Justia Delaware Supreme Court Opinion Summaries

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Viking Pump, Inc. and Warren Pumps, LLC sought to recover under insurance policies issued to a third company, Houdaille Industries, Inc. In the 1980's, Viking and Warren acquired pump manufacturing businesses from Houdaille. As a result, Viking and Warren were confronted with potential liability flowing from personal injury claims made by plaintiffs alleging damages in connection with asbestos exposure claims dating back to when the pump manufacturing businesses were owned by Houdaille. Houdaille had purchased occurrence-based primary and umbrella insurance from Liberty Mutual Insurance Company. Above the Liberty umbrella layer, Houdaille purchased layers of excess insurance. In total, Houdaille purchased 35 excess policies through 20 different carriers (the "Excess Policies"). Viking and Warren sought to fund the liabilities arising from the Houdaille-Era Claims using the comprehensive insurance program originally purchased by Houdaille. The insurance companies that issued the Excess Policies (the "Excess Insurers") contended that Viking and Warren were not entitled to use the Excess Policies to respond to the claims. The Excess Insurers also disputed the extent of any coverage available, particularly with respect to defense costs. The Supreme Court held, after careful consideration of the policies at issue: (1) the Superior Court correctly held that the 1980-1985 Liberty Primary Policies were exhausted; (2) the Superior Court held that 33 of the Excess Policies at issue in this appeal provided coverage to Viking and Warren for their defense costs, with many payments contingent on insurer consent; (3) the Court of Chancery correctly held that there were valid assignments of insurance rights to Warren and Viking under the Excess Policies; (4) the Superior Court was affirmed in part and reversed in part with respect to its determination of the Excess Policies' coverage for defense costs; and (5) the Superior Court erred with respect to the trigger of coverage under the Excess Policies. View "In Re Viking Pump, Inc. and Warren Pumps, LLC Insurance Appeals" on Justia Law

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On June 24, 2013, a Grand Jury indicted appellant Kahlil Lewis on charges of second degree murder, two counts of possession of a firearm during the commission of a felony, first degree reckless endangering, and possession of a firearm by a person prohibited. In December, the State filed an information charging Lewis with an additional crime, possession of a firearm by a person prohibited - negligently causing death. A few days later, the Grand Jury re-indicted Lewis. The re-indictment repeated the charges in the original indictment, and added the new charge under 11 Del. C. 1448(e)(2). In this appeal, the issue presented for the Supreme Court's review concerned whether the Grand Jury properly indicted appellee for a crime under a criminal statute mistakenly repealed by the General Assembly. Appellant argued the Grand Jury improperly indicted him for an additional crime as part of a renewed indictment incorporating earlier charges because the General Assembly repealed the statute covering the added crime before he was re-indicted. The General Assembly discovered the mistake but did not re-enact the repealed subsection until after the re-indictment. The Delaware Supreme Court held, after review and consistent with decisions interpreting a similar federal saving statute, that Delaware’s criminal saving statute permitted the State to prosecute crimes under a repealed criminal statute when the crimes were committed before the statute’s repeal. Because Lewis committed the crime before the statute was repealed, he was still subject to prosecution under the later repealed statute. Lewis also raised other arguments on appeal, but the Court found no merit to those arguments and affirmed Lewis' convictions. View "Lewis v. Delaware" on Justia Law

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Husband-appellant Alexander Jones appealed a Family Court order that entered the parties’ stipulation on property division, awarded wife-appellee Adriana Jones alimony, and ordered Husband to pay Wife an additional monthly amount for unpaid interim alimony. Husband also appealed another Family Court order denying the parties’ motions for reargument. After review of the arguments made on appeal, the Supreme Court found no merit to most of Husband’s contentions, but remanded on his claims regarding Wife’s medical and health insurance expenses. View "Jones v. Jones" on Justia Law
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Posted in: Family Law
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Delaware charged defendant Benjamin Rauf with one count of First Degree Intentional Murder, one count of First Degree Felony Murder, Possession of a Firearm During those Felonies, and First Degree Robbery. The State expressed its intention to seek the death penalty if Rauf was convicted on either of the First Degree Murder counts. In January 2016, the United States Supreme Court held in "Hurst v. Florida" that Florida‘s capital sentencing scheme was unconstitutional. In light of the "Hurst" decision, the trial court in this matter certified five questions of law to the Supreme Court, asking the Supreme Court to address the constitutionality of Delaware's state's death penalty statute; the Superior Court believed that Hurst "reflected an evolution of the law that raised serious questions about the continuing validity of Delaware‘s death penalty statute." After review, the Court concluded that Delaware's death penalty statute conflicted with the Sixth Amendment, and prior cases on the constitutionality of Delaware's capital sentencing scheme were overruled to the extent they were inconsistent with this opinion. View "Rauf v. Delaware" on Justia Law

