Justia Delaware Supreme Court Opinion Summaries

Leslie D. Small appealed his convictions of two counts of First Degree Murder, three counts of Possession of a Deadly Weapon During the Commission of a Felony, First Degree Robbery, and Second Degree Burglary. The trial judge sentenced Small to death. Small made two arguments on appeal: (1) that the judge violated his Fifth Amendment right to remain silent by allowing testimony that Small refused to discuss the crime during his mental evaluation; and (2) that the prosecutor’s characterization of mitigating circumstances as “excuses” jeopardized the fairness and integrity of the penalty hearing. Because the Supreme Court found the prosecutor’s repeated characterization of mitigating evidence as excuses to be plain error, the Court reversed the imposition of the death sentence and remanded the case for a new penalty hearing. View "Small v. Delaware" on Justia Law

Defendant-Appellant Intel Corporation appealed a Superior Court order granting partial summary judgment in favor of Plaintiff-Appellee American Guarantee & Liability Insurance Co. (AGLI) in a dispute over the interpretation of an excess insurance policy under California law. AGLI sought and obtained a declaration from the Superior Court that AGLI had no duty to reimburse Intel for defense costs or indemnity claims in connection with Intel's defense of various antitrust lawsuits, because the underlying insurance policy limits of $50 million were not exhausted as required by the AGLI policy. Intel read the AGLI Policy to allow Intel to exhaust the limits of its underlying policy with XL Insurance Company by adding Intel's own contributed payments for defense costs to the amount of Intel's settlement with XL. Under Intel’s interpretation, the XL Policy was exhausted and AGLI's duty to defend was triggered. Upon review, the Supreme Court agreed with the Superior Court that AGLI's reading was the only reasonable reading, and accordingly, affirmed. View "Intel Corporation v. American Guarantee & Liability Insurance Co., et al." on Justia Law

After a first trial, at which a jury convicted the Defendant Dallas Drummond of three crimes, the Supreme Court remanded for a new trial because the Superior Court judge failed to thoroughly inform the defendant about the significance of his decision to waive counsel. During retrial, the trial judge allowed the State to present a record of the testimony given at the first trial. Later, a prosecution witness referenced the defendant's criminal history while responding to a question on cross examination. After being convicted again, Defendant appealed, claiming that reading of the prior testimony, and the witness' reference, were admitted in error and warranted a new trial. Finding no merit to Defendant's argument, the Supreme Court affirmed. View "Drummond v. Delaware" on Justia Law

Defendant-Appellant Earl Bradley, a former pediatrician, was found guilty of fourteen counts of Rape in the First Degree, five counts of Assault in the Second Degree, and five counts of Sexual Exploitation of a Child for acts of sexual and physical abuse committed against children. He was sentenced to fourteen mandatory life sentences and 164 years at Level V imprisonment for these crimes. Defendant raised two claims in his appeal, both relating to the Superior Court's denial of his motion to suppress evidence seized during the execution of a warrant. Defendant argued that the warrant itself was defective because the affidavit in support of the search warrant application did not allege facts establishing probable cause that the patients' medical files would be found in an outbuilding on the property where he practiced, would be contained in digital format, or would relate to the crimes described in the search warrant application. Defendant also contended that the police exceeded the scope of the search warrant by proceeding with a general search to locate and seize evidence without probable cause. Upon review, the Supreme Court held that the issuing judge had sufficient facts before him to make a practical, common-sense determination that evidence pertaining to the commission of a crime could be found in the patients' medical files, whether in paper or digital format. The Court also held that it was objectively reasonable to conclude that Bradley used the white outbuilding identified in the warrant for medical examinations, and that patient files could be found there. The Supreme Court held that the police acted reasonably in executing the warrant with respect to the evidence that was introduced at Bradley's trial. Accordingly, the Court concluded that Defendant's claims lacked merit and affirmed. View "Bradley v. Delaware" on Justia Law

A jury convicted Peter Kostyshyn of three crimes. He appealed, claiming that the Superior Court judge erred by finding he forfeited his right to appointed counsel, even though he screamed "You’re an idiot" at one of his attorneys during a court hearing, and then managed to drive off his next attorney by engaging in behavior the Superior Court judge deemed "abusive." Kostyshyn claimed that the Superior Court judge erred by failing to order, sua sponte, a competency hearing, even though the judge conducted lengthy colloquies about all aspects of Kostyshyn’s case. Finally, Kostyshyn argued that the trial judge’s clarifying instruction to the jury constituted an impermissible comment on what facts the jury should find. Finding no merit to any of these arguments, the Supreme Court affirmed the convictions. View "Kostyshyn v. Delaware" on Justia Law

