Justia Delaware Supreme Court Opinion Summaries

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Magdalena Guardado, an undocumented worker, was employed as a machine manager for Roos Foods when she was involved in a work-related accident. She injured her left wrist and thereafter received total disability benefits. The employer petitioned the Industrial Accident Board (“the Board”) to terminate those benefits on the ground that the worker was no longer disabled and could return to work. The Board found: (1) the employer met its initial burden of showing that the worker was no longer totally disabled; (2) that the worker was a prima facie displaced worker based solely on her status as an undocumented worker; and (3) the employer had failed to meet its burden of showing regular employment opportunities within the worker’s capabilities. Accordingly, it denied the employer’s petition. The questions this case presented for the Delaware Supreme Court's review were: (1) whether an injured worker’s immigration status alone rendered her a prima facie displaced worker; and (2) whether the Board properly found that the employer failed to meet its burden of showing regular employment opportunities within the worker’s capabilities because its evidence failed to take into account the worker’s undocumented status. The Court concluded that an undocumented worker’s immigration status was not relevant to determining whether she was a prima facie displaced worker, but it was a relevant factor to be considered in determining whether she is an actually displaced worker. The Court also concluded that the Board correctly rejected the employer’s evidence of regular employment opportunities for the worker because that evidence failed to consider her undocumented status. View "Roos Foods v. Guardado" on Justia Law

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Trascent Management Consulting, LLC hired a top executive, George Bouri, giving him part ownership, naming him Managing Principal, and naming him as a member of the Board of Managers of Trascent with responsibility for human resources, IT, and finance. Bouri occupied these positions for about sixteen months. When Trascent terminated Bouri and sued him, for among other things, violating his employment agreement, Bouri sought advancement to defend himself in accordance with the plain language of both his employment agreement and Trascent’s LLC agreement. Belatedly in the process of defending Bouri’s motion for summary judgment, Trascent argued that the same employment contract on which many of its claims against Bouri were premised was induced by fraud and that Bouri could not receive advancement because the employment agreement was thereby invalid (and presumably that he would not have become a member of Trascent’s board, and thus be entitled to advancement, under the LLC agreement absent that contract). The Court of Chancery rejected that defense to advancement, relying on the plain language of the agreements, which required that advancement be provided until a court made a final, nonappealable determination that indemnification was not required, and on the summary nature of the proceedings under 6 Del. C. sec. 18-108 (the LLC analogue to 8 Del. C. sec. 145). Trascent appealed, arguing the Court of Chancery erred in that ruling. Finding no reversible error after its review, the Delaware Supreme Court affirmed the Court of Chancery's judgment. View "Transcent Management Consulting, LLC v. Bouri" on Justia Law

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In 2003, Zubin Mehta and Gregory Shalov formed Finger Lakes Capital Partners as an investment vehicle to own several operating companies. Mehta and Shalov contacted Lyrical Partners L.P. to participate in their venture. The parties signed a term sheet covering their overall relationship, as well as topics relating to two specific investments. On the advice of counsel, Finger Lakes held each of its portfolio companies as separate limited liability companies with separate operating agreements. Over the course of a decade, the companies did not perform as expected. Finger Lakes asked Lyrical for additional capital. The parties agreed to allow Lyrical to “clawback” its investment money as added protection for its continued investment in the enterprise. Only one investment performed well and generated a substantial return when it was sold. The others failed or incurred substantial losses. The parties disagreed about how the proceeds from the one profitable investment should have been distributed under the network of agreements governing their business relationship. The Court of Chancery held that the proceeds should have been distributed first in accordance with the operating agreement governing the investment in the profitable portfolio company; the term sheet and clawback agreement would then be applied to reallocate the distribution under their terms. Finger Lakes argued on appeal that the profitable investment entity’s operating agreement superseded the overarching term sheet and clawback agreement; even if the clawback agreement was not superseded, the Court of Chancery applied it incorrectly; Lyrical could not recover its unpaid management fees through a setoff or recoupment; and, the Court of Chancery improperly limited Finger Lakes’ indemnification to expenses incurred until Finger Lakes was awarded a partial judgment on the pleadings, instead of awarding indemnification for all expenses related to these proceedings. With one exception, the Supreme Court affirmed the Court of Chancery’s judgment with respect to that court's interpretation of the operating agreements. The Supreme Court found, however, that the Court of Chancery erred when it held that Lyrical could use setoff or recoupment to recover time-barred management fees. Further, Lyrical could not assert its time-barred claims by way of recoupment because the defensive claims did not arise from the same transaction as Finger Lakes’ claims. View "Finger Lakes Capital Partners, LLC v. Honeoye Lake Acquisition, LLC" on Justia Law
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This issue this case presented for the Supreme Court's review centered on whether the collateral source rule should apply when Medicaid pays for an injured party’s medical expenses. The Delaware Supreme Court held that, when Medicaid has paid an injured party’s medical expenses, the collateral source rule cannot be used to increase an injured party’s recovery of past medical expenses beyond those actually paid by Medicaid. "As with Medicare, the difference is unnecessary to make the injured party whole because it is paid by no one." Appellant Jennifer Smith, was injured in two car collisions. Although employed when her injuries occurred, Smith qualified for Medicaid coverage. At first, her treating physician sought to recover his standard charges of $22,911 from the proceeds of any personal injury settlement. But later, the treating physician opted to forego his original billed amount, and instead billed Medicaid for his charges. Medicaid paid the treating physician $5,197.71, and asserted a lien in that amount on the proceeds of any recovery by settlement or lawsuit. When all was netted out, the Superior Court entered judgment against the defendants jointly and severally for $49,911. Relying on the applicable case law, the trial court determined that “Delaware case law is clear that the collateral source rule does not apply to Medicaid or Medicare write-offs.” In its decision here, the Delaware Supreme Court refused to extend operation of the collateral source rule and affirmed the superior court's judgment. Also affirmed was the Superior Court’s ruling that future medical expenses were not subject to Medicaid reimbursement limitations. "Unlike Medicare, Medicaid coverage is income dependent, and might not be available if a plaintiff improves her financial position to a living wage and secures other insurance. Because of the uncertainty of future coverage, Medicaid benefits cannot be used to limit a plaintiff’s future medical expenses." View "Smith v. Mahoney" on Justia Law

