Justia Delaware Supreme Court Opinion Summaries

Blue Beach Bungalows DE, LLC sought to purchase Pine Haven, a manufactured home and RV community in Delaware, from its longtime owner. After entering a purchase agreement in March 2022, Blue Beach sent numerous letters to residents, informing them of changing tenancy statuses, threatening eviction, police action, and property destruction, and imposing shifting deadlines to vacate. These aggressive tactics prompted complaints to the Delaware Department of Justice (DOJ), which initiated an administrative enforcement action against Blue Beach for violations including the Consumer Fraud Act (CFA), alleging false or misleading statements regarding the nature of residents’ living arrangements and improper rent solicitations.After a four-day hearing, the administrative Hearing Officer largely ruled in favor of the DOJ, penalizing Blue Beach over $700,000 for statutory violations. Blue Beach appealed to the Superior Court of the State of Delaware, which affirmed some violations and vacated others. The Superior Court held the CFA applied to communications made after the underlying transaction and found the CFA constitutional, rejecting Blue Beach’s arguments about the right to a jury trial. The DOJ cross-appealed the vacation of certain penalties.The Supreme Court of Delaware reviewed the case. It held that the plain language of the CFA does not apply to post-transaction communications, reversing the Superior Court on that issue. The Court affirmed the Superior Court’s finding that the CFA is constitutional and does not violate Delaware’s jury trial right, because the statutory cause of action is not sufficiently analogous to common law fraud. The Court declined to address the DOJ’s cross-appeal, finding those issues moot in light of its holding on the CFA’s scope. The case was affirmed in part, reversed in part, and remanded for further proceedings consistent with the Supreme Court’s opinion. View "Blue Beach Bungalows DE, LLC v. Department of Justice Consumer Protection Unit" on Justia Law

In 2018, the board of a major clean-energy vehicle company approved a substantial equity compensation plan for its CEO, contingent on achieving a series of ambitious market capitalization and operational milestones. The plan granted the CEO the right to purchase significant company stock if these milestones were met. A company shareholder filed a derivative suit, alleging that the CEO, as a controlling stockholder, had improperly influenced the board to secure excessive compensation. The shareholder also claimed failures in disclosure to stockholders who later approved the plan.The Court of Chancery of the State of Delaware held a five-day trial. It found that the CEO exercised transaction-specific control despite not holding a majority of voting power. Concluding that the CEO and the board had breached their fiduciary duties, the court applied the “entire fairness” standard and ordered rescission of the CEO’s compensation package. After this decision, the board resubmitted the compensation plan to the stockholders with new disclosures, and a majority of disinterested stockholders approved it in a second vote. The board then requested that the court revise its prior judgment, but the Court of Chancery refused, maintaining rescission and awarding the plaintiff’s counsel substantial fees.On appeal, the Supreme Court of the State of Delaware reviewed whether rescission was a proper remedy. The Supreme Court held that rescission was improper because it could not restore all parties to their positions before the transaction, given the CEO’s six years of performance under the plan. The Court reversed the rescission remedy, reinstated the compensation plan, and awarded the plaintiff nominal damages. The Supreme Court further ruled that the plaintiff’s attorneys were entitled to fees based on the reasonable value of their services. View "In re Tesla, Inc. Derivative Litigation" on Justia Law