This was an appeal from a post-trial decision and final judgment of the Court of Chancery that awarded more than $2 billion in damages and more than $304 million in attorneys' fees. The Court of Chancery held that defendants-appellants, Americas Mining Corporation (AMC), subsidiary of Southern Copper Corporation's (Southern Peru) controlling shareholder, and affiliate directors of Southern Peru (collectively, Defendants), breached their fiduciary duty of loyalty to Southern Peru and its minority stockholders by causing Southern Peru to acquire the controller’s 99.15% interest in a Mexican mining company, Minera Mexico, S.A. de C.V., for much more than it was worth (i.e., at an unfair price.). Plaintiff challenged the transaction derivatively on behalf of Southern Peru. The Court of Chancery found the trial evidence established that the controlling shareholder, Grupo Mexico, S.A.B. de C.V., through AMC, "extracted a deal that was far better than market" from Southern Peru due to the ineffective operation of a special committee. To remedy the Defendants’ breaches of loyalty, the Court of Chancery awarded the difference between the value Southern Peru paid for Minera ($3.7 billion) and the amount the Court of Chancery determined Minera was worth ($2.4 billion). Defendants raised five issues on appeal. Upon review, the Supreme Court determined that all of the Defendants' arguments were without merit. Therefore, the judgment of the Court of Chancery was affirmed. View "Americas Mining Corp. v. Theriault Southern Copper Corp." on Justia Law

The New Castle County Sheriff sold real property encumbered with a judgment lien and a mortgage lien, in that order of priority, at a mandated sheriff’s sale. The Sheriff disbursed the proceeds to Eastern Savings Bank, the mortgage lien holder. CACH, LLC, the judgment lien holder, filed a complaint in the Court of Common Pleas alleging misappropriation and unjust enrichment. The Court of Common Pleas judge denied CACH’s Motion for Summary Judgment and granted Eastern’s Motion to Dismiss for failure to state a claim. The Superior Court judge reversed. On appeal, Eastern argued that the sheriff’s sale did not discharge the judgment lien, and therefore CACH is not entitled to the sale proceeds. Upon review, the Supreme Court found no merit to Eastern’s argument and held that: (1) all nonmortgage liens are discharged at a sheriff’s sale and (2) sheriff’s sale proceeds are disbursed according to a first in time, first in line priority. Therefore, the Court affirmed. View "Eastern Savings Bank, FSB v. Cach, LLC" on Justia Law

A grand jury indicted Defendant Jeffrey Rose for: (1) Trafficking in Cocaine, (2) Possession with Intent to Deliver, (3) Maintaining a Dwelling for Keeping Controlled Substances, and two other charges. The indictment for Maintaining a Dwelling referenced Counts I and II. The jury acquitted Defendant of those two Counts but convicted Rose on the Maintaining a Dwelling charge. Defendant argued on appeal that his conviction were based on insufficient evidence because Counts I and II were predicate offenses on which the jury acquitted him. The Supreme Court found no merit to Defendant's argument and affirmed. View "Rose v. Delaware" on Justia Law

Defendant-Appellant Patrick Monceaux appealed the denial of his motion to dismiss charges against him under Section 777A of the Delaware Code. He contended that the statute violated his right to due process under the United States and the Delaware Constitutions because placing his status as a sex offender directly in issue lessened the State's burden of proof and the presumption of innocence. He also contended that the trial judge erred by failing to address this constitutional argument when denying his motion to dismiss. Instead, the trial judge bifurcated the trial into two phases. In the first phase, the elements of the Unlawful Sexual Contact Second Degree charge were tried before a jury with no evidence of Monceaux's status as a sex offender. With the consent of Monceaux, the second phase of the trial, limited to determining his status as a registered sex offender, was tried before the trial judge. The bifurcation procedure used by the trial judge in this case prevented the jury from hearing evidence of Monceaux's sex offender status before determining his guilt for purposes of Section 777A. For that reason, the Supreme Court found no merit to Monceaux's constitutional claim. Furthermore, the Court held that the Superior Court must use a bifurcation procedure in all future Section 777A cases, to avoid the potential constitutional issues raised here. Finally, because the alternate relief requested in Monceaux's motion to dismiss was bifurcation, which the trial judge granted, Monceaux's second claim on appeal lacked merit. Accordingly, the Supreme Court affirmed. View "Monceaux v. State" on Justia Law

A private company applied to build a wastewater treatment facility that would occupy many acres within the area protected by the Coastal Zone Act (CZA). The application proceeded through multiple layers of review, and came before the Supreme Court to decide where this facility fit within the CZA’s classification scheme, how to enforce the regulations governing “offsets” when the facility constitutes its own offset and the permit contains conditions, and the legal status of an order from the Coastal Zone Industrial Control Board that a majority of members agreed to, but less than a majority signed. The Court remanded the case to the Board, with instructions that the facility at issue is neither a “heavy industry” use nor a “manufacturing” use, and that the Board should take care to follow the statutory requirement that all members of a quorum of a Board sign any order on which they voted. View "Sierra Club Citizens Coalition Inc. v. Tidewater Environmental Services, Inc." on Justia Law