2026-08-17 · Delaware · Courts

Delaware's manufactured home community statute gives a resident twelve days from the mailing of a notice to cure a violation. A three-judge Justice of the Peace panel has now shown exactly how that clock runs, and how short it is.

Sun Communities, Inc. d/b/a Sea Air Village v. Weicksel, C.A. No. JP17-26-001846, was decided May 29, 2026 after a trial de novo before a three-judge panel of Justice of the Peace Court No. 17 in Sussex County, the order signed by Justice of the Peace William Wood.¹

What happened

The community owner sought possession of a mobile home lot in Rehoboth Beach for subletting without approval, in violation of the lease and the community rules.

Two sub-tenants testified. One had rented from the leaseholder at $900 a month from August 2024 to November 2025; another at $700 a month from March to April 2026.

Written notice specifying the condition was given October 24, 2025. No corrective action was taken during the cure period. The tenant was warned that a further violation would terminate the lease. He repeated it.

The statutory mechanics

Section 7016(b)(2) of Title 25 governs noncompliance based on a condition on or of the premises. The community owner must give written notice specifying the condition and allow 12 days from mailing to cure. If the tenant remains in noncompliance after the twelve days, the owner may terminate immediately and bring a summary possession action.²

The panel found the sequence satisfied and entered judgment for possession and costs. A co-signer who never occupied the lot was removed as a party.

1. Sun Communities, Inc. d/b/a Sea Air Village v. Weicksel and Sharrar, C.A. No. JP17-26-001846 (Del. J.P. Ct. No. 17, May 29, 2026) (three-judge panel) ↩
2. 25 Del. C. ch. 70, subch. II — § 7016 (termination and noncompliance; 12-day cure from mailing) ↩