Justia Delaware Supreme Court Opinion Summaries

ConAgra Foods, Inc. ("ConAgra") sued Lexington Insurance, Co. ("Lexington") alleging breach of contract and breach of the implied duty of good faith and fair dealing. ConAgra's claims arose from the alleged 2007 contamination of certain Peter Pan and Great Value peanut butter products that ConAgra manufactured. ConAgra subsequently sought coverage under its insurance policy with Lexington for personal injury claims arising from its contaminated products and Lexington denied coverage. At issue was whether the provision in the insurance policy provided coverage in light of the "lot or batch" provision in the policy. The court held that the "lot or batch" provision was ambiguous where, under one of the two reasonable interpretations, Lexington's duties to defend and indemnify were triggered. The court also held that, because the policy arguably provided coverage to ConAgra, Lexington's duty to defend was thereby triggered when ConAgra satisfied the applicable "retained limit" for a single "occurrence." Accordingly, the court reversed and remanded to ascertain the intent underlying the ambiguous policy language for purposes of determining whether there was ultimate policy coverage.

Defendant appealed a conviction for driving under the influence of alcohol when she was arrested by police officers and performed field sobriety tests. At issue was whether defendant's motion to suppress intoxilyzer test results was erroneously denied where defendant asserted that her success on the field sobriety tests constituted "overwhelming evidence" that she was not impaired by alcohol. The court held that the motion was properly denied where the Superior Court applied a proper totality of the circumstances analysis in deciding to deny the motion and where the performance results of field sobriety tests could either eliminate or elevate suspicion into probable cause but had insufficient evidentiary weight to eliminate probable cause that was already established by the totality of the circumstances before the tests were performed.

Defendant-Appellant Hubbard appeals the lower courtâs denial of his motion to suppress his custodial statement, arguing that his waiver of Miranda rights was not knowing, intelligent or voluntary. Defendant was convicted on twelve offenses, including attempted murder, carjacking, conspiracy and possession of a deadly weapon. He was sentenced to twelve life terms. Defendant argues that he was not able to âfully comprehend the nature of his Miranda rights and the consequences of abandoning those rightsâ because he was âdrunk and high.â On review of the interrogation transcript, the Court held that Defendant made an express waiver of his Miranda rights by his words and actions, and that Defendantâs motion to suppress was properly denied.