court would
independently consider adequate to justify the decision, but merely “such relevant
evidence as a reasonable mind might accept” 71—more than a scintilla, but less than
a preponderance of the evidence. 72 A transcript of proceedings is not essential for
the Court to conclude that a “reasonable mind” could be persuaded of POST’s
decision. Even in the absence of a reliable transcript, the Court has before it
everything considered, and everything said, at POST’s April 12, 2024, meeting.
Delaware courts’ practice in the analogous area 73 of zoning appeals further
supports the Court’s conclusion on this issue. Zoning appeals, much like this one,
turn on the substantial evidence standard. 74 Zoning decisions may not be arbitrary
and capricious, and local zoning authorities must therefore establish the bases for
their actions, lest authorities “thwart[] the ability of a court to provide effective

69
Powell v. OTAC, Inc., 223 A.3d 864, 870 (Del. 2019) (quoting Noel-Liszkiewics, 68 A.3d at
191).
70
Zayas, 273 A.3d at 785 (quoting Roos Foods v. Guardado, 152 A.3d 114, 118 (Del. 2016)).
71
Powell, 223 A.3d at 870 (quoting Guardado, 152 A.3d at 118).
72
Id. (quoting Noel-Liszkiewicz, 68 A.3d at 191).
73
See New Castle County Council v. BC Dev. Assocs., 567 A.2d 1271, 1275 (Del. 1989) (“[I]n the
realm of rezoning, the power of [the county council] is analogous to that of an administrative
agency, since the fundamental power to regulate land use rests with the General Assembly.”);
accord 330 Hospitality Group, LLC v. City of Rehoboth Beach, 2024 WL 3520448, at *5 (Del.
Super. July 23, 2024); Sussex Medical Investors, L.P. v. Delaware Health Res. Bd., 1997 WL
524065, at *4 (Del. Super. Apr. 8, 1997).
74
See Rehoboth Art League, Inc. v. Bd. of Adjustment of Town of Henlopen Acres, 991 A.2d 1163,
1166, 1168 (Del. 2010) (applying the substantial evidence standard to the denial of a zoning
variance).
15
review.” 75 Nonetheless, as the Chancery Court noted in one zoning appeal, “the
burden of creating a sufficient evidentiary record is not a particularly demanding
one.” 76 A zoning authority must either “state on the record its reasons” or “create a
record” that is “an adequate substitute for a more formal explanation” because the
authority’s reasons are “clear” therefrom. 77
The sufficiency of the record in this case may be gleaned from the Supreme
Court’s description of what renders a zoning appeal record insufficient. The Court
has instructed that reviewing courts should not be “left to guess” which factors
contributed to an authority’s decision and held that “a murky picture of the reasoning
underlying” that decision “provides an inadequate basis for judicial review.” 78 As
such, the Court has suggested that for “particularly complex zoning application[s]”
with “a large body of conflicting evidence . . . a formal statement of [the zoning
authority’s] findings would greatly aid the process of judicial review.” 79 Here, the
Court need not guess at the reasoning for POST’s decision to decertify Griffin. The
reasons justifying Griffin’s decertification are clear from the Board’s formal written
decision and the exhibits thereto. This is not a complex case, and the material facts
are not in dispute. Thus, the record is sufficient, notwithstanding the absence of a
clearly written transcript of either the February 21 hearing or the April 12 meeting.
C. Griffin’s Due Process Rights
Griffin contends that POST violated his due process rights in two ways: first,
by not requiring the Board members to recuse themselves from the April 12, 2024,

75
BC Dev. Assocs., 567 A.2d at 1276.
76
O’Neill v. Town of Middletown, 2006 WL 4804652, at *36 (Del. Ch. Jan. 18, 2006) (citing BC
Dev. Assocs., 567 A.2d at 1277–78). See also id. at *36 n.297 (describing the applicable standard
as “relatively low” and stating that “evidence constituting ‘substantial evidence’ may, in some
instances, require relatively little in order to satisfy judicial review requirements,” such as when
“consistency with the comprehensive plan is . . . obvious.”).
77
BC Dev. Assocs., 567 A.2d at 1276 (citing Tate v. Miles, 503 A.2d 187, 191 (Del. 1986)).
78
Id. at 1277.
79
Id.
16
vote on Griffin’s decertification; and second, by considering evidence that had not
been presented to the Board. The former claim fails because the Board members
were not obligated to recuse themselves, and because Griffin waived his objection
by failing to raise it at POST’s April 12 meeting. The latter claim fails because the
only new evidence considered by the full POST was that presented by Griffin
himself, and Griffin cannot claim actual prejudice from the consideration of this
evidence.
“[A] necessary element of any judicial review is that claims of unfairness in
the administrative process be seriously addressed.”80 Nonetheless, appellants raising
such claims in administrative appeals must pass a high bar. “In order to prevail on
a procedural due process claim, a party must demonstrate the existence of a protected
property interest and show the deprivation of that interest without notice and [an]
opportunity to be heard.”81 “Due process essentially requires that an individual be
given a full and fair hearing before an impartial tribunal at a meaningful time and in
a meaningful manner.” 82 The due process requirements for administrative hearings
are less stringent than those for judicial hearings. 83 Due process is satisfied when a
party to the administrative process is given “a full opportunity to answer the

