Justia Delaware Supreme Court Opinion Summaries

Lisa Davis and her son, Brandon Zoladkiewicz, were involved in a car accident with an uninsured drunk driver, resulting in Davis's death and Brandon's serious injuries. Davis and her husband, Mark Ginsberg, had separate but nearly identical insurance policies from the same carrier, each with uninsured motorist coverage of $100,000 per person and $300,000 per accident. Ginsberg, individually and as executor of Davis's estate, and Ron Zoladkiewicz, as guardian ad litem for Brandon, sought coverage from both policies. The insurance carrier agreed to pay the coverage limit for one policy but refused to combine or stack the two policies.The Superior Court of Delaware dismissed the plaintiffs' complaint, agreeing with the insurance carrier that the Delaware Insurance Code limited coverage to one policy when the policies were issued by the same insurer to insureds in the same household. The court found that the statute allowed anti-stacking provisions and that the policies' provisions were not ambiguous enough to permit stacking.The Supreme Court of Delaware reversed the Superior Court's decision. The court held that the Delaware Insurance Code does not prohibit stacking of underinsured/uninsured motorist coverage policies issued by the same carrier to insureds in the same household. Instead, the Code requires that the court limit coverage to the highest limit of liability set by either insurance policy. The court found that the policies were ambiguous because they contained conflicting provisions regarding stacking. Interpreting the ambiguity in favor of the insureds, the court allowed stacking of the policies. Additionally, the court determined that the releases signed by Ginsberg and Brandon Zoladkiewicz did not preclude recovery under the Ginsberg Policy. The case was remanded to the Superior Court to determine the amount recoverable under the Ginsberg Policy. View "Ginsberg v. Harleysville Worcester Insurance Company" on Justia Law

GMG Insurance Agency filed a legal malpractice claim against Margolis Edelstein, alleging professional negligence in Margolis's representation of GMG in a non-compete action brought by Lyons Insurance Agency in the Court of Chancery. GMG claimed that Margolis's inadequate handling of discovery and failure to develop a proper factual record led to GMG's unfavorable position in the litigation. GMG eventually settled the case for $1.2 million after a key employee, Howard Wilson, recanted his prior testimony in an affidavit that was detrimental to GMG's defense.The Superior Court of Delaware granted summary judgment in favor of Margolis Edelstein, finding that Margolis's representation did not fall below the applicable standard of care. The court also concluded that Wilson's affidavit was a superseding cause that broke the causal chain linking Margolis's alleged negligence to GMG's claimed damages. GMG appealed this decision.The Delaware Supreme Court reviewed the case and found that the Superior Court erred in its judgment. The Supreme Court held that there were material disputed facts regarding whether Margolis deviated from the requisite standard of care. The court also found that the Superior Court failed to address GMG's contention that, but for Margolis's alleged negligence, GMG would have prevailed on all claims in the Court of Chancery litigation. Additionally, the Supreme Court concluded that the Superior Court erred in determining that Wilson's affidavit was a superseding cause as a matter of law.The Delaware Supreme Court reversed the Superior Court's judgment and remanded the case for further proceedings, emphasizing that the issues of negligence and causation should be resolved by a jury. View "GMG Insurance Agency v. Edelstein" on Justia Law

The case involves Rakiim Strickland, who was captured on surveillance video in possession of an assault weapon and discharging it in the direction of another person. Strickland, a convicted felon prohibited from possessing a firearm, was charged with possession of a firearm and ammunition by a person prohibited. At trial, the State presented video evidence showing Strickland with the weapon, which the jury viewed without objection from Strickland. Strickland was convicted and sentenced to 35 years in prison.Strickland appealed, arguing that the trial judge should have instructed the jury, sua sponte, to consider the video evidence only for identifying the person in possession of the firearm, not for any other improper purposes. He also contended that the trial court abused its discretion by allowing the prosecution to introduce evidence of two firearm-related convictions of a defense witness, which he claimed did not involve crimes of dishonesty.The Supreme Court of the State of Delaware reviewed the case. The court held that the video evidence was admissible as it directly proved the charged possessory offense and did not fall under the rule governing other, uncharged bad acts. The court found no plain error in the trial court’s failure to give a limiting instruction sua sponte. Regarding the defense witness's prior convictions, the court determined that any error in admitting the convictions was harmless, as the witness's credibility was already compromised by his relationship with Strickland and his other admissible conviction.The Supreme Court of the State of Delaware affirmed Strickland’s convictions. View "Strickland v. State" on Justia Law

