Justia Delaware Supreme Court Opinion Summaries

Liberty commenced this action against the Trustee under the Indenture, seeking injunctive relief and a declaratory judgment that the proposed Capital Splitoff would not constitute a disposition of "substantially all" of Liberty's assets in violation of the Indenture. The Court of Chancery concluded, after a trial, that the four transactions at issue should not be aggregated, and entered judgment for Liberty. The Court of Chancery concluded that the proposed splitoff was not "sufficiently connected" to the prior transactions to warrant aggregation for purposes of the Successor Obligor Provision. The court agreed with the judgment of the Court of Chancery and affirmed. View "The Bank of New York Mellon Trust Co. v. Liberty Media Corp." on Justia Law

A jury found that defendant and a co-defendant had crashed through patio doors of the Warren family, shot and killed Kenneth Warren in front of his wife and their nineteen-month-old-son. For that crime, defendant was sentenced to death. On appeal, defendant contended that the trial judge erred in admitting the out-of-court statements of his co-defendant; defense counsel was ineffective in failing to investigate DNA issues; certain evidence demonstrated that defendant was innocent, or alternatively, that a new trial was required; defense counsel was ineffective in failing to rehabilitate prospective jurors or to object to the trial judge's dismissal of them; his death sentence was unconstitutional; and defense counsel was ineffective in failing to conduct an adequate mitigation investigation and to present that mitigation evidence to the trial judge and jury. The court held that defendant was not entitled to postconviction relief or a new trial where defendant's first claim was procedurally barred; defendant's second claim failed because he had not shown prejudice; defendant's third claim failed for the same reason; defendant's fourth claim failed because he had not shown that defense counsel's performance was deficient; defendant's fifth claim was procedurally barred; and defendant's sixth claim failed because he had not shown prejudice. Accordingly, the court affirmed the judgment. View "Swan v. State" on Justia Law

Defendant was convicted of several crimes arising from the death of his fiancee and defendant was sentenced to death. Defendant subsequently appealed his convictions and death sentence. The court held that the trial court properly applied this court's holding in Cooke v. State to the circumstances of this case and did not deprive defendant of his Sixth Amendment right to the effective assistance of counsel. The court also held that there was sufficient evidence for a rational jury to find defendant guilty of Abuse of a Corpse beyond a reasonable doubt. The court further held that the judge in this case imposed the death sentence after adequately careful and deliberate consideration. The court finally held that defendant's death sentence, on the facts of this case, was not unlawfully disproportionate compared to the sentences imposed in similar cases. Accordingly, the court affirmed the judgment. View "Taylor v. State" on Justia Law

The Delaware Department of Health and Social Services (DHSS) appealed from a Superior Court order reversing a DHSS Administrative Hearing Officer's decision to place Madhu Jain on the Adult Abuse Registry for three years, because Jain had "neglected" a patient as defined by 11 Del. C. 8564(a)(8) and 16 Del. C. 1131(9). On appeal, DHSS claimed that the Superior Court erroneously concluded that DHSS had failed to show that Jain neglected the patient within the meaning of the two statutes because Jain's conduct breached basic, fundamental nursing standards. The court held that the facts did not support a finding that Jain committed an act of neglect, recklessly, knowingly, or intentionally. Therefore, the court affirmed the Superior Court's judgment. View "Dept. of Health & Social Servs v. Jain" on Justia Law

The police arrested defendant at a private party and based on evidence seized on the night of defendant's arrest, a magistrate issued a warrant to search his home. While executing the warrant, police discovered drugs and firearms in defendant's residence. Defendant was subsequently convicted of drug crimes committed on the evening of the arrest and defendant was later convicted of drug and firearm offenses related to the items seized at his home. Defendant appealed both his convictions, contending that the Superior Court judge erred by denying his motions to suppress. The court held that because the police illegally seized defendant when they obtained the drugs leading to his initial arrest, the evidence against him, including evidence seized from defendant's home, constituted inadmissible fruit of the poisonous tree. Accordingly, the court reversed. View "Jones v. State" on Justia Law