80
Sokoloff v. Bd. of Medical Practice, 2010 WL 5550692, at *5 (Del. Super. Aug. 25, 2010)
(quoting Blinder, Robinson & Co. v. Bruton, 552 A.2d 466, 472 (Del. 1989)).
81
Id. (citing Pravetz v. State Bd. of Med. Practice, 2003 WL 21203304, at *6 (Del. Super. May
21, 2003)). For purposes of this Opinion, the Court assumes, without deciding, that Griffin’s
certification is a property interest to which due process rights attach. Accord Husbands v.
Delaware Dep’t of Educ., 227 A.3d 558, 2020 WL 1814045, at *1–2 (Del. Apr. 7, 2020) (ORDER)
(declining to decide whether the appellant had due process rights in his teaching license and
certification, where the appellant failed to identify any defects in the process by which they were
revoked).
82
Husbands, 2020 WL 1814045, at *1 (quoting Cook v. Oberly, 459 A.2d 535, 538 (Del. Ch.
1983)).
83
BCBSD, Inc. v. Denn, 2008 WL 1838462, at *4 (Del. Super. Apr. 22, 2008) (citing Hibbard
Brown & Co., Inc. v. Hubbard, 1992 WL 389927, at *3 (Del Ch. Dec. 23, 1992), rev’d on other
grounds, 633 A.2d 345 (Del. 1993)).
17
charges.” 84 The administrative agency “need not ‘enumerate precisely every event
to which a hearing examiner may finally attach significance.’” 85 Even if there is a
defect in the administrative process, an appellant cannot prove that the appellant’s
due process rights were violated absent a showing of actual prejudice.86
1. There was no legal requirement that the members of the Board
recuse themselves from the POST vote, and Griffin waived any
objection to Board members’ voting.
Griffin objects to the fact that the members of the three-member Board
“participated in the decision as to whether or not to accept their factual findings and
decision below.”87 Griffin contends that this violates “common sense” and
constitutes an error of law. 88 Because Griffin alleges an error of law, the Court
reviews this question de novo.
11 Del. C. § 8404A, which sets forth the requirements for POST hearings,
contains no requirement for the recusal of Board members. Indeed, § 8404A(1)
requires that the three-member hearing Board be drawn from the POST
Commissioners.89 § 8404A(2) requires that “the board . . . submit its findings and
recommendation to the full commission in writing for consideration and vote.” 90 No
provision excludes Board members from this vote. Contrary to the plain language
of the statute, such an exclusion would necessarily mean that the “full commission”
would not be voting. This reference to a vote of the “full commission,” combined
with the requirement that the Board be drawn from POST’s Commissioners, evinces

