Corporate Voters Project, Delaware

Forever the Fenwick Island Corporation 

Or, Shady Sovereignty at the Sands Motel 

Corporate Voters Project – Research Note #7 

A postcard featuring the Sands Motel in Fenwick Island, DE. Three images: one is a view of the exterior of the hotel and its parking lot; a blue and white building with cars parked outside. A smaller insert features white people in bathing suits at the beach; and a third white people at the motel pool, with the logo and building behind them. Source: Sands Beach Resort Motel, 1979, Postcard, 21 x 9 cm, Special Collections, University of Delaware Library, GRA 0138, Delaware Postcard Collection, https://digitalcollections.udel.edu/Documents/Detail/sands-beach-resort-motel/164590.

Fenwick Island, as a modern community, was born a Delaware chartered corporation – which perhaps explains the municipality’s current attachment to corporate voting. 

Today, the Town of Fenwick Island is (in)famous for being among the handful of Delaware municipalities that allows corporations to vote in local elections.[1] Like other towns that enfranchise fictional persons, Fenwick awards voting rights on the basis of residency and property ownership. The tiny beach settlement (year round pop. < 400) does put some limits on the corporate vote: since 2008, Fenwick’s charter has insisted on a “one-person/entity, one vote” principle, so property owners cannot double dip, voting as both individuals and as the entities they control; nor can they vote multiple times based on the number of parcels they (or the entity) own.[2] 

Still, the political community that defines this narrow spit of land is firmly committed to oligarchy. Not only are non-resident property owners enfranchised, they can – and frequently do – make up a majority of the town council: only three of its seven members have to be full-time human residents.[3]

Recently, Fenwick was in the news for more than its generic lighthouse. In December 2025, the ACLU Delaware sued Fenwick in state court for violating the Delaware Constitution’s guarantee of “free and equal” elections conducted on the principle of “one person, one vote.” [4] The case is pending, though Fenwick Mayor Natalie Magdeburger told a reporter that it is “[o]ur belief is that everyone who pays taxes and is subject to our ordinances should have a vote” – including within “everyone,” the artificial entities commonly used to manage property. [5]

But how did this one-lane sea shore village become a rentiers’ redoubt? And when did it decide to shift from human rule to government for and by artificial entities? The legal history of this sandy spit on the Mason-Dixon line reveals the surprisingly recent roots of corporate voting, as an active practice – but also Delaware’s long tradition of privileging property over people. 

~~~

Fenwick Island began its life as a distinct Delawarean community as an insider real estate speculation. In 1893, John H. Layton, Clerk of the Delaware House, bought out the owners of the barrier island that overlapped the Delaware-Maryland border, commonly known, if vaguely, as “Fenwick Island.”[6] Layton appears to have been the front man for a consortium of moneyed Delaware speculators, including legislators and industrialists, who quickly won two corporate charters to develop and manage the property.

The first, the Fenwick Island Company, was a real estate firm dedicated to managing “the business of purchasing, selling, holding, improving and managing real estate and island property.” The state granted it a $50,000 capitalization, extendable to $300,000, and the right to construct a railroad. (NB: unlike corporations under current Delaware law, the Fenwick Island Company’s founding document guaranteed shareholders’ democratic governance rights: all bylaws had to be decided by stockholders, and at all stockholder meetings, “all questions shall be decided by decided by a majority of votes case…each share of stock being entitled to one vote.” No question about rights to make proposals then, though later corporate advocates committing acts of law office history have offered alternate facts.)

The second was the Fenwick Island Gunning Club. Though Fenwick’s dunes and marshes were reportedly good territory for goose and duck shoots, its charter was silent on “gunning” (hunting) – but it did declare the corporation’s purpose as to provide for the “social intercourse and mutual improvement of its members.” (It’s founding members were the same as the real estate company.) [7]

Despite Layton’s string-pulling in Dover to acquire land and investment vehicles, not much came of the effort. Fenwick land sales didn’t boom, and neither a hunting resort nor a railroad was built. But in the decades following,  Fenwick Island did become something of a cheap vacation spot, the site of regular evangelical camp-meetings, where vactioners enjoyed shore stays in rustic lean-tos and squat cottages [8]. After the state built a new road in the 1930s, cottagers petitioned for the right to purchase titles to the lots they leased – which they gained in 1942, after a legal battle over property rights between the state and the various “real estate men” resolved in the state’s favor.[9]