In two similar cases, Lincoln National Life Insurance Co. v. Joseph Schlanger Trust (Schlanger) and PHL Variable Insurance Co. v. Price Dawe 2006 Insurance Trust (Dawe), an insurer sought a judicial declaration that a life insurance policy was void as an illegal contract wagering human life that accordingly lacked an insurable interest. The district court denied both motions to dismiss and certified three questions to the Supreme Court of Delaware concerning the incontestability provision under 18 Del. C. 2908 and the insurable interest requirement under 18 Del. C. 2704. The certified question, shared by both Dawe and Schlanger, concerned whether an insurer could claim that a life insurance policy never came into existence, on the basis of a lack of insurable interest, where the challenge occurred after the insurance contract's mandatory contestability period expired. The court answered in the affirmative and held that a life insurance policy lacking an insurable interest was void as against public policy and thus never came into force, making the incontestability provision inapplicable. The second certified question concerned whether the statutory insurable interest requirement was violated where the insured procured a life insurance policy with the intent to immediately transfer the benefit to an individual or entity lacking an insurable interest. The court answered in the negative, so long as the insured procured or effected the policy and the policy was not a mere cover for a wager. The third certified question concerned whether the relevant statutory provisions conferred upon a trustee an insurable interest in the life of the individual insured who established the trust if the insured intended to transfer the beneficial interest in the trust to a third-party investor with no insurable interest. The court answered in the affirmative, as long as the individual insured actually established the trust. If, however, the insured did not create and fund the trust then the relationship contemplated under section 2704(c)(5) was not satisfied. View "PHL Variable Ins. Co. v. Price Dawe 2006 Ins. Trust, et al." on Justia Law

In two similar cases, Lincoln National Life Insurance Co. v. Joseph Schlanger Trust (Schlanger) and PHL Variable Insurance Co. v. Price Dawe 2006 Insurance Trust (Dawe), an insurer sought a judicial declaration that a life insurance policy was void as an illegal contract wagering human life that accordingly lacked an insurable interest. The district court denied both motions to dismiss and certified three questions to the Supreme Court of Delaware concerning the incontestability provision under 18 Del. C. 2908 and the insurable interest requirement under 18 Del. C. 2704. The certified question, shared by both Dawe and Schlanger, concerned whether an insurer could claim that a life insurance policy never came into existence, on the basis of a lack of insurable interest, where the challenge occurred after the insurance contract's mandatory contestability period expired. The court answered in the affirmative and held that a life insurance policy lacking an insurable interest was void as against public policy and thus never came into force, making the incontestability provision inapplicable. View "The Lincoln Nat'l Life Ins. Co. v. Joseph Schlanger 2006 Ins. Trust, et al." on Justia Law

Defendant was convicted of crimes related to the attempted murder of the victim on January 26, 2006, and the subsequent murder of the victim on April 2, 2007. On appeal, defendant contended that the trial court abused its discretion by denying defendant's motion to sever the trial of the attempted murder case from the murder case; that his right to a fair trial before an impartial jury was violated when the evidence presented at trial did not clearly and convincingly establish the State's proffered "other crime" evidence of motive, due to the unwillingness of a State witness to testify; and his due process rights were violated when the trial judge denied his motions to suppress two separate pretrial eyewitness identifications. The court held that defendant's arguments were without merit and therefore, affirmed the judgments of the Superior Court. View "Monroe v. State" on Justia Law

CML, a junior secured creditor of JetDirect, sued JetDirect's present and former officers directly and derivatively for breaching their fiduciary duties. The Vice Chancellor dismissed all four of CML's claims. The court affirmed the judgment because CML, as a JetDirector creditor, lacked standing to sue derivatively on JetDirect's behalf. View "CML V, LLC, et al. v. Bax, et al." on Justia Law