84
Husbands, 2020 WL 1814045, at *2 (quoting Denn, 2008 WL 1838462, at *4).
85
Denn, 2008 WL 1814045, at *5 (quoting Hibbard, 1992 WL 389927, at *4).
86
Agbemehia v. Delaware Bd. of Nursing, 2024 WL 66047, at *7 (Del. Super. Jan. 5, 2024) (citing
Sandefur v. Unemployment Ins. Bd. of the State of Delaware, 1993 WL 389217, at *5 (Del. Super.
Aug. 27, 1993)).
87
Appellant’s Opening Br. at 10.
88
Id.
89
11 Del. C. § 8404A(1) (“The chairperson shall select 3 members of the Commission to comprise
a board which will hear evidence on the allegation[.]”).
90
11 Del. C. § 8404A(2) (emphasis supplied).
18
a legislative intent for Board members to fully participate in decertification votes.
Griffin’s argument would fail even if the Board should have recused itself
from POST’s decertification vote. Griffin waived his objection by failing to raise it
at the April 12, 2024, POST meeting. A party who fails to raise a disqualification
issue may not seek to set aside the results of a vote when the basis for the
disqualification was known by the party prior to the meeting at which the vote was
held.91 The fact that Griffin now asserts necessitated recusal—i.e., that three
members of POST served on the Board—was known to him at the time POST
convened to vote on his decertification. Even if he were correct that recusal was
warranted, therefore, Griffin could not raise the issue for the first time in this
appeal. 92
2. POST did not violate Griffin’s due process rights by considering
evidence not heard by the Board.
Griffin’s second due process claim rests on the related premises that POST
heard new evidence not considered by the Board and that Griffin therefore lacked
both notice of the evidence and an adequate opportunity to test that evidence.93 It is
certainly true that due process requires “fair notice of the scope of the proceedings
and . . . adherence . . . to the stated scope of the proceedings.”94 It is also true that

91
Town of Cheswold v. Vann, 947 A.2d 1123, 2007 WL 1201716, at *3 (Del. Apr. 23, 2007)
(ORDER) (quoting Copeland v. Manuel, 653 A.2d 304, 1994 WL 665257, at *2 (Del. Nov. 22,
1994) (ORDER)).
92
Id. (police chief terminated by town council could not raise bias of council members on appeal,
where the circumstances allegedly indicating that bias were known prior to the council meeting
but the chief did not seek to disqualify them).
93
Appellant’s Opening Br. at 5 (“The nature of the Appeal in this matter is that [POST] abused
their discretion and committed errors of law by considering additional information and evidence
that was never presented to the lower Hearing Board which was appointed to review all the facts
of the incident in 2020.”); id. at 7 (“The inherent and fundamental flaw in the [POST decision] is
that it vitiated the entire hearing process. The . . . Commission chose to include new information
and evidence not considered by the Hearing Board.”).
94
Vincent v. Eastern Shore Markets, 970 A.2d 160, 164 (Del. 2009) (citing Philips v. Delhaize
America, Inc., 2007 WL 2122139, at *2 (Del. Super. July 20, 2007)).
19
an appellant has “the right of controverting, by proof, every material fact which bears
on the question of right in the matter[.]”95 Griffin’s argument, however, lacks any
support in the record. To the contrary, all of the “new evidence” of which Griffin
complains was either not new, not evidence, or not prejudicial.96
Griffin first points to a statement by Dover Police Department Chief Johnson
regarding the reason that the Complainant raised the events of August 26, 2020, so
long after the incident:
There was a disciplinary event that took place in my first year, in 2020,
that prompted a lengthy suspension. And this is anecdotal, because I
never actually spoke to the gentleman, but secondhand, my
understanding is that he thought that disciplinary event was related to
the incident that is before us right now . . . . So he was under the
mistaken impression that something had been done when he came in to
complain the first time.97
Griffin is simply incorrect that this was new information not presented to the Board.
Before the Board, the I.A. Investigator testified that the Complainant “sa[id] that he
thought [Griffin] was fired . . . . Originally he said he came to the police department
after this August of 2020 incident . . . and he thought it was dealt with then.” 98 Chief
Johnson merely restated the testimony of the I.A. investigator. Thus, Griffin cannot
credibly argue that his due process rights were violated by the Chief’s comments.
Griffin next objects to a Commissioner’s comments suggesting that the Board
hearing may not have been as in-depth as any investigation conducted by the two
departments that subsequently offered Griffin jobs, and noting that those agencies’

