Justia Delaware Supreme Court Opinion Summaries

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

Three siblings, who are stockholders in a closely held, family-run Delaware corporation that streams sports content, sought access to the company’s books and records. The siblings were dissatisfied with the lack of financial information and annual meetings after their brother was replaced as CEO. Their motivation was to value their shares and possibly sell them. Over a ten-month period, the siblings made three separate demands under Section 220 of the Delaware General Corporation Law, each seeking inspection of various corporate documents. The company denied all three demands, asserting that each failed to satisfy the statute’s procedural “form and manner” requirements for such demands.After the company denied the demands, the siblings filed a complaint in the Delaware Court of Chancery to compel inspection. The matter was first reviewed by a Magistrate in Chancery, who found that the third demand satisfied the statutory waiting period and that the siblings had a proper purpose for inspection, granting most of the requested documents except for tax-related items. The Magistrate also ordered the parties to negotiate a confidentiality agreement. Both parties filed exceptions to the Magistrate’s report, and the Court of Chancery conducted further review.The Court of Chancery ultimately found that all three demands failed to meet Section 220’s procedural requirements. It ruled that the first demand was deficient for lack of oath, power of attorney, and identification of stockholders; the second demand failed because affidavits verifying the demand were signed before the demand was finalized, with no evidence the verified version matched the final one; and the third demand was rejected because the siblings applied to the court before the statutory five-day waiting period had elapsed. Judgment was entered for the company.On appeal, the Supreme Court of Delaware affirmed the Court of Chancery’s decision. It held that strict compliance with Section 220’s form and manner requirements is necessary, and that the siblings failed to meet those requirements for all three demands. View "Martin Floreani v. FloSports, Inc." on Justia Law

The dispute centers on a Delaware law, House Bill 242 (HB242), which permits New Castle County school districts to set different property tax rates for residential and non-residential properties for the 2025-2026 school year. This legislation was enacted after a county-wide property reassessment revealed a significant shift in the tax base, resulting in higher taxes for residential properties. In response to public concern, HB242 allowed school districts to implement a split-rate system, reducing residential rates and increasing non-residential rates, with the stipulation that non-residential rates could not exceed twice the residential rate and that total projected revenue could not surpass the amount projected under the original tax warrant. Subsequent corrections to property classifications led to a net increase in projected tax revenue.The plaintiffs, four property-related associations, challenged HB242 in the Court of Chancery, arguing that it violated the Uniformity Clause of the Delaware Constitution and a “revenue neutrality” requirement in the statute. The Court of Chancery rejected these claims, finding that the General Assembly has the authority to create reasonable property classifications for tax purposes and that the statute’s use of “projected” rather than “actual” revenue allowed for adjustments due to classification corrections.On appeal, the Supreme Court of Delaware reviewed the constitutionality of HB242 and the statutory interpretation issues de novo. The Court held that the Uniformity Clause does not prohibit reasonable legislative classifications of property for taxation, provided tax rates are uniform within each class. The Court also determined that HB242’s revenue limitation applies to projected, not actual, revenue, and that corrections to property classifications do not violate the statute. The Supreme Court of Delaware affirmed the judgment of the Court of Chancery. View "Newark Property Association v. State" on Justia Law

A confidential informant reported seeing Anthony Miller, known as “Thugsy,” carrying a handgun and selling drugs in Wilmington, Delaware. Police surveilled the area, observed Miller, and attempted to arrest him. Miller fled, resisted arrest, and was subdued. Officers recovered a loaded handgun and drugs, including pills that tested positive for MDMA and cocaine. Miller admitted to selling MDMA and possessing the firearm. He was initially indicted by a New Castle County grand jury for several offenses, including Drug Dealing MDMA (a Class B felony). A subsequent reindictment changed the main drug charge to Drug Dealing Methamphetamine (a Class C felony), reflecting the actual substance involved.Before his suppression motion was heard, Miller entered a plea agreement in the Superior Court of the State of Delaware, pleading guilty to Drug Dealing Methamphetamine, Possession of a Firearm During the Commission of a Felony, and Resisting Arrest. Due to clerical errors, the plea paperwork and colloquy incorrectly identified the drug dealing charge as a Class B felony with a higher sentencing range, even though the court read the correct substance and quantity from the reindictment. Miller was sentenced to a total of seven years of unsuspended prison time. He did not seek to withdraw his plea but appealed, arguing that his constitutional right to be indicted by a grand jury was violated because he pled guilty to an unindicted, more serious offense.The Supreme Court of the State of Delaware reviewed the case for plain error, as Miller had not raised the issue below. The court held that Miller’s substantial rights were not affected because he received significant benefits from the plea, including immediate sentencing and avoidance of a much longer potential sentence. The court found no plain error and affirmed the conviction, but remanded to the Superior Court to consider Miller’s pending motion for sentence reduction. View "Miller v. State" on Justia Law