Law enforcement received anonymous tips in 2021 and 2022 alleging that a Wilmington resident was selling drugs and possessing firearms at his home, which also operated as an unlicensed barbershop. The tips included specific details about the individual’s activities and identifying information. After receiving the July 2022 tip, police corroborated aspects of the information through surveillance, database checks, and two traffic stops involving individuals seen leaving the residence—one was found with marijuana allegedly purchased from the suspect and another fled from police after acting suspiciously. Based on this investigation, police obtained and executed a search warrant, recovering drugs, cash, and a firearm. The individual, a previously convicted felon, was indicted on drug and firearm charges, including possession of a firearm by a person prohibited.The Superior Court of the State of Delaware denied the defendant’s motion to suppress the evidence, finding that the affidavit supporting the search warrant established probable cause through the combination of the July 2022 tip and corroborating police investigation. At trial, a police officer referred to information from the National Crime Information Center (NCIC) identifying the recovered firearm as stolen. The defense did not object to this testimony. The defendant was convicted of multiple offenses, including firearm and drug charges, and sentenced to seventeen years of incarceration.On appeal to the Supreme Court of the State of Delaware, the defendant raised claims of hearsay and Confrontation Clause violations due to the NCIC testimony, challenged the denial of his suppression motion, and argued that the statute prohibiting felons from possessing firearms was unconstitutional. The Supreme Court applied plain error review to most issues because they were not raised below, and affirmed the convictions. The Court held that there was no plain error in admitting the NCIC evidence, that the search warrant was supported by probable cause, and that the firearm prohibition statute was not plainly unconstitutional, either on its face or as applied to the defendant. The judgment of the Superior Court was affirmed. View "Johns v. State" on Justia Law

Police in Wilmington, Delaware, were monitoring social media when a detective saw a video on Instagram that appeared to show Marvin Swanson, a person legally prohibited from possessing firearms, mimicking shooting motions and possibly displaying what looked like a gun magazine in his waistband. Shortly after, a confidential informant, known to be reliable, sent the detective the same video and claimed to have personally observed Swanson in the area with a firearm. The police responded to the location, saw Swanson in the described clothing, conducted a pat down that did not reveal a weapon, but found a loaded handgun in a recycling bin about 25–30 feet away. Swanson was handcuffed and transported to the police station, where he voluntarily provided a DNA sample. DNA testing later matched Swanson to the gun, leading to his arrest for possession of a firearm and ammunition by a person prohibited.The Superior Court of the State of Delaware denied Swanson’s motion to suppress the DNA evidence, finding that officers had reasonable suspicion for the initial stop and that the continued detention and transport to the station were reasonable, necessary, and related to the investigation. A jury later convicted Swanson.On appeal, the Supreme Court of the State of Delaware found that while the officers had reasonable suspicion for the initial stop based on the informant’s tip and corroborating observations, the subsequent transport of Swanson to the police station amounted to a de facto arrest. The Court held that this arrest was not supported by probable cause because the evidence linking Swanson to the gun was insufficient at the time of the arrest. As a result, the Court reversed the judgment of the Superior Court, holding that the motion to suppress should have been granted. View "Swanson v. State" on Justia Law

Loews Corporation created a publicly traded master limited partnership, Boardwalk Pipeline Partners, LP, to operate natural gas pipelines. The partnership agreement included a call-right provision allowing the general partner, controlled by Loews, to acquire all public limited partnership units if certain conditions were met. In 2018, following proposed policy changes by the Federal Energy Regulatory Commission (FERC) that could affect pipeline profitability, Loews sought legal opinions to justify exercising the call right. Although Boardwalk's internal analysis suggested minimal impact from the FERC changes, Loews’ outside counsel issued an opinion that the policy shift was reasonably likely to have a material adverse effect on Boardwalk’s rates, satisfying a key condition for the call right. After obtaining a second law firm’s endorsement of the opinion’s acceptability, Loews exercised the call right, acquiring public units at a price that unitholders alleged was artificially depressed.The Court of Chancery initially found that the legal opinion used to trigger the call right was not rendered in good faith, meaning a contractual condition for exercising the call right had not been fulfilled. As a result, the court held that Boardwalk’s general partner breached the partnership agreement and awarded damages to the unitholders. The court stayed the remaining claims, which included breach of the implied covenant of good faith and fair dealing, tortious interference, and unjust enrichment.On appeal, the Supreme Court of the State of Delaware first held that the general partner was exculpated from monetary liability for breach of contract under the partnership agreement, reversing the damages judgment and remanding for consideration of the non-exculpated claims. Upon remand, the Court of Chancery dismissed those remaining claims, concluding that the Supreme Court’s prior decision foreclosed them. On further appeal, the Supreme Court of Delaware held that the lower court misunderstood the scope of its prior ruling; it affirmed dismissal of most claims but reversed as to tortious interference, remanding that claim for further proceedings. View "Bandera Master Fund LP v. Boardwalk Pipeline Partners, LP" on Justia Law