~~~

By 1953, the growth of Ocean City, Maryland next door, and the advent of better roads and more secure land titles, appears to have made Fenwick popular enough to lead property owners to petition the General Assembly for a charter, which duly passed into law without attracting comment. As with the corporation that preceded it, the town was to be run for and by property. Its government, a town council, was a body whose membership could only be composed of freeholders; those town councilors would be voted in by an electorate composed of “male or female” persons, twenty-one or over, who qualified for the franchise by being “freeholders,” either themselves or by marriage. Notably, while the original Fenwick Island town charter explicitly recognized that persons, partnerships, and corporations could be assessed taxes, implicitly it reserved voting rights for “persons” with qualities of gender and age – that is, human beings. [10]  

Unusually for Delaware municipalities, the Town of Fenwick Island has never revised its charter wholesale, but only amended it  – making it more difficult to track when corporate voting arose. The first evidence of the practice in state law appears in 1965, when the town charter was amended to allow the authorities to issue infastructure bonds. As with other municipalities, this new capacity for extending municipal credit came with new oversight: special hearings to propose and discuss the borrowing, and a special election to obtain voters’ approval. These special bond elections expanded the electorate to corporations, explicitly, and tilted power toward wealth: “every owner of property, whether individual, partnership or corporation” could vote, and they “shall have one vote for every dollar” paid in tax. Voting could be in person “or by proxy.” In other words: a few months before the US Congress would pass the Voting Rights Act to ensure all Americans could participate in elections equally, the Town of Fenwick Island in still-segregated Delaware extended new voting rights only to propertied fictional persons. [11]

Universal human suffrage did not reach Fenwick Island until after man had visited the moon and disco conquered the dance floor. In 1979, a charter amendment lowered the voting age to eighteen, and specified that all humans residents in town on election day were “entitled to vote.”[12]

This new regime was not without its complications, however. In 1981, Fenwick’s police chief, James L. Cartwright, was disqualified as a candidate for a town council race because he did not own a sufficiently decisive property interest. A non-resident, Cartwright had thought himself qualified, because he owned a minority stake in a corporation that owned real estate in town: 20/400 shares in the Sussex Sands Inc., a corporation that owned and operated the Sands Motel. Citing an unpublished “municipal policy” that granted only majority stockholders of property-owning corporations the right to run for office, the town council rejected Cartwright’s bid for candidacy – and he found a lawyer to contest the rejection. His attorney, Robert C. Wolhar, discovered that “at least three of the current councilmen” in Fenwick were similarly deficient – owning only a minority share of the same motel corporation. A town council thusly improperly constituted, Wolhar alleged, could not govern legally, and thus “all the ordinances and police arrests made in the small seaside town may be illegal because some of the commissioners … were seated illegally.” [13] 

The Delaware Department of Justice, following its characteristic approach to white collar law enforcement, declined to pursue the matter. The next Fenwick election – with a high turnout of 400 – swept in a slate of fully qualified candidates, seemingly resolving the immediate issue.[14] Following this dispute, Fenwick amended it’s charter several times in the early 1980s, using increasingly convoluted language to define qualifications for voters and candidates for office. In 1986, it settled on the exclusion of “freeholders” who “who claim title to real property by virtue of their ownership rights in a limited partnership, a corporation, or other fictitious name association, or in special circumstances, where an organization is formed for the apparent or express purpose of taking title to property principally to acquire the right to vote, or a person or persons who claim title to less than 50 percent of the real property which is owned jointly with a corporation, limited partnership, or fictitious name organization.”[15] How the town council was to discern the “apparent or express” purpose of a corporation was not specified.