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Tracey West was pulled over by police officer Thomas Gaul when her car was drifting back and forth in the lane. The officer saw the car swerve sharply to avoid hitting a concrete island. When he approached the car, Gaul smelled alcohol. West "staggered out of the car" and failed field sobriety tests. She was charged with an illegal lane change and driving under the influence. Before trial, West moved to suppress the evidence that she was intoxicated. She claimed that Officer Gaul lacked the reasonable suspicion required by the Fourth Amendment to make an investigative stop of her car. Thus, any evidence of her intoxication gathered after the stop should have been suppressed. After hearing testimony from the officer and reviewing the video from the police car camera, the trial judge dismissed the lane change charge, but denied the motion to suppress. The State then introduced at trial the evidence of her intoxicated state, and a jury convicted West of drunk driving. West appealed her conviction to the Superior Court, which affirmed the trial court’s ruling on the community caretaker doctrine, and also found that Officer Gaul had reasonable suspicion to stop West for driving while intoxicated. West then appealed to the Delaware Supreme Court, arguing the community caretaker doctrine did not apply, and Officer Gaul lacked reasonable suspicion as required by the Fourth Amendment for an investigatory stop of her car. Finding no reversible error, the Supreme Court affirmed. View "West v. Delaware" on Justia Law

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Defendant-appellee Isaiah McCoy was a pretrial detainee awaiting trial on capital murder and related charges. In May 2010, McCoy was arrested and charged with the murder of James Munford in Dover. He was convicted and sentenced to death at his first trial in June 2012. In January 2015, the Supreme Court reversed his conviction and remanded the case for a new trial. Using a points-based, objective risk assessment tool, the Department of Correction classified him to be held in the maximum security Secured Housing Unit (“SHU”) at James T. Vaughn Correctional Center (“JTVCC”). McCoy filed a motion in the criminal case requesting that he be transferred from the SHU to the prison’s general population on the ground that detention at the SHU was interfering with his Sixth Amendment right to assistance of counsel. The Superior Court, over the State’s objection, granted McCoy’s motion, and McCoy was, in fact, transferred to general population. While McCoy had some complaints about the adequacy of the attorney visitation rooms in the SHU and access to the library, the Superior Court based its order in significant part upon its perception of “the emotional and physical impact that prolonged, solitary placement has had on [McCoy’s] Sixth Amendment right to assistance of counsel . . . .” The Superior Court found there that it had such jurisdiction under 10 Del. C. sec. 542, 11 Del. C. sec. 6504, and several other cases, to order the transfer of a detainee from maximum security to the general population. The State renewed its jurisdictional argument in this case. After review, the Delaware Supreme Court concluded that neither the Sixth Amendment right to assistance of counsel nor the statutes and cases relied upon by the Superior Court granted it the authority to transfer a detainee from one housing unit to another in a criminal case. The order of the Superior Court was, therefore, vacated. View "Delaware v. McCoy" on Justia Law

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Milton Taylor was sentenced to death in 2001. He petitioned the Delaware Supreme Court for a writ of mandamus to direct the Superior Court to docket his second motion for post-conviction relief under Superior Court Criminal Rule 61. The State conceded that the writ should be issued. After careful consideration, the Court held that the Superior Court erroneously concluded that it lacked jurisdiction to act in Taylor’s case because of a stay of execution order entered by the United States District Court for the District of Delaware. The Delaware Supreme Court issued the writ. View "Matter of Taylor" on Justia Law

