Justia Delaware Supreme Court Opinion Summaries

Defendant Naifece Houston was charged with drug offenses following a traffic stop, and moved to suppress evidence on various grounds, including that the arresting officers impermissibly extended the stop to allow time for a drug-sniffing dog to arrive. In his motion to suppress, defendant asked the superior court to hold a Daubert hearing so that he could contest the admissibility of testimony from one of the arresting officers that he could detect an odor at the scene emanating from the defendant’s car - a “chemically smell” that the officer associated with large amounts of cocaine. Because the officer’s testimony was based on his training and experience as a police officer, according to defendant, it was “expert in nature,” triggering the trial court’s gatekeeping function under Daubert and its progeny. The superior court disagreed, concluding that the officer’s testimony was not based on scientific, technical, or other specialized knowledge, but, rather, was lay opinion testimony admissible under Delaware Rule of Evidence 701. On that rationale, defendant appealed, arguing the superior court erred. And had defendant’s motion been granted, he contended the State would have been left with no evidence that he was guilty of the drug offenses with which he was charged. The Delaware Supreme Court concluded that both defendant and the State, and ultimately the Superior Court, mistakenly framed the issue in the proceedings below as hinging upon the admissibility of the officer’s testimony under the rules of evidence governing opinion testimony. "Thus, the true question before the superior court was whether the challenged testimony was sufficiently reliable to justify the officer’s suspicion that there was cocaine in the defendant’s car." The Supreme Court concluded the trial court’s admission of the officer’s testimony was not an abuse of discretion. Thus, judgment was affirmed. View "Houston v. Delaware" on Justia Law

Appellant Wild Meadows MHC, LLC challenged the Superior Court’s dismissal of its petition for a writ of prohibition. The Wild Meadows manufactured home community (the “Community”) owned by Appellant, was located in Dover, Delaware. The Community was governed by the Manufactured Home Owners and Community Owners Act and its subsection commonly known as the Rent Justification Act (the “Act”). Appellee Intervenor/Respondent Wild Meadows Homeowners’ Association (the “HOA”) represented these homeowners. Multiple homeowners rejected Wild Meadows’ rent increase and, through the HOA, filed a petition with the Delaware Manufactured Home Relocation Authority (the “Authority”). The Authority appointed Appellee David J. Weidman, Esquire as the arbitrator under the Act. Before the scheduled arbitration, the HOA requested financial information from Wild Meadows relating to the Community’s recent revenue and costs. Wild Meadows refused to provide this information. The HOA moved to compel discovery and a motion for summary judgment with Weidman. In his initial decision, Weidman granted discovery of any financial documents that Wild Meadows intended to rely upon at arbitration, but he denied the HOA’s motion to compel the production of additional financial documents from Wild Meadows. Determining he could compel discover, Weidman ordered Wild Meadows to submit a proposed confidentiality agreement, and ordered the HOA to submit any comments on the draft. After taking both parties' comments into consideration, Weidman issued a final confidentiality agreement, rejecting many of the changes the HOA proposed. Wild Meadows refused to sign the confidentiality agreement and filed the underlying application for a writ of prohibition in the Superior Court. Wild Meadows argued to the Delaware Supreme Court that the Superior Court erroneously held that the arbitrator appointed under Delaware’s Rent Justification Act had authority to compel discovery and impose a confidentiality agreement upon parties concerning discovery material. Finding no reversible error in the Superior Court's judgment, the Supreme Court affirmed. View "Wild Meadows MHC, LLC v. Weidman" on Justia Law

In 2018, an enforcement officer working for the Department of Natural Resources and Environmental Control pulled over a truck hauling municipal solid waste from the Pine Tree Corners Transfer Station. The truck’s owner-operator, Contractors Hauling, LLC, did not have a valid permit to transport solid waste, violating Delaware law. The Department subsequently determined that on numerous occasions between September 2017 and July 2018, vehicles belonging to Contractors Hauling transported solid waste from the Pine Tree Station without a valid permit. The Delaware Solid Waste Authority operated the Pine Tree Station subject to a Department-issued permit. In 2017, the Authority transferred operations of the station to a subcontractor, Greggo & Ferrera, Inc. (“G&F”). Later that year - and apparently without the Authority’s knowledge - G&F began using vehicles owned and operated by its affiliate entity, Contractors Hauling, to transport waste from the transfer station to waste disposal facilities. The Department determined that each of the three entities - the Authority, G&F, and Contractors Hauling - violated various requirements related to solid waste, and the Department assessed civil penalties and costs. Each entity filed a timely appeal with the Environmental Appeals Board. The Board reversed the Department’s assessments of fines and penalties. The Department appealed to the Superior Court. The court held: (1) the Department had the authority to impose the permit condition, but it was unconstitutionally vague; (2) the Authority was strictly liable for failing to provide a complete list of transporters; (3) the Board erred by setting aside the penalties assessed against G&F and Contractors Hauling; and (4) the Secretary’s cost assessments were not before the Board. Each of the parties appealed the Superior Court’s decision. After review, the Delaware Supreme Court held: (1) the Superior Court and the Board erred by holding that the permit condition was unlawful; (2) the Superior Court properly held that the Authority was strictly liable for failing to provide a complete list of transporters; (3) the Superior Court erred by overturning the Board’s determination that no penalty should have been assessed against G&F and Contractors Hauling; and (4) the Superior Court properly held that the Secretary’s ability to recover costs was not before the Board. Accordingly, the Supreme Court affirmed in part, reversed in part, and remanded the case back to the Superior Court for further proceedings. View "Delaware Solid Waste Authority v. Delaware Department of Natural Resources and Environmental Control" on Justia Law

