State v. Shugard
In State v. Shugard, 2004 WL 844186, (Del. Com. Pl.), the parties also submitted briefs on the issue below and the trial court entered an order setting forth the court's rationale, and this Court found the record provided was sufficient for review.
However, in Shugard the court relied heavily on the fact that no testimony was taken in the proceeding below when it found that the State's failure to provide a transcript did not prevent appellate review. Id.