95
Id. (citing Mathews v. Eldridge, 424 U.S. 319, 333 (1976)).
96
The following description of Griffin’s arguments summarizes the comments actually made at
POST’s April 12, 2024, meeting for the sake of clarity, rather than reproducing the purported
statements contained in Griffin’s filings. Griffin’s briefs rely on the garbled automated transcript
of the meeting and attempt to give “context” for why portions thereof are objectionable.
97
April 12, 2024, Police Officer Standards and Training Comm’n Meeting Video Recording
(hereinafter “Commission Video”) at 1:04:30.
98
Board Audio at 25:59.
20
willingness to employ Griffin gave him “pause.” 99 These were merely comments on
the evidence—part of POST’s role in deliberating and voting on the Board’s
recommendation. Further, even if these comments could be characterized as “new
evidence,” they were not prejudicial to Griffin, as they echoed the very arguments
he wished POST to accept: that, notwithstanding the Board’s recommendation,
Griffin was a redeemable police officer, as evident from his employability. Griffin
cannot credibly claim actual prejudice because POST considered evidence he put
before them himself, 100 and certainly not because a Commissioner found it
persuasive. Thus, Griffin’s due process rights were not violated on this ground.
Relatedly, Griffin objects to a Commissioner’s comment that he “[did not]
know . . . what if any background those chiefs [that subsequently offered Griffin
jobs] had done prior to issuing that [employment offer] letter. So we know that we
were told that there were two conditional offers, but we don’t know if they’ve
already done the background or not.”101 This was merely a comment on the
evidence, or the absence or ambiguities thereof. Griffin’s due process rights were
not violated simply because POST deliberated. 102
Griffin further objects to the comments of a Commissioner who noted that
only one of the employment offers Griffin received was documented at the time of
the Board hearing 103 and asked whether there was a procedure for another

99
Commission Video at 1:06:28.
100
Agbemehia, 2024 WL 66047, at *7 (“[Appellant] cannot show any actual prejudice stemming
from the Board considering [his] own exhibits in the Board’s deliberations. Accordingly, the
Board did not violate [his] due process rights.”) (emphasis in original).
101
Commission Video at 1:12:38.
102
Indeed, deliberation is arguably one element of due process. See Warrington v. State,1994 WL
387028, at *2–3 (Del. Super. July 14, 1994) (reversing and remanding a decision where the officer
that cast the deciding vote “did not see the witnesses or participate in the deliberations[.]”).
103
Appellant’s Opening Br. at 8. This was an accurate statement. Before the Board, Griffin
represented that Delaware State University “didn’t want to put anything in writing” about the offer,
Board Audio at 20:45, and that the University had “recommended [Griffin] for hire” but was
“waiting on paperwork.” Id. at 45:15.
21
evidentiary hearing that would allow the Board to further consider the second offer
before deciding whether to revise its recommendation. 104 Griffin does not explain
why this inquiry would be problematic, and no reason is evident to the Court.
Also raised by Griffin is a Commissioner’s comment that “those [character]
witnesses that [Griffin] had in today . . . should have been at the hearing . . . and had
they been at the hearing we might not be here . . . right now.” 105 Griffin describes
these comments as “questioning [the Commissioner’s] opinion of the evidence at
[the] below hearing”106 but otherwise fails to specify why the comments would be
objectionable. Griffin certainly cannot claim prejudice because a Commissioner
argued that the Board could have found his witnesses compelling. Moreover, as
stated previously Griffin cannot claim prejudice from new evidence provided by his
own character witnesses.107 More disquietingly, in response to the Commissioner’s
comments, Griffin claimed that he was “not told” that he could have witnesses at the
Board hearing. 108 However, this claim is belied by the certified letter notifying
Griffin of his termination and right to a Board hearing before decertification, which
stated that Griffin had “the right to be represented by counsel, to present evidence,
and to cross-examine witnesses.”109 Likely for this reason, Griffin does not make
this same claim on appeal. For all these reasons, Griffin’s due process rights were
not violated on this ground.
Lastly, Griffin objects to a comment that “we have to be careful in this
proceeding not to present new evidence against Mr. Griffin.” 110 Griffin claims that

104
Commission Video at 1:16:58.
105
Commission Video at 1:23:46.
106
Appellant’s Opening Br. at 9.
107
See Note 100, supra.
108
Commission Video at 1:24:00.
109
Letter from Captain Kerry Reinbold, Admin., Council on Police Training, to Anthony Griffin
(Nov. 16, 2023).
110
Commission Video at 1:30:35.
22
the speaker “admit[ted] new evidence ha[d] been discussed” at the POST meeting.111
On the contrary, the speaker immediately stated that he “[didn’t] think [POST] ha[d]
gone there yet.”112 Far from evidencing a violation of Griffin’s due process rights,
these comments show that POST was cognizant of, and wanted to avoid violating,
those rights.
Upon a comprehensive review of the recordings of the Board hearing and
POST meeting, as well as all other components of the record, the Court finds that
the full POST considered only two categories of new evidence: the testimony of
Griffin’s character witnesses and potential documentation for the previously-
disclosed job offer from Delaware State University.113 This new evidence, presented
by and in support of Griffin, did not prejudice him, and as a result could not violate
his due process rights. Griffin’s arguments to the contrary, to the extent that any
arguments are proffered, are meritless. Griffin had a fair opportunity of
controverting the case against him at the Board hearing. POST afforded Griffin
adequate due process.
D. Substantial Evidence Review
As the Court has determined that the record before it is sufficient and that
Griffin was afforded due process, it must evaluate whether, in light of the record,
POST’s decision to decertify Griffin was properly supported pursuant to the
deferential substantial evidence standard. 114 Since the facts underlying this case are
undisputed, the Court evaluates whether those facts constitute substantial evidence