The appellant was charged with several serious offenses after allegedly shooting a neighbor during a dispute at their apartment complex. The evidence included eyewitness testimony, gunshot residue on the appellant’s hands, and ammunition found in the appellant’s apartment matching shell casings at the scene. The appellant ultimately entered a no-contest plea to reduced charges, but later sought to withdraw the plea, claiming that his attorney’s actions led him to enter the agreement involuntarily and without full understanding of the case against him.After the appellant attempted to file a pro se motion to withdraw his plea, his defense counsel followed guidance from a prior decision (Reed v. State) by moving to withdraw as counsel and requesting substitute counsel. The Superior Court of the State of Delaware held a hearing, but did not first address the motion to withdraw as counsel. Instead, the court required the appellant to advocate for his own plea withdrawal and ultimately granted the motion to withdraw the plea, finding it had not been entered voluntarily. However, the court denied counsel’s motion to withdraw and required the same attorney to represent the appellant at trial, where he was convicted by a jury and sentenced to prison.On appeal, the Supreme Court of the State of Delaware held that when defense counsel moves to withdraw after a defendant expresses a desire to withdraw a plea, the trial court must first address and resolve the motion to withdraw as counsel, applying the established “good cause” standard. The failure to do so in this case resulted in the defendant being denied his constitutional right to counsel at a critical stage. The Supreme Court reversed the appellant’s convictions and remanded for further proceedings consistent with its opinion. View "Bolden v. State" on Justia Law

After a series of shootings in Wilmington, Delaware, Kyair Keys was charged with attempted murder, assault in the first degree, and multiple firearm offenses stemming from incidents between January 14 and January 22, 2022. Surveillance footage and ballistics evidence linked Keys to the shootings, and he was apprehended driving a stolen vehicle. During the investigation, police obtained an Instagram video showing Keys in the stolen car listening to a rap song with lyrics allegedly alluding to violent conduct and referencing his street nickname.The Superior Court of the State of Delaware presided over Keys’s trial. Prior to trial, the State sought to admit the Instagram video, including its audio, as evidence. Keys objected, arguing the song’s lyrics were irrelevant and unduly prejudicial. The Superior Court viewed the issue through Delaware Rule of Evidence 404(b), which concerns evidence of other crimes, wrongs, or acts, and ultimately overruled Keys’s objection, allowing the jury to hear both the video and police interpretation of the lyrics. The jury found Keys guilty on most counts, and he was sentenced to 47 years of incarceration, followed by probation.On appeal to the Supreme Court of the State of Delaware, Keys argued that admitting the audio portion of the video was an abuse of discretion and prejudiced the jury unfairly. The Supreme Court found that while the Superior Court’s decision to admit the audio evidence was questionable and likely should have been excluded due to lack of relevance and prejudicial effect, any error was harmless given the substantial other evidence of guilt. Therefore, the Supreme Court of Delaware affirmed the convictions. View "Keys v. State" on Justia Law

