Justia Delaware Supreme Court Opinion Summaries

After an attorney filed a settlement offer under Rule 68, opposing counsel accepted the offer. Before either attorney filed the offer and acceptance with the Superior Court, the accepting attorney realized he had made a mistake, and revoked his acceptance. The attorney who had extended the offer responded to his revocation by filing the written acceptance, thereby securing a final judgment in the form of the settlement order by means of Super. Ct. Civ. R. 68’s instruction to the Prothonotary. The attorney did not mention that the written acceptance had been revoked before it was filed. Upon review, the Supreme Court reversed the Superior Court judge’s order denying the Motion to Vacate the Judgment, and remanded the case for further proceedings. View "Ceccola v. State Farm Mutual Automobile Insurance Co." on Justia Law

In this appeal the issue before the Supreme Court concerned whether the affidavit filed in support of a search warrant supported a magistrate's finding of probable cause. The affidavit described a confidential source as "past proven and reliable" without explaining the basis for that statement. In addition, the affidavit described the activities of a "drug detection K-9," but it did not state that the dog was trained and certified. Notwithstanding these omissions, the totality of the circumstances supported the magistrate's decision authorizing the search warrant. Accordingly, the Supreme Court affirmed. View "Arcuri v. Delaware" on Justia Law

Plaintiffs-Appellants WaveDivision Holdings, LLC and Michigan Broadband, LLC (collectively, "Wave") entered into two exclusive agreements with third-party Millennium Digital Media Systems, LLC ("Millennium") to purchase cable television systems from Millennium. Millennium terminated the agreements and pursued a refinancing with its note holders and senior lenders. In a separate proceeding, the Court of Chancery found Millennium liable to Wave for breach of contract and awarded Wave damages. Wave also brought an action in the Superior Court against Millennium's note holders and senior lenders, Defendant-Appellees Highland Capital Management L.P., Highland Crusader Funds, Highland Floating Rate Fund, Trimaran Capital Partners, L.P., and Pioneer Floating Rate Trust, (collectively, "Appellees"). Wave sought damages against Appellees, contending among other things, that the Appellees tortiously interfered with the Wave-Millennium contract. The Superior Court granted summary judgment to Appellees on this claim, concluding that any interference was justified under Delaware law and that Appellee Pioneer did not have actual or imputed knowledge of the underlying contract. Upon review, the Supreme Court agreed and affirmed the appellate court's decision. View "WaveDivision Holdings, LLC, et al. v. Highland Capital Management, L.P., et al." on Justia Law

Plaintiffs-Appellants Elizabeth, Edmond, John and James Plummer appealed a Superior Court order granting summary judgment in favor of Defendant-Appellee R.T. Vanderbilt Co., Inc. Vanderbilt moved to dismiss the Plummers' appeal as untimely. Vanderbilt took the position that the Superior Court's June 28, 2011 dismissal order was the final order in the matter below. Thus, Vanderbilt contended, the Plummers' notice of appeal filed on September 6, 2011 was untimely under Supreme Court Rule 6(a)(i). Vanderbilt argued in the alternative that if the June 28 Order was not the final order, the appeal is interlocutory and any appeal must await entry of a final order. The Plummers contended that their appeal was timely and not interlocutory because a Special Master's August 9, 2011 order dismissing nine defendants and not the June 28 Order, constituted the final order. The Plummers contended that under accepted Superior Court practice, the June 28 Order was not understood to be final. After its review of the case, the Supreme Court concluded that the June 28 Order was the only final order in this case and that no court error contributed to the Plummers' delayed filing of this appeal. Accordingly, the Court dismissed the Plummers' appeal as untimely under Supreme Court Rule 29(b). View "Plummer v. R.T. Vanderbilt Company, Inc." on Justia Law

Defendant-Appellant Maurice Williams appealed his Superior Court conviction and sentence for Violation of Probation. Defendant contended on appeal that the Superior Court abused its discretion when it found him in Violation of Probation following his escape from Level IV custody, because he would not have been in custody but for an illegal sentence. Upon review, the Supreme Court found no merit to Defendant's appeal and affirmed his conviction and sentence. View "Williams v. Delaware" on Justia Law