The case involves a dispute over the control of Byju’s Alpha, Inc., a Delaware subsidiary of Think and Learn Private Ltd. (T&L), an Indian company. Byju’s Alpha entered into a $1.2 billion loan agreement with GLAS Trust Company LLC (GLAS) as the administrative and collateral agent. The agreement required Whitehat, another T&L subsidiary, to become a guarantor, contingent on approval from the Reserve Bank of India (RBI). However, changes in RBI regulations made it impossible for Whitehat to obtain the necessary approval.The Court of Chancery of Delaware held a trial and ruled that Timothy R. Pohl was the sole director and officer of Byju’s Alpha, following actions taken by GLAS to enforce its rights under the loan agreement. The court found that the failure of Whitehat to accede as a guarantor constituted a breach of the loan agreement, allowing GLAS to take control of Byju’s Alpha’s shares and appoint Pohl as the sole director and officer.The Delaware Supreme Court reviewed the case and affirmed the Court of Chancery’s decision. The Supreme Court held that the amendments to the loan agreement explicitly defined Whitehat’s failure to accede as a “Specified Default,” entitling GLAS to enforce its remedies. The court also rejected the impossibility defense, concluding that the changes in RBI regulations were foreseeable and could have been guarded against in the contract. The court found that the sophisticated parties involved should have anticipated the regulatory changes and included provisions to address such risks.In conclusion, the Delaware Supreme Court affirmed the lower court’s ruling that Pohl was the sole director and officer of Byju’s Alpha, and that GLAS was entitled to enforce its remedies under the loan agreement due to the breach caused by Whitehat’s failure to accede as a guarantor. View "Ravindran v. GLAS Trust Company LLC" on Justia Law

In this case, SARN SD3 LLC ("SD3") brought a breach of contract action against Czechoslovak Group A.S. ("CSG") regarding an option contract for shares in RETIA A.S. ("RETIA"). The contract stipulated that if CSG ceased to own a majority of RETIA before SD3's call option expired, CSG would pay SD3 a "Penalty Amount" based on an "Independent Valuation" of RETIA. CSG sold RETIA, triggering the Penalty Amount, but disputes arose over access to valuation information, leading SD3 to file suit.The Superior Court of Delaware granted SD3's entitlement to the Penalty Amount and calculated the Independent Valuation as the average of two valuations from Big Four accounting firms, despite CSG's objections. The court later determined that SD3's valuation was independently determined and in good faith. SD3 then filed a Rule 37 Motion for sanctions, alleging CSG withheld important valuation documents, but the court denied the motion, suggesting SD3 seek relief under Rule 60(b) for newly discovered evidence. SD3's subsequent Rule 60 Motion was also denied, as the court found the documents were not newly discovered and no exceptional circumstances warranted relief.The Delaware Supreme Court reviewed the case and affirmed the Superior Court's decisions. The Supreme Court held that the contract's provisions were clear and unambiguous, not requiring judicial inquiry into the valuation methodologies. The court also found no abuse of discretion in the Superior Court's handling of the Rule 37 and Rule 60 motions, as SD3 had the documents in question well before the summary judgment ruling and failed to demonstrate due diligence. Additionally, the Supreme Court upheld the Superior Court's decision to convert the judgment to U.S. dollars using the exchange rate as of the valuation date, rejecting SD3's arguments for a different conversion date. View "Czechoslovak Group A.S. v. SARN SD3 LLC" on Justia Law

The case involves a dispute over attorneys' fees following a $1 billion settlement in litigation challenging Dell Technologies' redemption of Class V stock. The plaintiff, Steamfitters Local 449 Pension Plan, alleged that Dell Technologies, controlled by Michael Dell and Silver Lake Group LLC, redeemed the Class V stock at an unfair price. The litigation was complex, involving extensive discovery and expert testimony, and was settled on the eve of trial.The Court of Chancery of the State of Delaware awarded 26.67% of the settlement, or $266.7 million, as attorneys' fees. Pentwater Capital Management LP and other class members objected, arguing that the fee was excessive and that a declining percentage method should be applied, similar to federal securities law cases. The Court of Chancery rejected this argument, holding that Delaware law, as established in Sugarland Industries, Inc. v. Thomas and Americas Mining Corp. v. Theriault, does not mandate a declining percentage approach. The court found that the $1 billion settlement was a significant achievement and that the fee award was justified based on the results achieved, the time and effort of counsel, and other relevant factors.The Supreme Court of the State of Delaware reviewed the case and affirmed the Court of Chancery's decision. The Supreme Court held that the Court of Chancery did not exceed its discretion in awarding 26.67% of the settlement as attorneys' fees. The court emphasized that the Sugarland factors, particularly the results achieved, are paramount in determining fee awards. The Supreme Court also noted that while a declining percentage approach is permissible, it is not mandatory, and the Court of Chancery adequately justified its decision not to apply it in this case. View "In re Dell Technologies Inc." on Justia Law