Three individuals were arrested after a fatal shooting in a Delaware apartment complex. Surveillance and witness testimony established that a caravan of vehicles traveled together to the scene, where two men exited, one remaining in front of a building while the other proceeded to the rear. The man at the front, later identified as the defendant, fired shots into the air, while the other shot and killed the victim, who was not the intended target. The defendant was also seen moving toward the back of the building and holding a firearm near the victim. After the shooting, all involved fled together.A grand jury indicted the defendant and two others for first-degree murder and related offenses. One co-defendant pleaded guilty to lesser charges. Following a bench trial in the Superior Court of the State of Delaware, the defendant was found guilty on all counts, while another co-defendant was acquitted. The defendant moved for judgment of acquittal, arguing the evidence failed to establish intent to kill the victim, failed to prove accomplice liability, and that he had withdrawn from any complicity before the murder. The Superior Court denied the motion, finding that liability attached based on the intent to promote the criminal conduct, regardless of the victim’s identity, and that the defendant did not effectively withdraw from the joint criminal enterprise.On appeal, the Supreme Court of the State of Delaware reviewed de novo the denial of the motion for judgment of acquittal and affirmed the Superior Court’s decision. The Supreme Court held that, under Delaware law, a person may be found guilty of first-degree murder as an accomplice if he intentionally aided the commission of the offense, regardless of whether he was the actual shooter, and that withdrawal from complicity requires affirmative acts to sever involvement, which the defendant had not demonstrated. The conviction and judgment were affirmed. View "Henry v. State" on Justia Law

In 2015, a firefighter suffered a compensable back injury while working part-time for a fire company. He settled his workers’ compensation claim related to that incident in 2018 by accepting a lump sum and releasing the insurer from future liability. Years later, in 2023, while working for a different fire department, he experienced another back injury while carrying heavy equipment up stairs during a call. Medical evaluations indicated the new injury involved the same area of his spine as the 2015 incident. The firefighter sought workers’ compensation from his current employer, but the claim was denied.The Industrial Accident Board (IAB) held an evidentiary hearing, receiving testimony from the claimant, his treating physician, and an orthopedic surgeon retained by the employer. The Board concluded that the 2023 incident was a recurrence of the 2015 injury—not an aggravation or a new injury—based primarily on the orthopedic surgeon’s opinion and a comparison of medical imaging. Under Delaware law, liability for a recurrence rests with the insurer on the risk for the original injury, while an aggravation caused by a new workplace incident would be covered by the current employer’s insurer. Because the firefighter had already settled and released all claims relating to the 2015 injury, no compensation was available for the 2023 event. The Superior Court of the State of Delaware affirmed the Board’s decision, finding that the correct legal standard had been applied and that the decision was supported by substantial evidence.On appeal, the Supreme Court of the State of Delaware affirmed the Superior Court’s judgment. The Supreme Court held that the IAB and the Superior Court properly applied the standard from Standard Distributing Co. v. Nally for distinguishing between recurrence and aggravation in successive injury cases, and that substantial evidence supported the Board’s finding that the 2023 incident was a recurrence rather than an aggravation or a new injury. View "Corey Ferrell v. City of Wilmington IAB" on Justia Law

The appellant was charged with multiple serious sexual offenses involving a minor, including first-degree rape, child sexual abuse by a person in a position of trust, and unlawful sexual contact. Prior to trial, his defense counsel raised concerns about his mental health and ability to participate meaningfully in his defense, noting that while the appellant understood the legal process and charges, he appeared unable or unwilling to engage in his own defense. The trial court ordered a psychiatric evaluation, which found the appellant incompetent to stand trial due to his refusal to participate. The parties subsequently agreed that he should undergo a competency restoration program.After completing the restoration program, a second psychiatric evaluation was conducted. This evaluation concluded that the appellant’s condition had improved, finding him able to communicate with counsel and participate in his defense. The Superior Court of the State of Delaware reviewed both evaluations and, after a teleconference with counsel, found the appellant competent to stand trial. The court scheduled trial, during which the appellant’s counsel did not again raise the competency issue. The appellant was convicted by a Superior Court jury of ten offenses and sentenced to 216 years of imprisonment.On appeal to the Supreme Court of the State of Delaware, the appellant argued that the trial court failed to make adequate factual findings in its competency ruling and that the record as a whole did not support the finding of competency. The Supreme Court reviewed the legal standard de novo and factual findings for support in the record, holding that the trial court relied on competent psychiatric evaluations and statements from counsel, satisfying its duty to make and briefly state factual findings. The Supreme Court found the record supported the determination of competency and affirmed the judgment of the Superior Court. View "Castro v. State" on Justia Law