Thornton v. State
In Thornton v. State, 405 A.2d 126 (Del. 1979), although the State did not obtain explicit testimony that the crime in question occurred in New Castle County and State of Delaware, the officer testified that it occurred at "the De LaWarr Motel, which is just south of Wilmington in New Castle County." Id.
The Court found that, taken as a whole, the specific nature of the testimony was enough to establish situs. Id.