Justia Delaware Supreme Court Opinion Summaries

The issue on appeal before the Supreme Court in this case was the denial of a postconviction relief motion. Specifically, the issue was whether defense counsel were ineffective during a defendant's first-degree murder trial. Upon review, the Court held that the attorneys' alleged failure to consult with a forensic pathologist or toxicologist, to present more evidence regarding the victim's dominant hand, to investigate ballistics issues, appeal certain issues, and to object to the dismissal of jurors who indicated that they could not impose the death penalty did not prejudice the defendant during his trial's guilt phase. During the penalty phase, however, the postconviction hearing judge failed to reweigh the aggravating evidence against the total mix of mitigating evidence in determining whether the attorneys' failure to present additional evidence during the penalty phase prejudiced the defendant. Accordingly, the Court affirmed in part, and remanded in part so that the postconviction judge could supplement his opinion for further review.View "Ploof v. Delaware" on Justia Law

Defendant-Appellant Parris Hamilton appealed his conviction on two counts of Murder First Degree, two counts of Attempted Murder First Degree, two counts of Kidnapping First Degree, one count of Burglary First Degree, and seven counts of Possession of a Firearm During the Commission of a Felony. On appeal, defendant argued: (1) that the trial court erred when it allowed a nonlegal expert witness to make a misstatement of the law and failed to give a timely and adequate curative instruction; and (2) that the State failed to prove every element of the burglary charge. Finding no merit to Hamilton's claims, the Supreme Court affirmed. View "Hamilton v. Delaware" on Justia Law

Defendant Tyrone Guy appealed the denial of his application for postconviction relief. The issue before the Supreme Court in this case centered on how the procedural bars of Superior Court Criminal Rule 61 applied to his claims, including a claim of ineffective assistance of postconviction counsel. Defendant argued on appeal: (1) that the Superior Court erred during his trial by failing to give the "modified 'Bland'" jury instruction on accomplice testimony mandated by the Supreme Court's 2012 decision in "Brooks v. Delaware"; and (2) that his appointed counsel was ineffective in his first postconviction proceeding for failing to present ten out of eleven claims of ineffective assistance of trial counsel. Upon review, the Court concluded that defendant's claims were untimely and that his first claim was previously adjudicated. Defendant failed to meet the procedural burdens. Accordingly, the Court affirmed the Superior Court's judgment in this case, although it did so on independent and alternative grounds. View "Guy v. Delaware" on Justia Law

Plaintiff-Appellants asserted various tort claims against Advanced Micro Devices, Inc. (AMD). AMD moved to exclude certain expert testimony under Delaware Rule of Evidence 702, which the Superior Court granted after determining that the evidence was not relevant. Plaintiff-Appellants appealed to the Supreme Court, which remanded the case to the Superior Court for further findings related to the expert testimony’s admissibility. On remand, the Superior Court found that the expert testimony was unreliable and therefore inadmissible. After review of that decision, the Supreme Court concluded that the Superior Court did not abuse its discretion in finding the expert testimony unreliable, and affirmed its judgment. View "Tumlinson, et al. v. Advanced Micro Devices, Inc." on Justia Law

Defendant-appellant Kalvin Peterson a Superior Court judgment convicting him of one count of Possession of a Firearm by a Person Prohibited. Peterson's claim of error was that collateral estoppel and double jeopardy barred his conviction: that the bench trial conviction was precluded because at a concurrent trial, a jury acquitted him of both Possession of a Firearm During the Commission of a Felony, and the underlying felony of Assault in the First Degree. Upon review, the Supreme Court concluded that Peterson's arguments were without merit. View "Peterson v. Delaware" on Justia Law

Defendant-appellant Ronald Jones appealed his bench trial conviction on one count of Failing to Reregister as a Sex Offender. Jones raised one claim on appeal: that the evidence failed to show beyond a reasonable doubt that Jones had knowingly or recklessly failed to re-register as a homeless sex offender. Finding Jones' argument without merit, the Supreme Court affirmed his conviction. View "Jones v. Delaware" on Justia Law

Defendant Michael Neal appealed the denial of his motion for post-conviction relief. The issue before the Supreme Court in this matter was whether defendant received ineffective assistance of both trial and appellate counsel. Defendant was arrested after a series of robberies on New Year’s Eve 2008. Defendant argued that his trial and appellate counsel were ineffective for failing to request at trial, and for failing to argue on direct appeal: (1) the inclusion of a "Bland" instruction in connection with certain accomplice testimony; and (2) the admission of certain out-of-court statements under Delaware Rule of Evidence 804(b)(3). Ultimately, the Supreme Court held that the defendant's trial and appellate counsel were not ineffective in their representation. View "Neal v. Delaware" on Justia Law

Appellant Quadrant Structured Products Company appealed the Court of Chancery's dismissal of its complaint. Quadrant holds certain Notes issued by Athilon Capital Corp., an allegedly insolvent Delaware corporation. The Notes are long term obligations covered by two separate trust indentures that are governed by New York law. Defendants EBF & Associates, LP, Athilon Structured Investment Advisors ('ASIA'), an affiliated EBF entity, Athilon's board of directors, and Athilon itself, all which indirectly own 100% of Athilon's equity. The Court of Chancery granted defendants' motion to dismiss Quadrant's complaint on the ground that all claims alleged were barred for failure to comply with the 'no-action' clauses in the Athilon trust indentures. In both cases the cited by the Court of Chancery applied New York law, and held that those bondholder actions were barred by the no-action clauses of the respective trust indentures that governed the bonds at issue. Quadrant appealed to the Delaware Supreme Court. The Delaware Court remanded the case to the Court of Chancery with directions to analyze the significance under New York law (if any) of the differences between the wording of the no-action clauses at issue in the two cited cases and in this case. In its Report, the Court of Chancery held that: (i) 'the language of the Athilon no-action clause distinguishe[d] this case from [the two cited cases],' and (ii) the motion to dismiss should have been denied except as to two (and part of a third) of the ten Counts of the Quadrant complaint. After its re-review, the Delware Supreme Court concluded that the resolution of this case depended on dispositive and unsettled questions of New York law that, in its view, were properly answered in the first instance by the New York Court of Appeals. View "Quadrant Structured Products Co., Ltd. v. Vertin, et al." on Justia Law

Robert McKinley and Michele Casson were involved in a motor vehicle accident McKinley’s motorcycle collided with the back of Casson’s SUV. McKinley, who was not wearing a motorcycle helmet, sustained serious injuries. The issue before the Supreme Court centered on several evidentiary rulings made by the trial court. Among other things, appellant contended the trial court erred in denying him access to the appellee’s medical records, and that the jury should not have been allowed to learn that he was not wearing a helmet at the time of the accident. The Supreme Court agreed, and reversed and remanded for a new trial. View "McKinley v. Casson" on Justia Law

A Superior Court jury found Defendant–Appellant Davear Whittle guilty of Murder in the Second Degree, Possession of a Firearm During the Commission of a Felony, Reckless Endangering in the First Degree, and Possession of a Firearm by a Person Prohibited. On appeal, he challenged his convictions, contending the prosecutor improperly vouched for the credibility of three witnesses in his closing argument, by stating that they were "right" or "correct" at least 20 times. Upon review, the Supreme Court concluded that the prosecutor's amounted to improper vouching and constituted plain error. Therefore, the Court reversed the Superior Court and remanded the case for a new trial. View "Whittle v. Delaware" on Justia Law