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Joann Enrique appealed the Superior Court’s grant of summary judgment for State Farm Mutual Automobile Insurance Company in an action she brought for bad faith denial of uninsured motorist (“UM”) coverage stemming from a 2005 car accident. In 2005, an uninsured driver crashed into Enrique’s car by improperly turning into her lane. Enrique suffered a fractured rib, trauma to the right knee requiring arthroscopic surgery, trauma to the left knee for which she was a candidate for arthroscopic surgery, abrasions, and soft tissue injuries. Throughout the settlement negotiations and the processing of Enrique’s claim, State Farm personnel expressed concerns about whether Enrique’s knee injuries were caused by pre-existing conditions. The record was unclear as to why there were large lapses in time during the settlement negotiations. While the parties were waiting for the Independent Medical Examiner report, in July 2008, Enrique filed suit against State Farm, seeking benefits up to the $100,000 policy limits, as well as punitive damages against State Farm for bad faith by refusing to pay up to those limits. In support of the bad faith claim, Enrique alleged that State Farm refused to compensate her up to the UM policy limits without any reasonable justification. In October 2008, the Superior Court severed and stayed the bad faith claim pending resolution of the UM damages claim. The parties then stipulated to a partial dismissal of the bad faith claim without prejudice. Due to the continuing impasse, in September 2008 State Farm decided to advance Enrique $25,000, as the parties both agreed the claim was worth at least that much. As trial approached, State Farm offered Enrique another $20,000 to settle the case, for a total of $45,000. Enrique also revised her demand, and as of January 2010, was willing to settle for an additional $65,000, representing a $90,000 demand. The parties could not bridge the gap, and the damages case went to trial in February 2010. The jury returned a $260,000 verdict. State Farm did not seek remittitur, but did appeal on an evidentiary issue. The Delaware Supreme Court affirmed, and State Farm paid the remaining $75,000 of their policy limits, costs and interests. Enrique then pursued her bad faith claim against State Farm, claiming as damages the unpaid $160,000 portion of the jury verdict, prejudgment interest, and punitive damages. The Superior Court granted State Farm summary judgment because Enrique failed to make a prima facie showing of bad faith. The court based its decision on causation issues arising from Enrique’s pre-existing knee problems (which gave State Farm a reasonable basis for its actions), State Farm’s multiple valuations of Enrique’s claim that put it below policy limits, and her failure to offer facts showing State Farm exhibited reckless indifference in handling her claim. Finding no reversible error as to the Superior Court's grant of summary judgment, the Supreme Court affirmed. View "Enrique v. State Farm Mutual Automobile Insurance Co." on Justia Law

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Caris Life Sciences, Inc. operated three business units: Caris Diagnostics, TargetNow and Casrisome. The Diagnostics unit was consistently profitable. TargetNow generated revenue but not profits, and Carisome was in the developmental stage. To secure financing for TargetNow and Carisome, Caris sold Caris Diagnostics to Miraca Holdings. The transaction was structured using a "spin/merge" structure: Caris transferred ownership of TargetNow and Carisome to a new subsidiary, then spun off that subsidiary to its stockholders. Owning only Caris Diagnostics, Caris merged with a wholly owned subsidiary of Miraca. Plaintiff Kurt Fox sued on behalf of a class of option holders of Caris. Fox alleged that Caris breached the terms of the Stock Incentive Plan because members of management as Plan Administrator, rather than the Board of Directors, determined how much the option holders would receive. Regardless of who made the determination, the $0.61 per share attributed to the spun off company was not a good faith determination, and resulted from an arbitrary and capricious process. The Court of Chancery found that fair market value was not determined, and the value received by the option holders was not determined in good faith and that the ultimate value per option was determined through a process that was "arbitrary and capricious." Caris appealed, arguing the Court of Chancery erred in arriving at its judgment. Finding no reversible error in the Court of Chancery's judgment, the Delaware Supreme Court affirmed. View "CDX Holdings, Inc. v. Fox" on Justia Law

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In this direct appeal, the issue before the Delaware Supreme Court implicated the constitutional boundaries of a trial court’s discretion to limit the scope of a criminal defendant’s cross-examination of the witnesses against him. Wayne Williams was indicted on two counts of Drug Dealing plus aggravating factors, one count of Tampering with Physical Evidence, one count of Resisting Arrest, and two counts of Possession of Drug Paraphernalia. The principal question presented on appeal was the extent to which Williams should have been permitted at trial to cross-examine witnesses concerning misconduct at the Office of the Chief Medical Examiner (“OCME”) and elicit testimony that presented an alternative explanation for the weight discrepancy involving the drug evidence in his case. The Court concluded there was no unconstitutional restriction of Williams’ confrontation rights and that the Superior Court imposed reasonable limits when exercising its discretion to limit the scope of cross-examination. In view of the overwhelming evidence unrelated to the misconduct at the OCME, the Court held that, even if the trial court had erred, the error would have been harmless beyond a reasonable doubt. Accordingly, but for the Tampering with Physical Evidence conviction which the State conceded had to be reversed, the Supreme Court affirmed Williams’ convictions. View "Williams v. Delaware" on Justia Law