Sidebar: Sussex Sands, Inc., the corporation that owned the Sands Motel and in which Cartwright and several town councilmen owned minority shares, remains a going concern. John Caldwell, the owner and operator of the motel (and failed town council candidate himself) died in 1982, but his widow remains listed as the registered agent for the corporation, at the motel's original address (a comparison of a 2012 Google Street View image and a 1979 postcard featuring the motel reveal the property to be the same). In 2020 the motel was remodeled and renamed, and is now branded as an upscale Hilton property, “Fenwick Shores.”[16]

The latest major change with regard to corporate voting in Fenwick Island was made by amendment in 2008. In a sweeping revision of the charter’s voter qualification section, the amendment inserted a by-then increasingly common (in Delaware) “one-person/entity, one vote,” provision, limiting both natural persons and artificial entities to one vote, total, no matter how many parcels of property they owned. It also specified more clearly the documentation needed for corporations (a notarized power of attorney designating a proxy voter; corporations still need humans to take action). 

In keeping with twenty-first century Delawarean practice, the provision of corporate voting went unremarked in public discussions of the  amendment process. The town manager, Anthony Carson, justified the revision only in terms of needing to increase the town’s “outdated” credit limit, raise funds sufficient to build a new “public safety building.” At least in news reports, the “one person/entity” rule – or corporate voting, more generally – did not warrant a mention. [17] A 2018 charter amendment increased the burden on human voters  – requiring more identification to establish residency – but left procedures for corporate voters unchanged. [18]

~~~

Human democracy – government for the people, by the people – has never taken firm root in the sandy soils of Fenwick Island. A land imagined speculatively from its first legal organization, property has always called the shots there. Controversy over governing power, when it has occurred, has been over how much control a given person (natural or legally fictitious) has over real estate title – not whether people matter more than property. 

Fenwick Island, then, mirrors in some ways Delaware’s increasingly unambiguous preference for corporate controllers over community stakeholders. Whether it’s taxes at the beach, or plaintiffs at the bar, the state’s governing institutions seem to incline to consolidated power over any other available option. It remains to be seen how this system will weather the strong storms we know are coming.

—–

Header Image Source: Sands Beach Resort Motel, 1979, Postcard, 21 x 9 cm, Special Collections, University of Delaware Library, GRA 0138, Delaware Postcard Collection, https://digitalcollections.udel.edu/Documents/Detail/sands-beach-resort-motel/164590.

[1] Corporations and other artificial entities, including “partnerships, trusts, and limited liability companies” – provided they are domiciled in the state, and own property in the town. Charter of Fenwick Island, Sec. 9(A)(2), State of Delaware, accessed January 20, 2026, https://charters.delaware.gov/fenwickisland.shtml&nbsp;

[2] 76 Del. Laws, c. 363 (2008)

[3] Charter of Fenwick Island, Sec. 6 and Sec. 9, State of Delaware, accessed January 20, 2026, https://charters.delaware.gov/fenwickisland.shtml&nbsp;

[4] ACLU-DE Files Lawsuit Against Fenwick Island for Allowing Corporations to Vote in Local Elections, (ACLU Delaware), December 3, 2025, https://www.aclu-de.org/press-releases/fenwick-corporate-voting/ ; Jacob Owens, “ACLU Sues Fenwick Island over Non-Resident Voting,” Spotlight Delaware, December 5, 2025, https://spotlightdelaware.org/2025/12/05/aclu-sues-fenwick-island-over-non-resident-voting/. (NB that the Spotlight article significantly misstates the core contention of the ACLU’s suit: the organization is contesting Fenwick’s practice of non-human voting – not non-resident voting).

[5] Kerin Magill, “Fenwick Island Responds to ACLU Lawsuit,” Coastal Point, December 12, 2025, https://www.coastalpoint.com/news/communities/fenwickisland/fenwick-island-responds-to-aclu-lawsuit/article_0ff740be-481b-43c5-8271-6c2faaae1899.html.

