Justia Delaware Supreme Court Opinion Summaries

Plaintiff-Appellant the State of Delaware appealed a Superior Court order granting a motion to suppress by the Defendants-Appellees Michael Holden and Lauren Lusby on grounds that the search warrant affidavit approved by the magistrate failed to establish probable cause. Upon review of the matter, the Supreme Court held that the magistrate had a substantial basis to conclude that probable cause existed to search Holden's home for contraband or evidence of a crime. Accordingly, the Court reversed the Superior Court judgment granting the motion to suppress. View "Delaware v. Holden" on Justia Law

In this appeal, the issue before the Supreme Court was whether a Superior Court judge’s decision to admit a blood analysis report without the testing chemist’s testimony violated Defendant–Appellant’s Sixth Amendment confrontation rights. Here, the testifying laboratory manager who ultimately certified the report testified before the jury, but the manager neither observed nor performed the test. The Court held that the absent analyst’s testimonial representations were admitted for their truth on an issue central to the case, which violated the Defendant’s right to confront the witnesses against him. Accordingly, the Court reversed and remanded the case for further proceedings. View "Martin v. Delaware" on Justia Law

The issue before the Supreme Court in this appeal was whether a Superior Court judge abused his discretion when he granted defense counsel an overnight continuance to review an additional set of laboratory reports the State’s chemist produced while testifying on cross examination. The Court agreed with the Superior Court judge’s ruling that the State failed to comply with Superior Court Criminal Rule 16. However, the Court held that the trial judge abused his discretion by granting defense counsel a continuance for less than 24 hours to review the highly technical data in the reports. Accordingly, the Court reversed and remanded the case for further proceedings. reverse. View "Oliver v. Delaware" on Justia Law

A state trooper stopped a member of Hells Angels for speeding. He refused to respond when asked where he was going. The trooper then informed him that he would be pat down. Defendant revealed he possessed two handguns. Defendant appealed his conviction on firearms charges, maintaining the trooper lacked probable cause to stop and arrest him. Upon review, the Supreme Court agreed with the superior court judge who suppressed evidence of the firearms because, under the totality of the circumstances, there was no particularized, reasonable, articulable suspicion that defendant was then armed and dangerous. View "Delaware v. Abel" on Justia Law

Defendant-appellant Frederick S. DeJohn, II appealed a Superior Court violation of probation ("VOP") sentencing order. On appeal, Defendant claimed that the Superior Court judge sentenced him with a closed mind and that the sentencing order contains a calculation error. Upon review, the Supreme Court concluded that the sentencing order did contain a calculation error, and that that when this matter was remanded for a recalculation of Defendant's sentence, he should be resentenced entirely by another judge. Therefore, the Court did not reach Defendant's issue of whether the Superior Court judge's comments evidenced a closed mind. View "DeJohn v. Delaware" on Justia Law

The issue on appeal before the Supreme Court in this case was whether the Chancellor correctly interpreted 15 Del. C. Sec. 3306, which allows political parties to replace candidates who become incapacitated. The Court held that under the statute, the term "incapacity" includes situations where a candidate would be practically incapable of fulfilling the duties of office in a minimally adequate way. In determining whether the standard was met, the Chancellor could consider events that occurred after the candidate withdrew. In this case, the Court concluded the withdrawing candidate was incapacitated and therefore affirmed the Court of Chancery's judgment. View "Sussex County Dept. of Elections, et al. v. Sussex County Republican Committee, et al." on Justia Law

The issue before the Supreme Court in this case was whether the Superior Court abused its discretion by dismissing a “trip and fall” case because appellant failed to file an expert report. Appellant’s counsel did provide medical records, but insisted that a formal expert report was unnecessary because such a report would provide no additional information. "Counsel’s stubborn refusal to appreciate that an expert report had to be filed is difficult to understand." But the Supreme Court concluded that the sanction of dismissal was inappropriate under the circumstances. "The claim appeared to have merit; there was time to submit the report without impacting the trial date; and the trial court had not imposed lesser sanctions that were ignored." Accordingly, the Court reversed. View "Hill v. DuShuttle" on Justia Law

The trial court precluded appellants’ experts from testifying at trial because they failed to provide the experts’ reports in accordance with the trial scheduling order. Without any expert testimony, appellants’ claims failed as a matter of law, and judgment was entered for appellees. But appellants had requested a conference with the trial court six months before the trial date to discuss the need to revise the scheduling order. The trial court refused to meet with counsel or change the trial date. Appellants appealed the trial court's refusal to confer, and the Supreme Court held that was an abuse of discretion: "A conference held at that point would have allowed the trial court to determine whether the circumstances justified a new trial date. If not, the trial court could have set new discovery deadlines that would have maintained the original trial date. . . . Because experience has shown that sanctions are not always effective [when counsel fails to abide by set deadlines, and to address crowded, high volume docket problems of the courts]," the Court has determined that it is necessary to refine the "Drejka" analysis. "Henceforth, parties who ignore or extend scheduling deadlines without promptly consulting the trial court, will do so at their own risk." View "Christian v. Counseling Resource Associates, Inc., et al." on Justia Law

The issue on appeal in this case stemmed from the Superior Court’s dismissal of appellant’s complaint for failure to provide discovery to appellees. Appellant was acting pro se for the first 18 months after she filed the complaint. During that time appellees, who had filed a counterclaim, filed several motions to compel answers to interrogatories and production of documents. The trial court held hearings on the motions; explained exactly what appellant needed to do in responding to the discovery; and warned that failure to comply with the court’s order could result in sanctions and dismissal. Appellant ignored the trial court’s warnings, and the court dismissed the complaint. She appealed, arguing the Superior Court abused its discretion in dismissing her case. Applying the "Drejka" factors, the Supreme Court found no abuse of discretion and affirmed. View "Adams v. Aidoo" on Justia Law

The issue before the Supreme Court in this case was whether the Superior Court abused its discretion in refusing to reopen a summary judgment entered against appellants after they missed the deadline for filing a response to appellees’ motion. Appellants mistakenly believed that they had 20 additional days to respond because appellees filed supplemental materials two weeks after filing their motion. The trial court apparently accepted the fact that appellants had made a mistake, but refused to reopen the case because appellants were unable to justify their mistake. Upon review, the Court concluded that the trial court failed to give adequate weight to the policy in favor of deciding cases on the merits, and reversed. View "Keener v. Isken" on Justia Law