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Appellant Greenville Country Club, through its workers’ compensation carrier, Guard Insurance (“Guard”), appealed a Superior Court Order affirming a decision of the Industrial Accident Board (the “Board”). While working for Greenville Country Club, Jordan Rash suffered injuries to his lumbar spine in two separately compensable work accidents. The first accident occurred in 2009 while the country club was insured by Guard Insurance Group. The second accident occurred in 2012 while the country club was insured by Technology Insurance (“Technology”). In 2014, Rash filed two Petitions to Determine Additional Compensation, one against Guard and one against Technology. After a hearing, the Board determined that the condition at issue was a recurrence of the 2009 work injury and not an aggravation of the 2012 work injury, and concluded that Guard was therefore wholly liable for the additional compensation to Rash. Guard appealed, arguing: (1) the Board failed to properly apply the rule for determining successive carrier liability; and (2) there was no substantial evidence to support the Board’s finding that Rash fully recovered from the 2012 accident or that his ongoing condition was solely caused by the 2009 work accident. After review, the Delaware Supreme Court found no error in the Board’s decision, and that the decision was supported by substantial evidence. Accordingly, the Court affirmed the Board's decision. View "Greenville Country Club (Guard Insurance) v. Greenville Country Club (Technology Insurance)" on Justia Law

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Defendant Tyrone Redden appealed the Superior Court’s Order denying his Amended Motion for Postconviction Relief. At issue in this appeal were two out-of-court statements introduced at Redden’s trial. In his Motion, Redden argued that his trial counsel was ineffective for failing to object to the statements after the State failed to ask each witness whether his or her out-of-court statement was truthful. Redden further argued that his appellate counsel was ineffective for failing to raise the same issue on direct appeal. The Superior Court denied the Amended Motion, holding that Redden’s claims were procedurally barred. After review, the Supreme Court agreed with the Superior Court that Redden’s claims were procedurally barred and affirmed the denial of Redden’s Motion. View "Redden v. Delaware" on Justia Law

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The State appealed the grant of post-conviction relief to defendant-appellee Damone Flowers. The Superior Court recognized that Flowers post-conviction motion was untimely under Criminal Rule 61(i)(1) because he filed it three years after his conviction became final. However, the Superior Court invoked an exception to the procedural bars as a basis for addressing Flowers' motion on the merits. At the time of Flowers' second motion for relief, the bars to relief in Rule 61(1)(1)-(3) did not apply "to a colorable claim that there was a miscarriage of justice because of a constitutional violation that undermined the fundamental legality, reliability, integrity or fairness of the proceedings leading to the judgment of conviction." After its review, the Supreme Court concluded Flowers' second motion for relief was indeed untimely and that the exception was improperly invoked by the Superior Court. Accordingly, the Court reversed the Superior Court. View "Delaware v. Flowers" on Justia Law

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Robert Ovens appealed the Superior Court’s reversal of the Delaware Human Relations Commission’s award of damages, attorney’s fees, and costs to Ovens based on the Commission’s determination that a prison was a place of "public accommodation." The Commission found that the Department of Correction (“DOC”), through its operation of Sussex Correctional Institution (“SCI”), violated section 4504(a) of the Delaware Code (known as theEqual Accommodations Law), by not providing equal accommodations to Ovens, who was deaf, while he was incarcerated. After review of the issue, the Delaware Supreme Court concluded that a prison was not a place of "public accommodation" as contemplated by the law. "Ovens’ argument hinges on his assertion that a prison is a state agency, and therefore, it falls under the second sentence of section 4502(14), which includes state agencies, local government agencies, and state-funded agencies in the definition of a place of public accommodation. But, he ignores that the second sentence of section 4502(14) cannot be decoupled from the critical language in the first." View "Ovens v. Danberg" on Justia Law

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At issue in this appeal was whether five beneficiaries of a Delaware trust could recover on their $88 million judgment against the individual trust established by a brother to one beneficiary and uncle to the rest. The judgment arose from the trustee's alleged bad faith and willful misconduct in handling the estate. A Master held that a spendthrift clause in the trustee's Trust precluded the beneficiaries from obtaining relief against the Trustee's interest. The Court of Chancery found that the beneficiaries' notice of exceptions to the Master's final report on the spendthrift issue was late, and that they forfeited their right to challenge the ruling. The beneficiaries appealed, arguing the Court of Chancery erred by not considering the merits to the beneficiaries' exceptions to the Master's ruling on the spendthrift issue. View "Mennen. v. Fiduciary Trust International of Delaware" on Justia Law
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Defendant-appellant Joel Stevenson appealed convictions for first- and second-degree unlawful sexual contact and two counts of sex offender unlawful sexual conduct with a child. On appeal of those convictions, Stevenson argued that the trial court abused its discretion in admitting certain out-of-court statements of three child witnesses rebutting defendant's allegation that the State improperly influenced the witnesses' testimony. After review of the record, the Delaware found no merit to defendant's arguments and affirmed his convictions. View "Stevenson v. Delaware" on Justia Law