[6] The newspaper reporting on Layton’s purchase is somewhat contradictory, but it appears he gained title to the island by buying out two members of the Gum family, Dr. F. M. Gum and William A. Gum, for a total of $6,750, in separate transactions. Layton’s purchase was covered in an amused tone by otherwise bored legislative reporters, who noted his enthusiasm for the property and its possibilities for duck hunting and sheep herding . “Bought Fenwick Island,” Morning News, April 10, 1893, p. 4; “Legislative notes,”Every Evening, April 18, 1893, p.1; “They Own the Whole Island,” Evening Journal, April 28, 1893, p.5;  “Clerk Layton’s Purchase,” Every Evening, April 28, 1893, p.1. 

There were earlier Delaware corporations with “Fenwick Island” in their names, but these appear to have been aimed at improving water infrastructure – ditch digging. See 14 Del. Laws, c. 149 (1871), “An Act to Incorporate the Fenwick’s Island Improvement Company,” March 15, 1871, pp. 217-220; 18 Del. Laws, c. 375 (1887), “An Act to Incorporate the Fenwick’s Island Beach Company,” April 14, 1887.

[7] “A Fenwick’s Island Boom,” Every Evening, April 19, 1893, p.2; 

 19 Del. Laws, c. 982 (1893), “An Act to incorporate the Fenwick Island Gunning Club,” April 24, 1893; 19 Del. Laws, c. 722 (1893), “An Act to incorporate the Fenwick Island Company,” April 25, 1893 pp. 972- 975. (On shareholder rights, see 19 Del. Laws, c. 722 (1893), p. 973-74.)

[8] “Fenwick Island Camp,”Every Evening, April 25, 1921, p.6; “State Offers Vactionists Rest,”Newark Post, July 26, 1922,p.2 ; “Delaware Vacation Spots Attract Pleasure Seekers,”Morning News, Feb. 27, 1937, p.27 

[9] “Ask Right to Buy Land,”Morning News, June 16, 1938, p.20; “Fenwick Island Land Sale Ready,” Morning News, January 5, 1942, p.18;  “Delaware to Sell Fenwick Island Land: Owners of Cottages Get Right to Buy Lots on Ocean Front,”Daily Times (Salisbury, MD), Jan. 5, 1942, p.8 

[10] “Other New Bills,” The Morning News, March 27, 1953, p.10; “Other Bills Passed,” Morning News, July 2, 1953, 40; 49 Del. Laws, c. 302 (1953), “An Act to Incorporate the Town of Fenwick Island, Delaware,” July 8, 1953, pp. 602-23 (on voter qualifications, see p.606, on taxes, p. 612).

In 1962, a Washington DC paper reporting on Fenwick’s amenities for vacationers – including a beach that coughed up silver dollars – noted that “the council is elected by everyone registered on the property tax rolls.” See: Janet Koltun, “Money Banks Deposits Dwindle but Fun Rises,” Evening Star (Washington, DC), Aug. 5, 1962, C-6

[11] 55 Del. Laws, c. 89 (1965), “An Act to Amend Chapter 302 … ‘ An Act to Incorporate the Town of Fenwick Island, Delaware’ By Authorizing the Borrowing of Money and Issuing Bonds Therefore…,” (May 27, 1965), pp. 360-62.

[12] 62 Del. Laws, c. 3 (1979), “An act to amend chapter 302…,” February 6, 1979, p.4

[13] Ed Shur, “Arrests May Be Illegal,”Daily Times (Salisbury, MD), July 14, 1981; Grayson Smith, “Fenwick Election Imperiled,”Morning News, July 14, 1981, p. C2 

[14] “Two Candidates run into flap in Fenwick election,”Morning News, July 31, 1981, p.C4; “Election Settles Issue in Fenwick,”Morning News, Aug 2, 1981, p.B2 

[15] 65 Del. Laws, c. 321 (1986), p. 603. Prior amendments include: 64 Del. Laws, c. 53 (1983). p. 110 and 63 Del. Laws, c. 371 (1982), p.775.

[16] Sussex Sands, Inc., file no. 858088, Entity Search Database, Delaware Division of Corporations, https://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspxSands Beach Resort Motel, 1979, Postcard, 21 x 9 cm, Special Collections, University of Delaware Library, GRA 0138, Delaware Postcard Collection; “J.R. Caldwell, Sands Motel owner, dies,” Morning News, Feb. 2, 1982, C4; 

[17] 76 Del. Laws, c. 363 (2008) ; Andrew Ostroski, “Fenwick Island Officials Meet to Change Charter,”Daily Times, July 25, 2008, B4. 

[18] 81 Del. Laws, c. 258 (2018).

Corporate Voters Project

The Persistence of Oligarchy 

Or, What’s a Little Light Voting Restriction Between Friends, Across Decades?

Corporate Voters Project – Research Note #3


 
Having surveyed the swampy landscape of corporate voting in present-day Delaware, I’ve now turned to digging post holes in it. That is, to get a clearer sense of when as well as why the practice of enfranchising business entities took hold, I’m taking a closer look at a handful of municipalities with corporate citizens, by investigating the legal history of their charters – specifically, when corporate voting entered their basic law – and trying to contextualize those developments using historical newspapers. 