McArthur Risper was convicted by jury of first-degree murder, first degree conspiracy, and possession of a firearm during the commission of a felony for his role in the May 2018 shooting death of Corey Bailey. The superior court sentenced Risper to life plus 30 years in prison. The theory of the prosecution was that Risper intentionally killed Bailey as revenge for Bailey’s theft of drugs and a firearm belonging to Risper. Risper claimed that the evidence of Bailey’s theft and Risper’s subsequent efforts to recover the stolen drugs and firearm was prior-misconduct evidence, and therefore inadmissible under Delaware rules of evidence. Furthermore, Risper claimed he did not receive a fair trial because the State did not disclose in a timely manner evidence that was favorable to the defense as required under Brady v. Maryland and its progeny. According to Risper, the State’s belated disclosures (one on the day before trial was to begin and the other on the fourth day of trial) fundamentally undermined the fairness of his trial. The Delaware Supreme Court agreed with Risper as to his second contention, concluding that the State’s failure to produce, until the afternoon before Risper’s trial was to begin, a recorded interview of an individual who told the chief investigating officer that another person had confessed to her that he had killed Bailey and showed her the gun used in the shooting was a violation of the State’s obligations under Brady. "And because that violation undermines our confidence in the outcome of Risper’s trial, we reverse and remand to the Superior Court for a new trial." View "Risper v. Delaware" on Justia Law

A Delaware superior court affirmed decisions by the Delaware Secretary of State (the “Secretary”) and the Delaware Board of Medical Licensure and Discipline (the “Board”) to revoke Dr. Nihar Gala’s medical license and controlled substance registration (“CSR”). The court upheld the Board’s and Secretary’s decisions after finding that substantial evidence existed to support the issued discipline. On appeal, Gala argued: (1) the Board’s decision to deliberate “behind closed doors” rendered the record incomplete for judicial review; (2) the Board and the Secretary were biased; and (3) the Board’s and the Secretary’s decisions to revoke his medical license and CSR were not supported by substantial evidence. The Delaware Supreme Court found the the Board and Secretary's decisions were supported by substantial evidence and were free from legal error. Accordingly, it affirmed the superior court. View "Gala v. Bullock" on Justia Law

Defendant Damon Anderson was convicted by jury on five felonies for his involvement in a Wilmington drug dealing enterprise. The Superior Court declared Anderson an habitual offender and sentenced him to an aggregate thirty-two years of incarceration. Anderson argued on appeal: (1) the trial court erred when it denied his motion to sever his case from that of co-defendants Eric Lloyd and Dwayne White; (2) the trial court should not have admitted gun evidence seized from a co-defendant’s apartment; (3) the trial court erred by denying his motions to suppress evidence discovered following search warrants for his home, car, and cell phones; and (4) the trial court erred in denying his motion for judgment of acquittal on two charges. The Delaware Supreme Court found no merit to any of these contentions and affirmed the Superior Court. View "Anderson v. Delaware" on Justia Law

Eric Lloyd was convicted by jury of six felonies stemming from his involvement in a Wilmington drug dealing enterprise. The Superior Court sentenced Lloyd to an aggregate of thirty years of incarceration without the possibility of early release. On appeal, Lloyd challenged his convictions and sentence, contending: (1) the trial court erred when it denied his motion to sever his case from that of co-defendant Dwayne White; (2) the trial court erred when it denied his motion for a mistrial after an eyewitness to a shooting misidentified Lloyd as the gunman; (3) the trial court should not have admitted gun evidence seized from a co-defendant’s apartment and rap music videos created by other enterprise members; (4) the trial court erred by allowing testimony from Lloyd’s former attorney’s secretary about a drug transaction. Finally, Lloyd argued the trial court violated his rights under the Eighth Amendment by imposing consecutive sentences, resulting in thirty years of incarceration, without the option for early release. Finding no merit to these claims, the Delaware Supreme Court affirmed Lloyd's convictions. View "Lloyd v. Delaware" on Justia Law