In the fall of 2020, the Wilmington Police Department investigated the NorthPak street gang, which was involved in a series of violent crimes in Wilmington, Delaware. Gregory Wing, identified as a leader and shooter for NorthPak, was implicated in multiple shootings, including the murders of Ol-lier Henry and Taquan Davis. The investigation revealed that NorthPak was engaged in a violent feud with the M-Block Grimy Savages (MGS) gang. Wing was tied to the crimes through ballistics evidence, cell tower data, social media posts, and witness testimony. He was arrested in September 2020 with a firearm linked to the shootings.The Superior Court of Delaware tried Wing and his co-defendant Elijah Coffield together. The trial lasted 14 days, with over 50 witnesses and 600 exhibits. The jury found Wing guilty of gang participation, two counts of first-degree murder, and four counts of attempted first-degree murder, among other charges. He was sentenced to two life terms plus additional years in prison. Wing appealed, challenging two evidentiary rulings: the admission of a witness's out-of-court statement and the limitation on cross-examination of another witness.The Supreme Court of Delaware reviewed the case. Wing argued that the Superior Court erred in admitting Kenneth Griffin's out-of-court statement under 11 Del. C. § 3507, claiming it was not voluntary and not truthful. The court found that Griffin's statement was voluntary, as he initiated contact with the police and was read his Miranda rights. The court also determined that Griffin's indication of the truthfulness of his statement met the requirements of § 3507. Wing also contended that the court improperly restricted cross-examination of Tyrie Burton, a witness who testified against Coffield. The court held that the trial judge did not abuse his discretion in limiting the cross-examination to avoid Fifth Amendment issues.The Supreme Court of Delaware affirmed Wing's convictions and sentences. View "Wing v. State" on Justia Law

Shannon Watson was convicted of Assault Second Degree after striking Damon Howard in the face multiple times, resulting in severe and permanent head injuries. The incident occurred outside the bathroom of Catherine Rooney’s Irish Pub. Watson claimed he acted in self-defense due to prior tensions with Howard, who was his friend’s ex-boyfriend. Both men testified, providing conflicting accounts of the altercation. Watson argued that Howard had a history of violence and that he felt threatened during the encounter.The Superior Court of Delaware presided over the initial trial. Watson did not object to the trial court’s use of the term “victim” when referring to Howard, nor did he request a specific jury instruction regarding character evidence. The jury found Watson guilty, and he was sentenced to eight years in custody, suspended for one year at supervision Level II.The Supreme Court of Delaware reviewed the case on appeal. Watson argued that the trial court’s reference to Howard as the “victim” and the failure to issue a “character of the defendant” jury instruction constituted plain error. The Supreme Court held that the single reference to Howard as the “victim” did not amount to plain error, as it did not suggest the trial court’s acceptance of the State’s version of the facts. Additionally, the court found that the omission of a specific character evidence instruction did not deprive the jury of its ability to perform its duty, as the jury was adequately instructed to consider all evidence and determine the appropriate weight to give it. Consequently, the Supreme Court of Delaware affirmed Watson’s conviction. View "Watson v. State" on Justia Law

In response to the COVID-19 pandemic, the Governor of Delaware issued a series of emergency orders that included restrictions on religious services. These restrictions, which were lifted by June 2020, limited in-person worship to ten people and imposed various other mandates. Over 18 months later, two religious leaders filed suit in the Court of Chancery seeking injunctive relief against these restrictions, which were no longer in effect. The Court of Chancery dismissed the case for lack of subject matter jurisdiction, concluding that the plaintiffs could not demonstrate a reasonable apprehension of future harm.The plaintiffs then transferred their action to the Superior Court, seeking declaratory judgment and damages for alleged violations of their constitutional rights. The Superior Court dismissed the claims, ruling that the requests for declaratory relief were not justiciable because the restrictions had been lifted and there was no ongoing controversy. Additionally, the court found that the Governor was immune from the damages claims under the State Tort Claims Act and the doctrine of qualified immunity.On appeal, the Delaware Supreme Court affirmed the lower courts' decisions. The Court agreed that the plaintiffs failed to show a reasonable apprehension of future harm, which is necessary for injunctive relief. The Court also held that the plaintiffs' claims for declaratory judgment were not justiciable because there was no ongoing controversy and the alleged harm could not be redressed by a declaratory judgment. Finally, the Court upheld the Superior Court's finding that the Governor was immune from damages claims, as his actions were discretionary and taken in good faith during an unprecedented public health crisis. View "In re Covid-Related Restrictions on Religious Services" on Justia Law

The case involves a dispute between two parties who entered into a partnership agreement that specified the financial conditions under which the appellant would receive a distribution upon the sale of the partnership’s principal asset. The agreement set a net-sale-price threshold above which the appellant would receive a distribution, and it directed the general partner to calculate that net sale price by deducting certain categories of costs from the gross sales price. The general partner determined that the deductions reduced the net sale price below the minimum threshold for a distribution. The appellant challenged several of these deductions, particularly the costs incurred to defease the interest payments on the mortgage.The Court of Chancery of the State of Delaware reviewed the case and held that the deduction for the costs to defease the interest payments on the mortgage was proper under the partnership agreement. The court concluded that this deduction was outcome determinative and entered judgment in favor of the partnership. The court also noted that the general partner acted in good faith in calculating the net sale price, which eliminated any breach of contract claim.The Supreme Court of the State of Delaware reviewed the case and affirmed the Court of Chancery’s judgment. The Supreme Court held that the plain language of the partnership agreement and the formula used permitted the challenged deduction for defeasance costs. The court did not reach the effect or correctness of the Court of Chancery’s alternative holding regarding the general partner’s good faith. The Supreme Court concluded that the defeasance costs were properly deducted, which reduced the net resale price below the threshold required for the appellant to receive a distribution. View "Exit Strategy, LLC v. Festival Retail Fund BH, L.P." on Justia Law