First up? Dagsboro, Delaware.  

~*~

Ten miles from the coast as crows and google maps fly, Dagsboro was first incorporated in 1899. The town proper was carved out of Dagsborough Hundred, in Sussex County. (“Hundreds” are unincorporated subdivisions of counties – not unique to Delaware, but unusually long-lived here, where they served as the primary local political unit from the colonial era through to the 1940s. Most were defined by waterways: “White Clay Creek Hundred,” in what is today Newark, centered on said creek, for example; there’s a similar story behind the much more metal “Murderkill Hundred”) [1]. 

According to Thomas Scharf, the excitable, voluble, and occasionally reliable nineteenth-century chronicler of Delaware history, Dagsborough Hundred was named after its lead proprietor under late British rule, John Dagworthy. Alternately described by Scharf in the course of one printed page as a captain, colonel, and general, in 1774, Dagworthy was granted generous tracts of land – known as “Dagworthy’s Conquest” – as a reward for military service rendered, and well-placed connections worked, in the Seven Years’ War. He repaid this boon during the American Revolution by seizing British war matériel and arresting accused loyalists. When not offering such forceful signs of ingratitude to the British Crown, Scharf records that “General” Dagworthy

“built a capacious one story house upon an eminence at the east end of the town…The approach was a broad avenue lined with trees. There surrounded by his family and a retinue of slaves he dispensed a liberal hospitality.”[2]

What a swell a petty tyrant, eh? 

When he died, Dagworthy was buried under the chancel at Prince George’s Chapel, a tiny but persistent house of worship, just off the main drag of what became the Town of Dagsboro in 1899.

Dagsboro’s inaugural charter has a number of interesting features – but corporate voting is not one of them. The municipal franchise, per Section 3, is reserved for tax-paying property owners: “every male taxable of said town above the age of twenty-one years” as well as the “husbands of woman freeholders in said town.” (It pays to marry well!) 

The franchise was premised on landholding – a “freeholder” is a resident who owns real estate in fee simple – and, critically, paying in to the town treasury: to vote you had to be up-to-date on your assessed taxes.[3]

The amount of tax you paid mattered, too. You’ve heard of voting with your dollars? Well, so had the legislators who chartered Dagsboro. In their wisdom, they decided that this jumped-up village was going to be an oligarchy, not a democracy. At town elections “each person entitled to vote shall be entitled to one vote for each dollar, or fractional part thereof, which shall have been paid by them or their wives as town tax on the property so assessed.”

To put it more plainly: the more land you owned, and the more tax you paid, the more votes you could cast! Like most oligarchies, this regime lasted only a short while: in 1903, the charter was amended to eliminate the vote-per-dollar scheme – though voting was still restricted to landowners, or men who married women who owned land.[4]

The press noted the Dagsboro charter’s passage through the legislature in January 1899 only perfunctorily. There are more stories about the sick wife of the charter bill sponsor (and first town commissioner), Rep. William P. Short, and his subsequent arrest for bribery (later dismissed), than there are about Dagsboro’s creation itself. 

That’s understandable: a town with at best one crossroads warrants little notice most days, and much less in a year when Delaware politics were as lively and consequential as they ever get. Dagsboro’s competition for column inches was, first, the extensive extralegal efforts of one J. Edward Addicks, erstwhile Republican, to bribe himself into the U.S. Senate (Rep. Short was part of that effort – caught but not prosecuted); and then second, the total revolution in the state’s political economy, via the wholesale adoption of the New Jersey corporate code. (This was Delaware’s bid to steal their northern neighbor’s revenue scheme – though it took until 1913 for fruit of that poisonous tree to fully ripen).[5] 

