Justia Delaware Supreme Court Opinion Summaries

DTC filed a complaint with the Court of Chancery against the Union and Harry Bruckner, a para-transit driver, in the nature of a declaratory judgment action (Complaint) pursuant to Title 1, Chapter 65. The Complaint sought an order vacating or modifying a labor arbitration award issued by a certain arbitrator pursuant to a collective bargaining agreement between DTC and the Union. The award reinstated Bruckner, who was terminated by DTC, with back pay less interim earnings. The Court of Chancery granted the Union's motion for summary judgment. DTC's sole argument on appeal was that the arbitrator's decision should be vacated due to the appearance of bias or partiality on the part of the arbitrator. The court held that the alleged bias or partiality which DTC attributed to the arbitrator failed to meet the "evident partiality" standard where the mere fact that an arbitrator may share a personal life experience with a party or a party's agent was legally insufficient to constitute a substantial relationship that a reasonable person would conclude was powerfully suggestive of bias. Accordingly, the judgment was affirmed. View "Delaware Transit Corp. v. Amalgamated Transit Union Local 842" on Justia Law

Plaintiff brought this action under 8 Del. C. 220 to inspect certain books and records of defendant. More specifically, plaintiff sought to inspect one document that defendant refused voluntarily to disclose: an interim report (Covington Report) prepared by defendant's outside counsel in connection with an internal investigation into sexual harassment allegations made against defendant's former CEO. The Court of Chancery denied plaintiff relief and held that plaintiff had not demonstrated a need to inspect the Covington Report sufficient to overcome the attorney-client privilege and work product immunity protections. The court affirmed, but on the alternative ground that plaintiff had not shown that the Covington report was essential to his stated purpose, which was to investigate possible corporate wrongdoing. View "Espinoza v. Hewlett-Packard Co." on Justia Law

Defendant was found guilty of Conspiracy to Commit First-Degree Murder, but acquitted of First-Degree Murder and Possession of a Firearm During the Commission of a Felony. Defendant appealed from the Conspiracy conviction, claiming that the Superior Court erred by denying his motion for a judgment of acquittal because the evidence was legally insufficient. The court held that a rational juror could infer from the evidence that defendant wanted a co-conspirator to retaliate, that he knew the co-conspirator intended to use a deadly weapon to accomplish that retaliation, and that the shooter (whether defendant or the co-conspirator) carried out the plan exactly as intended. Given those reasonable inferences from the evidence introduced at trial, a rational juror could have also concluded beyond a reasonable doubt that defendant conspired to commit First-Degree Murder. Accordingly, the judgment was affirmed. View "Lemons v. State" on Justia Law

Appellants appealed from a Superior Court decision denying their motion for summary judgment in this matter arising from a single-vehicle accident caused by a Delaware resident in North Carolina, while operating a motor vehicle registered in Delaware. Appellants contended that the Superior Court erred as a matter of law by holding that Delaware's law of comparative negligence, and not North Carolina's law of contributory negligence, applied to plaintiff's claims of personal injuries from the accident. The court held that the record reflected that Delaware had the most significant relationship to the parties and the occurrence. Therefore, the Delaware doctrine of comparative negligence applied to plaintiff's claims against both appellants and the judgment of the Superior Court was affirmed. View "Sinnott, et al. v. Thompson" on Justia Law

SVIP brought an action in the Court of Chancery against ThoughtWorks for a declaratory judgment of the meaning of the phrase "funds legally available" as it related to ThoughtWorks' obligation under its Amended Charter to redeem Series A Preferred Stock. The court held that because the record supported the Court of Chancery's conclusion that SVIP did not show that ThoughtWorks had "funds legally available," even under its own proposed definition of that phrase, the court affirmed the judgment. View "SV Investment Partners, LLC, et al. v. Thoughtworks, Inc." on Justia Law

In an interlocutory appeal of a medical malpractice action, the court considered whether a doctor owed a duty of care to a patient after the doctor referred the patient to a specialist. The patient allegedly suffered serious injuries as a result of the specialist's negligence. The court held that the referring doctor had no duty to the patient at the time of her injury and that the referring doctor's alleged negligence was not the proximate cause of the patient's injury. Accordingly, the Superior Court correctly granted summary judgment in the referring doctor's favor. View "Spicer, et al. v. Osunkoya, M.D." on Justia Law

Plaintiff filed suit against nursing home staff members alleging that defendants committed medical negligence that resulted in his father's death. A Superior Court judge dismissed the suit, stating that plaintiff's Affidavit of Merit failed to comply with 18 Del. C. 6853 because plaintiff failed to enclose a copy of the testifying expert's curriculum vitae. The court held that, since this error was procedural, a proper exercise of the trial judge's discretion would have permitted the later submission of the curriculum vitae. Therefore, the Superior Court judge erroneously dismissed the complaint. View "Dishmon, et al. v. Fucci, et al." on Justia Law

Defendant appealed from his convictions for Reckless Burning, Burglary in the Third Degree, two counts of Criminal Trespass in the Third Degree, and three counts of Arson in the Second Degree. At issue was the trial judge's decision allowing a latent fingerprint examiner, who had also been trained in tire track and shoeprint analyses, to testify as an expert that boot and tire tracks at arson scenes were consistent with defendant's boot and tire on his mountain bike. The trial judge found the examiner to be qualified by his knowledge, skill, training, experience or education under Rule 702 of the Delaware Rules of Evidence. The court found no abuse of discretion and affirmed the judgment. View "Rodriguez v. State" on Justia Law

A real estate agent served as the seller's agent for two sales of the same house. The initial purchaser submitted a bid for the house and, the same day, hired the initial seller's agent to serve as seller's agent for the second sale. A few days later, the agent convinced the initial seller to accept the initial purchaser's bid without disclosing his conflict of interest or the purchaser's interest in flipping the house. After one day of trial concerning the initial seller's complaint against the agent alleging, inter alia, breach of fiduciary duties, the trial judge granted defendant's motion for a directed verdict. The court held that because plaintiff raised issues of material fact concerning whether defendant breached his fiduciary duties to the seller, the court remanded the case for a new trial. View "Estate of Eller v. Bartron" on Justia Law