Justia Delaware Supreme Court Opinion Summaries

The defendant, while under the influence of illegal drugs, killed a police officer and assaulted several others. He claimed that his behavior was due to someone substituting bath salts for his methamphetamine, and sought to use a statutory involuntary intoxication defense. The Superior Court granted a motion in limine, preventing the presentation of this defense and deemed the defendant’s evidence inadmissible.The Superior Court of Delaware reviewed the case. The court examined whether a person who knowingly introduces an unlawful intoxicating substance into their body can present an involuntary intoxication defense if the substance or its effects differ from what was anticipated. The court concluded that under Title 11, Section 423 of the Delaware Code, a person who knowingly introduces an unlawful intoxicating substance into their body is precluded from presenting an involuntary intoxication defense unless certain statutory exceptions apply.The Delaware Supreme Court affirmed the Superior Court’s decision. The court held that the statutory language was unambiguous and that a person who knowingly introduces an unlawful intoxicating substance into their body cannot claim involuntary intoxication unless specific statutory exceptions are met. The court did not address the admissibility of the defendant’s evidence under Rule 702 and 11 Del. C. § 303, as the defense was unavailable as a matter of law. The court also found that precluding the defense did not violate the defendant’s constitutional right to present a complete defense. View "Wilkerson v. State" on Justia Law

In 2005, James E. Cooke, Jr. was convicted of the rape and murder of Lindsey Bonistall, a University of Delaware student. Cooke's first conviction was overturned in 2009 due to his defense counsel's strategy, which conflicted with Cooke's plea of not guilty. Cooke was retried in 2012, where he represented himself initially but was later replaced by standby counsel due to his disruptive behavior. He was again convicted and sentenced to death, which was affirmed by the Delaware Supreme Court in 2014.Cooke filed a motion for postconviction relief in 2015, claiming ineffective assistance of counsel and other errors. The Superior Court denied his motion, leading to this appeal. Cooke argued that his second-trial counsel failed to explore his competency to stand trial, did not adequately investigate the case, and failed to object to the State's peremptory challenges during jury selection. He also claimed cumulative errors and procedural issues with the court's denial of his continuance requests and discovery limitations.The Delaware Supreme Court reviewed the claims and found that Cooke's counsel acted reasonably given Cooke's insistence on testifying and his refusal to cooperate with mental health evaluations. The court also found that Cooke was competent to stand trial, and his counsel's decisions were within the bounds of reasonable professional assistance. The court held that Cooke's claims of cumulative error and procedural issues were without merit and affirmed the Superior Court's denial of postconviction relief. View "Cooke v. State" on Justia Law

Police were surveilling a known drug dealer in a high-crime area. The dealer arrived at a Wawa convenience store in a car driven by his girlfriend. The dealer exited the car and stood near the gas pump. The defendant approached the dealer on foot, and they conversed briefly. The dealer then had his girlfriend exit the car, sat in the driver’s seat, reached under it for several seconds, and returned to the defendant. They engaged in a brief hand-to-hand exchange and then departed. Believing they had witnessed a drug transaction, police stopped the defendant, who informed them he had a firearm in his bag. Police found the firearm but no drugs, and the defendant was arrested for illegally possessing the gun.The defendant was charged with carrying a concealed deadly weapon and possession of a firearm with an altered serial number. He moved to suppress the evidence, arguing that police lacked reasonable articulable suspicion to stop him. The Superior Court of Delaware denied the motion, finding that police had reasonable articulable suspicion based on their belief that the defendant and the drug dealer had engaged in a hand-to-hand drug transaction. The defendant was found guilty on both counts and appealed the denial of his suppression motion.The Supreme Court of Delaware reviewed the case and affirmed the Superior Court’s decision. The court found that the trial court’s factual findings were supported by sufficient evidence. It held that, based on the totality of the circumstances and the experienced officers’ interpretation of the facts, police had reasonable articulable suspicion to stop the defendant. The court concluded that the stop was justified, and the evidence obtained was admissible. View "Register v. State" on Justia Law

LKQ Corporation, a Delaware corporation in the auto salvage and recycled parts business, designated certain employees as "Key Persons" eligible for Restricted Stock Units (RSUs) through RSU Agreements. These agreements included non-competition clauses and provisions for forfeiture of RSUs and any stock issued if the employee competed with LKQ within nine months post-departure. Robert Rutledge, a plant manager at LKQ, signed these agreements and received stock under them. In April 2021, Rutledge resigned and joined a competitor shortly after.LKQ sued Rutledge in Illinois federal court for breach of contract and unjust enrichment, seeking to enjoin him from working for a competitor and to recover proceeds from the sale of LKQ stock. The district court dismissed the unjust enrichment claim and granted summary judgment for Rutledge on the contract claims, holding that the non-competition provisions were unreasonable restraints of trade under Illinois law and unenforceable under Delaware law, based on the Court of Chancery's decision in Ainslie v. Cantor Fitzgerald, L.P.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal of the unjust enrichment claim and the summary judgment ruling on the Restrictive Covenant Agreements. However, it was uncertain about the enforceability of the RSU Agreements' forfeiture-for-competition provisions under Delaware law, especially after the Delaware Supreme Court reversed the Court of Chancery's decision in Cantor Fitzgerald. The Seventh Circuit certified two questions to the Delaware Supreme Court regarding the applicability of Cantor Fitzgerald outside the limited partnership context.The Delaware Supreme Court held that the principles from Cantor Fitzgerald, which endorse the employee choice doctrine and prioritize freedom of contract, apply beyond the limited partnership context, including to RSU agreements. The court emphasized that forfeiture-for-competition provisions do not restrict competition or an employee's ability to work and should be treated as enforceable terms subject to ordinary breach of contract defenses. View "LKQ Corp. v. Rutledge" on Justia Law

