Justia Delaware Supreme Court Opinion Summaries

Articles Posted in August, 2011
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Central Mortgage Company (CMC) sued Morgan Stanley after mortgages for which CMC purchased servicing rights from Morgan Stanley began to fall delinquent during the early financial crisis of 2007. CMC subsequently appealed the dismissal of its breach of contract and implied covenant of good faith and fair dealings claims. The court held that the Vice Chancellor erroneously dismissed CMC's breach of contract claims on the basis of inadequate notice where CMC's pleadings regarding notice satisfied the minimal standards required at this early stage of litigation. The court also held that the Vice Chancellor erroneously dismissed CMC's implied covenant of good faith and fair dealings claim where the claims were not duplicative. Accordingly, the court reversed the Vice Chancellor's judgment dismissing all three of CMC's claims and remanded for further proceedings. View "Central Mortgage Co. v. Morgan Stanley Mortgage Capital Holdings LLC" on Justia Law

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Intercontinental Exchange, Inc. and the Board of Trade of the City of New York, Inc. (collectively, defendants), merged in 2007. Plaintiff was a member of the Board of Trade before the merger and the merger agreement required that if a member, including plaintiff, wished to continue in the newly merged enterprise, the member had to submit an Election Form specifying that preference by a stated deadline. Plaintiff did not receive the Election Form until after the deadline had passed and thereafter, defendants learned that many members, including plaintiff, had failed to submit the Election Form. Defendants waived the deadline and then, in an ad hoc manner and without notice to any member, imposed a new deadline. Defendants subsequently decided that plaintiff's Form was untimely and, of all the post-deadline-filled Forms, plaintiff's Form was the only one that defendants deemed untimely and refused to honor. Thereafter, plaintiff filed an action alleging breach of contract and the Court of Chancery ruled in favor of defendants. The court concluded, however, that defendants waived the initial deadline and also failed to retract that waiver by providing reasonable notice of their new deadline. Because the retraction of the waiver was invalid as a matter of law, plaintiff's Election Form was timely. Accordingly, the judgment of the Court of Chancery was reversed and the matter remanded for further proceedings. View "Amirsaleh v. Bd of Trade of the City of New York Inc., et al." on Justia Law

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Linda Thompson appealed from a Superior Court judgment reversing the determination of the Unemployment Appeals Board (UIAB) that good cause existed for Thompson's voluntary resignation and granting her unemployment benefits. Thompson contended that good cause existed for voluntarily terminating her employment, that she exhausted her administrative remedies, and that substantial evidence in the record supported the UIAB's decision. The court affirmed the judgment of the Superior Court and held that substantial evidence did not support the UIAB's decision and the UIAB erred as a matter of law by concluding that Thompson was entitled to benefits pursuant to 19 Del. C. 3314(1). View "Thompson & UIAB v. Christiana Care Health System" on Justia Law

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Defendant appealed from a Family Court order finding him delinquent of, and sentencing him for, the offenses of Assault in the First Degree, Reckless Endangering in the First Degree, and Offensive Touching. On appeal, defendant challenged two of the Family Court's evidentiary rulings and claimed that there was insufficient evidence to support the court's adjudication of delinquency on all three charges. The court held that there was no plain error and that there was sufficient evidence to support the Family Court's finding of delinquency on all three charges. The court also held that the trial judge properly exercised his discretion in not excluding the state's rebuttal evidence. The court further held that the Family Court did not abuse its discretion in denying defendant's request to admit evidence of the victim's two convictions because there was no basis to admit that evidence as probative of defendant's claim of self-defense. Therefore, the judgments of the Family Court were affirmed. View "Wright v. State" on Justia Law