A man was shot and killed outside a convenience store in Wilmington, Delaware. Surveillance footage captured the masked shooter’s movements before and after the incident, and police identified several witnesses, including Darnella Spady, who was present at the scene. During a police interview, Spady identified the shooter as “Gunner,” later determined to be Kevin Berry, and described her interactions with him. However, at trial, Spady was uncooperative, claimed memory loss due to drug use, and stated she could not recall the shooting or her prior statement to police. The prosecution sought to admit Spady’s out-of-court statement as substantive evidence under 11 Del. C. § 3507.The Superior Court of the State of Delaware conducted a bench trial after Berry waived his right to a jury. The court admitted Spady’s prior statement over Berry’s objection, finding that the State had established the necessary foundation under Section 3507 and that the statement was voluntary. The court found Berry guilty of first-degree murder and related weapons charges, and sentenced him to life plus ten years. Berry appealed, arguing that the trial court erred in admitting Spady’s statement and urging the Delaware Supreme Court to overturn its recent precedent in McCrary v. State, which clarified the foundational requirements for admitting such statements.The Supreme Court of the State of Delaware reviewed the case and affirmed the Superior Court’s decision. The Court held that there was no urgent reason or clear error warranting a departure from McCrary v. State, and that the trial court did not abuse its discretion in admitting Spady’s statement. The Court concluded that the State’s questioning satisfied the statutory requirements, and Berry’s confrontation rights were not violated. The convictions were affirmed. View "Berry v. State" on Justia Law

A masked assailant entered a jewelry store in Delaware, assaulted the owner with a gun and hammer, smashed display cases, and stole jewelry before fleeing. The owner, Chang Yen Suh, suffered significant injuries requiring hospitalization and months of rehabilitation. Calvin Ushery was indicted for multiple offenses, including first-degree robbery, first-degree assault of a person over 62, possession of a deadly weapon during the commission of a felony, and other related charges. After a mistrial in the first jury trial, a second jury trial resulted in Ushery’s conviction on three counts. The State dismissed several other charges, and Ushery was sentenced as a habitual offender to substantial prison terms.The Superior Court of the State of Delaware presided over both trials and sentencing. Ushery appealed, arguing that the trial court failed to properly admonish the jury against pre-deliberation discussions and exposure to extrajudicial information, and that the court erred by not investigating or excusing an alternate juror who submitted a note raising questions about the evidence and his own hearing difficulties. Ushery claimed these failures violated his constitutional right to a fair trial by an impartial jury and requested the adoption of a presumption of juror misconduct when admonishments are lacking.The Supreme Court of the State of Delaware reviewed the case for plain error, as Ushery’s claims were not raised at trial. The Court held that, although daily admonishments are recommended, the instructions given were sufficient and did not constitute plain error. The Court also found no evidence of juror misconduct or bias, and that the trial court acted within its discretion regarding the alternate juror. The Supreme Court affirmed the Superior Court’s judgment of conviction. View "Ushery v. State" on Justia Law

Two young sisters reported to their mother that their father had sexually abused them. The mother contacted the police, and after an investigation, the State charged the father with multiple offenses related to the sexual abuse of both daughters, who were under the age of twelve at the time. Before trial, the defense sought permission to introduce evidence of the daughters’ prior sexual abuse allegations against other individuals, including a half-brother and a cousin, arguing this evidence was relevant to their credibility and knowledge of sexual matters. The defense also requested to admit a police report describing the children’s inappropriate behavior, but later withdrew some of these requests.The Superior Court of the State of Delaware denied the defense’s motion to admit the prior allegations, finding the evidence either nonspecific or lacking proof of falsity, and applied a clear and convincing evidence standard for showing that prior allegations were false. At trial, both daughters testified, with one allowed to hold a stuffed animal for comfort. The jury convicted the father on most charges, and he was sentenced to 119 years in prison. The defense moved for a new trial, arguing the court used the wrong legal standard for admitting the prior allegations and improperly allowed the comfort item. The Superior Court denied the motion, reaffirming its evidentiary rulings and the standard applied.On appeal, the Supreme Court of the State of Delaware reviewed whether the Superior Court applied the correct legal standard regarding the admissibility of prior sexual abuse allegations and whether it abused its discretion in allowing the comfort item. The Supreme Court held that, regardless of the standard, the defense failed to present any evidence that the prior allegations were false, and thus exclusion was proper. The Court also found no abuse of discretion in permitting the child to hold a stuffed animal while testifying. The convictions and judgment were affirmed. View "Massey v. State" on Justia Law