~*~

Corporate voting first appeared in Dagsboro with the town’s re-chartering and re-incorporation in 1941. So far, I have only found spare notices of this in state or local newspapers: Sen. Alden P. Short shepherded the bill through the General Assembly, but what his relation was to William P. Short, or why 1941 was the year to do this civic business, remains unclear.[6] 

What is clear, though, is that the 1941 charter enfranchises corporations to vote in bond referenda. In these “special elections,” residents and property owners, “whether individual, partnership or corporation” all received “one vote for every dollar and fractional part of tax paid.” Oligarchy, again!

Voting for annual municipal elections in Dagsboro was, in this revision, more open – reserved for taxpayers 21 and over, with no stated racial or gender restrictions – but the process became malignly unusual. To indicate their choice for town commissioner, voters “shall cross out the names of all candidates which he or she does not desire to vote for” – that is, in Dagsboro you vote via negation. I read this as a form of Jim Crow-restrictions in action: a purposefully confusing process put in place to allow white election officials to reject votes at their discretion. [7]

And while thus far, I have not found any newspaper accounts that shed light on why this re-incorporation happened when it did, I think it’s notable that the bond referenda section re-used the 1899 charter’s “one dollar, one vote” mechanism – even while other voting restrictions were loosened, or altered.

The past is never truly past, especially if property is involved.

~*~  

In 1991, the Town of Dagsboro re-incorporated again, and once again revised its charter. This time corporate voting was brought fully into all elections, both annual and special. The path, again, for corporate enfranchisement was property ownership – though now limited to one vote per person/entity.[8] As with the 1941 revisions, the motivation for this overhaul is not immediately clear from the newspaper record – but there is a notable coincidence, involving sewers.

The charter revision bill was sponsored by Sen. Richard S. Cordrey, a powerful pol from nearby Millsboro, who was then serving as Senate pro-tem. And while Cordrey’s other initiatives made the newspapers regularly – there was a redistricting that session, as well as smaller fights with the Governor over appointments and the budget – Dagsboro’s new charter only appears in the press as a one-line entries in legislative recap articles.[9]   

What did make the papers was a slow-moving effort by Sussex County to build new sewers to accommodate an ongoing wave of new residents and housing developments. Beginning in 1990, the County and affected towns – including Dagsboro – were involved in a series of lawsuits and legislative wrangling to select sites for wastewater treatment and disposal. By 1991 work was sufficiently underway on the job of replacing Dagsboro’s private septic systems with a County-administered municipal flush that the Wilmington News Journal, the state’s biggest newspaper, thought it warranted a town profile. 

The New Journal’s Southern Delaware correspondent noted the Dagsboro was a sleepy place, with one hill, one stoplight, and one predatory, “hawk-eyed lawman” eager to “fatten the town’s coffers” with tickets written to out-of-towners. But beyond that picaresque character, the story was that Dagsboro’s citizens – and possibly it’s corporate voters, too – expected the sewers to set off a “boom time,” attracting new residents and new economic vibrancy into the town.[10]

My hunch is that sewers and corporate voting are linked, both metaphorically and politically. The 1991 charter revision, by empowering non-resident property owners, both human and corporate, could have been part of a horse trade, to get the infrastructure investment needed to enable a “boom time.” Giving corporations the vote could have been what was needed to get them to invest in the project of the town’s growth – and in return, corporations got to help decide how much they’ll pay for all the new shit they bring. 

Call it the “Cum Cloacarum et Corporationes, Civitas” theory of government.[11] 

~*~

