State v. Wright
In State v. Wright, 821 A.2d 330, 333 (Del. Super. 2003), the court held that it had the power to order the State to "supply" certain discoverable evidence to the defendant on a date prior to trial that would provide the defendant an adequate opportunity to prepare. Id. The State argued that the court rules did not expressly grant the court such authority. Id. However, the court opined that it could issue the order in accordance with its inherent authority to achieve the orderly disposition of its business. Id.
The court reasoned that this inherent authority necessarily includes the power to issue orders specifying the manner and time for discovery between the parties. Id. "The Court's inherent power is not per se restricted by the Court's rules of procedure. Indeed, guided by considerations of justice, and in the exercise of inherent powers, courts may, within limits, formulate procedural rules not specifically required by the Constitution or the legislature.'" State v. Wright, supra at 333.