Justia Delaware Supreme Court Opinion Summaries

Defendant Dallas Drummond, Jr., directly appealed to the Supreme Court after having been convicted by a Superior Court jury on two counts of First Degree Rape and one count of Unlawful Conduct Against a Child by a Sex Offender. Defendant claimed that the trial court reversibly erred by denying his (and the State's) joint motion to sever the Rape charges from the Unlawful Conduct charge. While his appeal was pending, the Supreme Court decided "Monceaux v. State" which relevantly held that a trial court "must use a bifurcated procedure in all future [Unlawful Conduct Against a Child by a Sex Offender] cases." Because "Monceaux" controlled this case, the Court reversed the convictions and remanded the case for further proceedings. View "Drummond v. Delaware" on Justia Law

Appellant Reuben Cordero appealed a Superior Court order that affirmed an order of the Industrial Accident Board dismissing his petitions against a general contractor, Gulfstream Development Corporation, and a Gulfstream subcontractor, Delaware Siding Company. On appeal, Cordero argued that the Superior Court reversibly erred in interpreting 19 Del. C. sec. 2311(a)(5). Upon review, the Supreme Court disagreed and affirmed the Board's decision. View "Cordero v. Gulfstream Development Corporation" on Justia Law

The issue on appeal in this case came from a decision that dismissed a complaint against a foreign business entity for lack of personal jurisdiction. The foreign company allegedly conspired with other defendants to divest appellant of his interest in a lucrative joint venture. That plan was accomplished, in part, by causing the dissolution of a Delaware limited liability company co-founded by appellant. Under the "conspiracy theory" of personal jurisdiction, a plaintiff must allege facts from which one can infer that a foreign defendant knew or should have known that the conspiracy would have a Delaware nexus. The trial court found that the foreign company did not know about the Delaware connection until after the limited liability company had been dissolved. As a result, the trial court dismissed for lack of personal jurisdiction. Upon review, the Supreme Court reversed finding that the trial court's analysis was flawed in two respects: (1) the applicable standard is whether the foreign entity knew or should have known that it was conducting activity in Delaware (here, even if the record facts did not establish that appellee knew about the dissolution before it occurred, they established that appellee should have known that it was dealing with a Delaware company); (2) the conspiracy did not begin or end with the dissolution of the Delaware company (appellee learned that its business partner had been a Delaware entity shortly after the dissolution, and the alleged conspiracy continued long after that date). View "Matthew v. Flakt Woods Group SA" on Justia Law

Defendant-Appellant Solomon Collins appealed his convictions by a jury of Murder First Degree, two counts of Possession of a Firearm During the Commission of a Felony, and three counts of Reckless Endangering First Degree. Collins was charged with the shooting death of Tommear Tinnin. At trial, the State offered into evidence two out-of-court statements that identified Collins as the shooter of Tinnin. The declarants, Violet Gibson and Shakira Romeo, denied making the statements during their in-court testimony. The statements were admitted into evidence based upon the testimony of Detective Patrick Conner, the officer who interviewed Gibson and Romeo. After eleven hours of deliberation, the jury reported to the trial judge that they were deadlocked. The trial judge gave an "Allen" charge and instructed the jury to deliberate further. Two hours later, the jury returned the guilty verdicts. Collins raised three claims on appeal: (1) there was an insufficient foundation to admit into evidence the out-of-court statement of Gibson; (2) there was an insufficient foundation to admit into evidence the out-of-court statement of Romeo; and (3) that the trial judge erred in administering an Allen charge, which, as administered, was coercive. "Gibson and Romeo were classic turncoat witnesses." The Supreme Court concluded that the testimony at trial presented a sufficient foundation for the admission of their out of-court statements: the record showed that their out-of-court statements were given voluntarily, they were each subject to cross examination at trial, and their in-court testimony touched on both the events perceived and the content of their prior statements. The Court also concluded that there was no abuse of discretion by the trial judge in giving an Allen charge. Accordingly, the Court affirmed. View "Collins v. Delaware" on Justia Law

In resolving this dispute between the controlling member–manager and the minority investors of a Delaware Limited Liability Company (LLC), the Supreme Court interpreted the LLC's governing instrument as a contract that adopted the equitable standard of entire fairness in a conflict of interest transaction between the LLC and its manager. The Court held that the manager violated that contracted-for fiduciary duty by refusing to negotiate with a third-party bidder and then by causing the company to be sold to himself at an unfair price in a flawed auction that the manager himself engineered. The Court affirmed the trial court's damages award solely on contractual grounds, and affirmed the court’s award of attorneys' fees. View "Gatz Properties, LLC v. Auriga Capital Corp., et al." on Justia Law

Defendant-Appellant Cookie A. Hunter appealed his judgments of conviction, after a Superior Court jury trial, of Assault in the Second Degree, Resisting Arrest with Force or Violence, and Driving Under the Influence, First Offense. Defendant raised two issues in his direct appeal to the Supreme Court: (1) it was error for the trial judge to admit the results of his blood alcohol content (BAC) blood test into evidence because the foundational requirements necessary to admit that scientific evidence were not met; (2) the trial judge erred by not granting his motions for judgments of acquittal on the Assault and Resisting Arrest charges, because the State failed to preserve the videotape that recorded the events that led to those charges. Upon review, the Supreme Court concluded that the results of the BAC test were erroneously admitted into evidence. Therefore, the DUI judgment of conviction was reversed. Furthermore, the Court determined that Defendant's motions for judgments of acquittal on the Assault and Resisting Arrest charges were properly denied. Consequently, the judgments of the Superior Court were affirmed in part and reversed in part. The case was remanded for further proceedings. View "Hunter v. Delaware" on Justia Law

Defendant-Appellant Pablo Melendez appealed his convictions after a Superior Court jury trial stemming from numerous actual and attempted robberies. Defendant was convicted of: eighteen counts of Robbery in the First Degree, thirty-three counts of Possession of a Firearm During the Commission of a Felony, eleven counts of Wearing a Disguise, six counts of Conspiracy in the Second Degree, six counts of Aggravated Menacing, eight counts of Attempted Robbery in the First Degree, and one count of Reckless Endangering in the First Degree. In this appeal, Defendant claimed that the trial judge erred by admitting "improper witness bolstering and needlessly cumulative evidence when, despite their lack of personal knowledge, [two] police [officers] were allowed to provide their own interpretations and opinions of what happened during the [crimes]." Upon review, the Supreme Court concluded that Defendant waived his claim by failing to raise it at trial. Therefore, the judgments of the Superior Court were affirmed. View "Damiani-Melendez v. Delaware" on Justia Law

Plaintiff-Appellant Keila Rodriguez Alvarez appealed a Superior Court order granting defendant's Motion for Summary Judgment. The case arose from an automobile accident that occurred in 2010. On appeal, Plaintiff argued that the trial court by granting the motion erred as a matter of law because the parties had made a mutual mistake of fact about the existence and scope of her injuries resulting from an automobile accident. The record reflected that the unambiguous language of the release executed by Plaintiff was controlling and that there was no mutual mistake. Therefore, the judgment of the Superior Court was affirmed. View "Alvarez v. Castellon" on Justia Law