For the curious and civic-minded, the Town of Dagsboro website explains local election procedures. If you are a human resident – but not lucky enough to be a property owner – you face some hurdles. You have to present yourself with identification and documentation at the Town Hall office, during business hours, to be certified and entered into the town voter registration book. (Unlike other Delaware municipalities, Dagsboro does not participate in the state voter registration system). Then, come election time, provided the clerk can find and verify you in that book, you can vote.

However, if you are a property owner – whether a natural person or artificial entity – your task is requires less of a time expenditure. Simply appear at the polling place with your name on a deed to a property within the corporate limits; and if “you” are a business entity – a partnership, or a corporation – you proxy must appear with that deed, plus “a certified resolution of said entity authorizing the person therein to vote for the entity.” Two pieces of paper, and you’re golden, no fuss, no waiting. 

The Town of Dagsboro helpfully provides a standard certification form; all a corporation needs to do is fill in the blanks. 

——–

[1] The best and most detailed account of Delaware’s extraordinarily creaky administrative state that I have encountered is Penjerdel Corporation and Pennsylvania Economy League, Historical Development of Local Government in the Penjerdel Region, Penjerdel Governmental Studies 1 (Philadelphia, PA: Penjerdel, 1961), https://catalog.hathitrust.org/Record/005888599.

[2] J. Thomas Scharf, History of Delaware, 1609-1888, 2 vols, (Philadelphia: L. J. Richards & co., 1888), 2:1335, https://catalog.hathitrust.org/Record/001874039.

[3] 21 Del. Laws, c. 285: “An Act to Incorporate the Town of Dagsboro,” Approved February 9, 1899, pp. 549.

[4] 22 Del. Laws, c. 437: “An Act to Amend Chapter 285, Volume 21, Laws of Delaware, Being Entitled ‘An Act to Incorporate the Town of Dagsboro, Approved February 9, 1899’,” Approved March 31, 1903, p.435. 

Special thanks is due to Willard Hall Porter, Attorney at Law, who annotated his personal copy of the Laws of Delaware in bright red pencil to note this charter update. His copy was scanned in and made available by Princeton University via Hathi Trust. It takes a (long-dead) village to write a history, y’all!  

[5] Typical of press coverage of the charter is “Legislature,” News Journal, Mon, May 5, 1941, p.4. On Short’s wife’s pneumonia, “Mr. Short’s Sad Message,” Wilmington Daily Republican, February 24, 1899, p.2.  On his dismissed bribery indictment: “Kent Bribery Cases,” Middletown Transcript, April 29, 1899, p.3, https://chroniclingamerica.loc.gov/lccn/sn84026820/1899-04-29/ed-1/seq-3/

[6] 43 Del. Laws, c. 161:  “An Act to Reincorporate the Town of Dagsboro,” Approved May 14, 1941; “Legislature,” News Journal, Mon, May 5, 1941, p.4.

[7] On bond elections, 43 Del. Laws, c. 161, Sec. 22(B)6; on regular muncipal elections, Sec. 5(D). 

[8] 68 Del. Laws, c. 138; “An Act to Reincorporate the Town of Dagsboro,” Approved July 9, 1991. On annexations, see Sec. 3(F); on muncipal elections Sec. 7(G); and on bond referenda, Sec 33(A)5

[9] “Legislature,” News Journal, Thu, June 20, 1991, p.19; “Legislature,” News Journal, Thu, June 27, 1991, p.15; “Legislature,” News Journal, Sat, June 29, 1991, p.7; Nancy Kesler, “Castle OKs restrictions on adult entertainment,” News Journal, July 10, 1991, p.12

[10] Carolyn Lewis, “Sleepy Dagsboro gets wake-up call: Boom time predicted as sewer system nears completion,” News Journal, Tues Dec 24, 1991, A4. 

On the Susex sewers saga – which involved the legislature overturning a Chancery Court decision within weeks of its announcement – see:  Bruce Pringle, “Court Blocks Sewer Plants Outside District,” News Journal, Wed, Mar 21, 1990, p.1;  Bruce Pringle, “Sussex: Change Sewer District Rules,” News Journal, Thu, Mar 22, 1990, p.1; Bruce Pringle, “Sussex OKs boundaries for sewer district,” News Journal, Fri, Mar 23, 1990, p.5 ; Nancy Kessler, “Castle Signs Sussex County Sewer District Bill,” News Journal, April 19, 1990, p.22; “Sussex County Has Eye On Parcel,” News Journal, May 30, 1990, p.2; Bruce Pringle, “Decision on Sussex disposal site expected within 2 weeks,” News Journal, Thu, June 28, 1990, p.1; Bruce Pringle, “Piney Neck Picked for sewage disposal site,” News Journal, Wed, July 4, 1990, p. 1

[11] Google translate latin for “With Sewers and Corporations, [the] City.”