In 1994, the Delaware General Assembly enacted a statute, applicable to both criminal and civil proceedings, that eased the evidentiary burden on the proponent of controlled-substance-testing evidence. The statute, "Subchapter III," allowed for the admission of, and a favorable presumption relating to, written reports from a forensic toxicologist or forensic chemist, without the necessity of their appearance in court, so long as the report complied with certain requirements. After Stephen Hairston was indicted on several criminal offenses, including serious drug offenses, he served a written demand on the State, which, by the unambiguous terms of the statute, required the presence at trial of, among other individuals, the officer who seized and packaged the substances that formed the basis of Hairston’s drug offenses. Upon the State’s pretrial motion in limine, however, the Superior Court, believing that the seizing and packaging officer was unavailable, relieved the State of its obligation to produce him and permitted another officer who was present at the scene of Hairston’s apprehension to appear in the seizing and packaging officer’s stead. The Superior Court’s ruling, according to Hairston, erroneously relieved the State of a mandatory statutory duty and violated Hairston’s rights under the Confrontation Clause of the Sixth Amendment of the United States Constitution. The Delaware Supreme Court held the Superior Court’s interpretation of the statute in question was erroneous as a matter of law and that, absent the appearance of the witness identified in Hairston’s demand, it was error for the court to admit the forensic chemist’s report and testimony. Judgment was reversed and the matter remanded for further proceedings. View "Hairston v. Delaware" on Justia Law

In 2011, Appellants Eric Monzo and Dana Spring Monzo purchased a homeowners insurance policy issued by Appellee Nationwide Property & Casualty Co. (“Nationwide”). The policy contained standard exclusions for water damage and earth movement, along with optional water backup coverage. In July 2017, a heavy thunderstorm destroyed a pedestrian bridge and retaining wall located at the Monzos’ residence. A pair of engineering reports prepared after the storm indicated that a combination of water backups from drainage systems, scouring of supporting earth embankments, heavy rain, and tree debris caused the damage. The Monzos filed a claim with Nationwide, seeking coverage under the homeowners insurance policy. Nationwide denied coverage, and the Monzos sued. The court granted summary judgment for Nationwide, holding that the policy’s earth movement and water damage exclusions applied. The Monzos appealed, arguing the Superior Court erred by granting summary judgment too early in the discovery process, misinterpreting the policy, and denying a motion for post-judgment relief. Having reviewed the briefs and record on appeal, the Delaware Supreme Court: (1) affirmed the Superior Court’s holding that Nationwide was entitled to summary judgment regarding the collapsed bridge; (2) reversed the Superior Court’s holding that Nationwide was entitled to summary judgment regarding the retaining wall; and (3) affirmed the Superior Court’s denial of the Monzos’ post-judgment motion. View "Monzo v. Nationwide Property & Casualty Insurance Co." on Justia Law

In 2014, appellant and cross-appellee LCT Capital, LLC (“LCT”) helped appellee and cross-appellants NGL Energy Partners, LP and NGL Energy Holdings LLC (collectively, “NGL”) acquire TransMontaigne, a refined petroleum products distributor. LCT played an "unusually" valuable role in the transaction. The transaction generated $500 million in value for NGL, more than double the $200 million price that NGL paid to acquire TransMontaigne. NGL’s CEO Mike Krimbill represented on several occasions that LCT would receive an unusually large investment banking fee, but the parties failed to reach an agreement on all of the material terms. After negotiations broke down completely, LCT filed suit seeking compensation for its work under several theories, including quantum meruit and common law fraud. At trial, LCT presented a unitary theory of damages that focused on the value of the services that it provided, measured by the fee that Krimbill proposed for LCT’s work. Nonetheless, the jury verdict sheet had two separate lines for damages awards, one for the quantum meruit claim and another for the fraud claim. The jury found NGL liable for both counts, awarded LCT an amount of quantum meruit damages equal to a standard investment banking fee, and awarded LCT a much larger amount of fraud damages approximately equal to the unusually large fee that Krimbill proposed. Following post-trial briefing, the superior court set aside the jury’s awards and ordered a new trial on damages. LCT and NGL both filed interlocutory appeals of the superior court’s order. On appeal, LCT argued that benefit-of-the-bargain damages were available without an enforceable contract. On cross-appeal, NGL argued the superior court erred by ordering a new trial on damages because the jury’s quantum meruit award fully compensated LCT for its harm. NGL also argued it was entitled to judgment as a matter of law on the fraud claim. Finally, NGL argued the superior court provided the jury with erroneous fraudulent misrepresentation jury instructions. After review, the Delaware Supreme Court found LCT was not entitled to benefit-of-the-bargain damages and that the Superior Court did not abuse its discretion by ordering a new trial on quantum meruit damages. Nonetheless, the Supreme Court also held the superior court abused its discretion by ordering a new trial on fraud damages because LCT did not assert any independent damages to support its fraud claim. Accordingly, the Court affirmed in part and reversed in part the superior court’s judgment. View "LCT Capital, LLC v. NGL Energy Partners LP" on Justia Law