This case centered on whether a Justice of the Peace properly granted a search warrant based on the information in the affidavit of probable cause placed before her. "When reviewing a motion to suppress the evidence police discovered while executing a search warrant, Superior Court judges should give substantial deference to the magistrate's finding on the existence of probable cause. Resolution of this case require[d] elaboration about the meaning of 'substantial deference.' Upon review, the Supreme Court held that "substantial deference" means that if some facts in the affidavit of probable cause support the inference that evidence of criminal activity exists in a particular place, the Superior Court judge should affirm the issuance of a search warrant. Consequently, the Court reversed the Superior Court's judgment granting the motion to suppress, and remanded the case for further proceedings. View "Delaware v. Holden " on Justia Law

Pro se prisoner Defendant-Appellant Damar Smith appealed his conviction and sentence for Rape in the Third Degree, Unlawful Imprisonment in the Second Degree, and Possession of a Deadly Weapon by a Person Prohibited. His notice of appeal was received by the Supreme Court on February 28, 2012, one day after the thirty-day deadline to appeal from his January 27, 2012 sentence. The Court directed Defendant to show cause as to why his appeal should not have been dismissed under Rule 29(b). The Court then directed the State to file a supplemental memorandum addressing whether the Court should re-examine its holding in "Carr v. Delaware" and adopt the Federal "mailbox rule" set forth in "Houston v. Lack." The State took the position that the Court should again decline to adopt the federal prison mailbox rule. Amicus curiae argued that the Court should adopt the rule, in light of changed prison mail procedures and for the policy reasons set forth in "Houston" and subsequent cases. Last year, in "Hickman v. Delaware," the Delaware Supreme Court considered the same issue and declined to adopt the federal prison mailbox rule; it reached the same conclusion in this case. Accordingly, the Court dismissed Defendant's appeal as untimely. View "Smith v. Delaware" on Justia Law

Plaintiff Martin Marietta Materials, Inc. appealed a Chancery Court judgment granting Defendant Vulcan Materials Company relief on its counterclaims, and an accompanying injunction. The Chancery Court enjoined Martin for a four month period from continuing to prosecute its pending Exchange Offer and Proxy Contest to acquire control of Vulcan. That injunctive relief was granted to remedy Martin's adjudicated violations of two contracts between Martin and Vulcan: a Non-Disclosure Letter Agreement (the "NDA") and a Common Interest, Joint Defense and Confidentiality Agreement (the "JDA"). Finding that the Chancery Court did not abuse its discretion in holding that the equities favored Vulcan, the Supreme Court affirmed that court's decision. View "Martin Marietta Materials, Inc. v. Vulcan Materials Co." on Justia Law

Plaintiff Martin Marietta Materials, Inc. appealed a Chancery Court judgment granting Defendant Vulcan Materials Company relief on its counterclaims, and an accompanying injunction. The Chancery Court enjoined Martin for a four month period from continuing to prosecute its pending Exchange Offer and Proxy Contest to acquire control of Vulcan. That injunctive relief was granted to remedy Martin's adjudicated violations of two contracts between Martin and Vulcan: a Non-Disclosure Letter Agreement (the "NDA") and a Common Interest, Joint Defense and Confidentiality Agreement (the "JDA"). Finding that the Chancery Court did not abuse its discretion in holding that the equities favored Vulcan, the Supreme Court affirmed that court's decision. View "Martin Marietta Materials, Inc. v. Vulcan Materials Co." on Justia Law

Three officers completed a traffic stop, making "ancillary, permissible inquiries." A probation officer continued to question one of the car's passengers, a probationer, even though the officer testified he had no reasonable suspicion of criminal activity. Officers testified that the car was leaving a "drug area." And drugs were found in the car following the stop. The passenger-probationer was on probation for drug charges. He was ultimately arrested following that stop, and he challenged his arrest on the grounds that officers lacked probable cause to make the arrest. Upon review, the Supreme Court reversed: "[a]n officer who pulls a car over for speeding does not thereby gain free rein to ask as many questions, for as long a time, as he might wish. Further investigation requires further justification. . . . [the Defendant's] continued detention constituted an impermissible seizure, and the questioning itself violated even the limited rights possessed by a probationer." View "Murray v. Delaware" on Justia Law