In the early morning of June 22, 2022, Luis Coello called 911 after a vehicle crash. When officers arrived, they found Coello in pain and lying on the ground. Officer Miller asked Coello to sit down for medical reasons and requested his license as part of the accident investigation. Coello, still in pain, began to walk away, prompting Miller to ask him to stay. Officers Braun and Strickland arrived and questioned Coello, who indicated he only spoke Spanish. Coello admitted to driving the vehicle involved in the crash. He was not arrested at the scene but was later indicted on charges of Vehicular Homicide, Vehicular Assault, and Unreasonable Speed.The Superior Court of Delaware denied Coello's motion to suppress his statements made at the crash scene, ruling that he was not in custody for Miranda purposes and thus not entitled to Miranda warnings. The court found that the questioning was part of a routine, on-scene investigation and that Coello's statements were voluntary. Coello was subsequently convicted of all charges.On appeal, Coello argued that his statements should have been suppressed as they were obtained in violation of the Fifth Amendment and the Delaware Constitution. The Supreme Court of Delaware reviewed the case and held that Coello was not in Miranda custody during the on-scene questioning. The court emphasized that the questioning was part of a routine investigation and that Coello was not physically restrained or arrested at the scene. Therefore, the court affirmed the Superior Court's decision to deny the motion to suppress and upheld Coello's conviction. View "Coello v. State" on Justia Law

The case involves Sunder Energy, LLC (Sunder), a solar sales dealer, and its former employee, Tyler Jackson, along with several other defendants. Sunder sought to enforce restrictive covenants against Jackson, who had joined a competitor, Solar Pros LLC, and allegedly recruited Sunder employees to the new company. The restrictive covenants were part of Sunder's operating agreement, which Jackson signed without negotiation or full understanding of its terms.The Court of Chancery of the State of Delaware denied Sunder's motion for a preliminary injunction to enforce the restrictive covenants. The court found the covenants unenforceable for two reasons: they originated from an egregious breach of fiduciary duty by Sunder's principals, and they were facially unreasonable. The court also declined to "blue pencil" the covenants to make them reasonable, citing the overbroad and oppressive nature of the restrictions. Additionally, the court ruled that Utah law governed Sunder's tortious interference claim against Jackson's new employers, which effectively dismissed that claim under Utah law.The Supreme Court of the State of Delaware reviewed the case and affirmed the Court of Chancery's decision in part and reversed it in part. The Supreme Court agreed that the Court of Chancery did not abuse its discretion in refusing to blue pencil the restrictive covenants, given the lack of negotiation, minimal consideration, and the overbroad nature of the covenants. The Supreme Court also upheld the application of Utah law to the tortious interference claim. However, the Supreme Court reversed the Court of Chancery's ruling that the operating agreement was unenforceable as a matter of law, stating that such a determination exceeded the scope of the preliminary injunction stage and should await a complete factual record. View "Sunder Energy, LLC v. Jackson" on Justia Law

The case involves an ex-wife, Stephanie P. Shilling, attempting to enforce an agreement with her ex-husband, Ebon T. Shilling, regarding the sale of her interest in a property acquired during their marriage. The ex-husband offered to purchase the ex-wife's interest via email, and she accepted the offer. However, the Family Court found that the email exchanges did not result in an enforceable contract because the parties did not adequately manifest their intent to be bound and the exchanges did not contain all material contractual terms.The Family Court of the State of Delaware previously reviewed the case. The court found that there was no enforceable contract between the parties because the email exchanges lacked a meeting of the minds and did not include all material terms. Additionally, the court concluded that signing a formal written agreement was a condition precedent to the contract, and even if there was a contract, the ex-wife acquiesced in the ex-husband's repudiation by continuing to negotiate.The Supreme Court of the State of Delaware reviewed the case and disagreed with the Family Court's findings. The Supreme Court found that the email exchanges did form an enforceable contract as they contained a clear offer and acceptance, and the parties intended to be bound by the terms discussed in the emails. The court also determined that the signing of a formal written agreement was not a condition precedent to the contract. Furthermore, the Supreme Court found that the ex-wife did not acquiesce in the ex-husband's repudiation. Consequently, the Supreme Court reversed the Family Court's judgment and remanded the matter for further proceedings to determine appropriate relief in light of the enforceable contract. View "Shilling v. Shilling" on Justia Law

In this case, the defendant was convicted of first-degree murder, possession of a firearm during the commission of a felony, and possession of a firearm by a person prohibited. The key facts involve a shooting incident in Wilmington, Delaware, where the victim, Lionel Benson, was shot and later died from complications related to his injuries. The police investigation identified the defendant as the shooter based on statements from witnesses who later recanted their testimonies at trial.The Superior Court of Delaware admitted prison communications between the defendant and another inmate, which were used to show a conspiracy to dissuade witnesses from testifying. The court also admitted redacted statements from a key witness, which the defendant argued created a false impression and hampered his defense. The jury found the defendant guilty on all charges, and he was sentenced to life imprisonment plus additional years for the firearm charges.The Supreme Court of Delaware reviewed the case and affirmed the Superior Court's decisions. The court held that the prison communications were admissible under the co-conspirator exclusion from hearsay and as evidence of the defendant's identity and intent. The court also found that the redactions to the witness's statements did not violate the defendant's due process rights or constitute plain error. Additionally, the court upheld the reasonable doubt jury instruction, finding it consistent with constitutional requirements and previous case law.The Supreme Court of Delaware concluded that the Superior Court did not abuse its discretion in its evidentiary rulings and that the defendant's convictions were supported by the evidence presented at trial. The court affirmed the defendant's convictions and sentences. View "Burrell v. State" on Justia Law

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