111
Appellant’s Opening Br. at 9.
112
Commission Video at 1:30:45.
113
From reviewing the recording of the April 12, 2024, POST meeting, it appears that no offer
letter from Delaware State University was ever offered into evidence, though said offer was
discussed, and some Commissioners appeared to view the offer as new information. See id. at
1:17:05, 1:27:20. As such, there is no copy of an offer letter from the University, if such letter
exists, in the record.
114
See supra Section II(A).
23
in support of POST’s conclusion that decertification, rather than certification
suspension, was warranted in Griffin’s case. Upon a review of the full record, the
Court concludes that substantial evidence supported this decision.
The rationale for POST’s decision may be inferred from the Board’s
recommendation thereto. The Board stated that POST had historically “reserved
decertification for cases where an officer’s misconduct implicates honesty and
integrity or where an officer’s conduct places the public or fellow officers at risk of
harm.”115 As to Griffin’s case, the Board noted that Griffin “showed severe lack of
judgment” and that he “took advantage” of the “vulnerability” of a woman “in a
severely compromised position.” 116 Moreover, Griffin’s unprofessional and explicit
text messages threatened the then-pending prosecution of the woman. 117 This
misbehavior was even more troubling in light of his history of insubordinately
associating with another woman while on duty, resulting in a 480-hour suspension,
demotion, and imposition of a 2-year probationary period.118 The Board concluded
that the evidence “support[ed] a finding of calculated intentional misconduct” that
merited decertification. 119
The Board’s conclusion, adopted by POST, is reasonable in light of the facts
in evidence, which were fully developed and documented through the LEOBOR and
Board hearings. Griffin’s behavior on August 26, 2020, raised serious doubts as to
his integrity. It threatened public safety because the texts may have been
discoverable and effective impeachment material in a prosecution of either the
woman or the Complainant. The events of August 26, 2020, would likely have
merited decertification on their own. However, the Board justifiably viewed the

115
B.D. 8.
116
Id.
117
Id.
118
Id. at 8–9.
119
Id. at 9.
24
August 26 incident in light of Griffin’s prior disciplinary history concerning women.
The details of that prior behavior remain somewhat cloudy, but POST could
reasonably conclude, as the Board did, that “the conduct must have been serious to
merit the severe discipline that DPD” imposed for it, particularly given the harsh
language in Chief Johnson’s termination letter.120 This was a permissible inference
for POST to make. 121

120
Id. at 8. The letter read, in relevant part, as follows: “A review of [Griffin’s] disciplinary
history indicates that no amount of corrective action has resulted in a sustained change in his
behavior or altered his propensity to commit serious policy violations . . . . On a regular and
recurring basis, Anthony E. Griffin, Sr. follows his own rules rather than the written directives of
his employer.” Notice of Disposition of Complaint of Misconduct (Ex. B).
121
Cf. Donovan Smith HOA v. Donovan Smith MHP, LLC, 190 A.3d 997, 2018 WL 3360585, at
*1 (Del. 2018) (ORDER) (arbitrator could infer that installing a driveway to each unit of a
manufactured home community and repainting the community’s maintenance building entailed
“substantial cost,” and that, “without an increase in rent, the [landlord’s] rate of return [on
investment] would have been reduced,” even though no evidence of the costs was presented);
accord Canterbury Crossing, 2024 WL 4824777, at *8 (“While some of the evidence cited by the
Arbitrator did not directly pertain to the statutory requirements, their satisfaction was a fair
inference from the evidence the Landlord presented.”).
25
III. CONCLUSION

For the foregoing reasons, the Court finds that POST’s April 15, 2024,
decision was supported by substantial evidence, that it did not rest on any errors of
law, and that the process by which it was made did not violate Griffin’s due process
rights.
WHEREFORE, POST’s decision of April 15, 2024, is AFFIRMED.
IT IS SO ORDERED.

NEP/tls
Via File & ServeXpress
oc: Prothonotary
cc: Counsel of Record

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