A computer repair shop owner in Wilmington, Delaware, came into possession of a laptop and data belonging to Robert Hunter Biden in April 2019, after Biden left the device for repair and failed to retrieve it. The shop owner, John Paul Mac Isaac, eventually provided a copy of the data to an attorney for Rudy Giuliani, who then shared it with the New York Post. The Post published a story about the laptop in October 2020, which led to widespread media attention and public identification of Mac Isaac as the source. Subsequent media coverage included a Politico article summarizing a letter from former intelligence officials suggesting the laptop story had the hallmarks of Russian disinformation, and public statements by the Biden campaign and Hunter Biden himself, some of which Mac Isaac alleged were defamatory.Mac Isaac filed suit in the Delaware Superior Court against Politico, Hunter Biden, and the Biden campaign, alleging defamation and related claims. He later amended his complaint to add the Biden campaign as a defendant. The case was briefly removed to federal court and then remanded. The defendants moved to dismiss, and Hunter Biden also filed counterclaims for invasion of privacy, which Mac Isaac moved to dismiss.The Supreme Court of the State of Delaware reviewed the Superior Court’s dismissal of Mac Isaac’s claims and Hunter Biden’s counterclaims. The Court held that the allegedly defamatory statements did not concern Mac Isaac and were not actionable as defamation. It also found that the Superior Court properly dismissed Hunter Biden’s counterclaims as time-barred under the statute of limitations, given the facts known to him by October 2020. The Supreme Court affirmed the Superior Court’s order in all respects. View "Isaac v. Politico LLC, et al." on Justia Law

CVS Health Corporation sought insurance coverage from its insurers for thousands of lawsuits brought by government entities, hospitals, and third-party payors. These lawsuits alleged that CVS’s opioid dispensing practices contributed to the opioid epidemic, resulting in significant public health and economic costs. CVS’s insurance policies, issued by Chubb and AIG, generally covered damages that CVS became legally obligated to pay “because of bodily injury or property damage” caused by an “occurrence.” Some policies included endorsements related to pharmacist or druggist liability, which CVS argued broadened coverage.The insurers filed a declaratory judgment action in the Superior Court of the State of Delaware, seeking a declaration that they owed no duty to defend or indemnify CVS in these lawsuits. The Superior Court granted summary judgment in favor of the insurers, holding that the underlying lawsuits did not seek damages for specific, individualized bodily injury or property damage as required by the policies. Instead, the court found that the lawsuits sought recovery for the plaintiffs’ own economic losses, such as increased public spending and general harm to public health systems. The court also determined that the policy endorsements did not alter the requirement that damages must be “because of” bodily injury or property damage. The court further held that the insurers had no duty to indemnify CVS, as the underlying claims did not depend on proof of personal injury or property damage.On appeal, the Supreme Court of the State of Delaware affirmed the Superior Court’s decision. The Supreme Court held that the insurance policies and their endorsements did not provide coverage for the lawsuits at issue because the claims did not allege specific and individualized bodily injury or property damage. The court also concluded that the duty to indemnify was not triggered, as there were no unresolved factual issues that could lead to coverage. The judgment of the Superior Court was affirmed. View "In Re: CVS Opioid Insurance Litigation" on Justia Law

A corporate parent acquired several subsidiaries that had previously developed and sold earplugs, which later became the subject of extensive products-liability litigation. The lawsuits, consolidated in federal multidistrict litigation and Minnesota state court, alleged hearing injuries from defective earplug design. While defending these suits, the subsidiaries and the parent incurred substantial legal costs. During the litigation, the subsidiaries filed for Chapter 11 bankruptcy, but the bankruptcy court found they were financially healthy and dismissed the petitions. Subsequently, the parent and subsidiaries reached a global settlement of the lawsuits.After the bankruptcy dismissal, the subsidiaries and their parent sought insurance coverage from the subsidiaries’ insurers for defense costs. The relevant insurance policies, issued by Twin City Fire Insurance Company, ACE American Insurance Company, and MS Transverse Specialty Insurance Company, contained self-insured retention (SIR) provisions requiring the “Named Insured” to pay a specified amount before coverage was triggered. The parent company was not a “Named Insured” under any policy. The Superior Court of the State of Delaware held that only payments made by the “Named Insured” could satisfy the SIRs, and payments made by the parent did not trigger the insurers’ coverage obligations. The court also rejected the argument that the policies’ maintenance clauses entitled the insureds to coverage for all defense costs minus the SIR, finding those clauses inapplicable.On appeal, the Supreme Court of the State of Delaware reviewed the Superior Court’s summary judgment decision and interpretation of the insurance contracts de novo. The Supreme Court affirmed, holding that the policies unambiguously required the “Named Insured” to satisfy the SIRs and that the parent’s payments did not trigger coverage. The Court further held that the maintenance clauses did not apply to excuse satisfaction of the SIRs or create a setoff in this context. The judgment for the insurers was affirmed. View "In Re Aearo Technologies LLC Insurance Appeals" on Justia Law