Justia Delaware Supreme Court Opinion Summaries

Murad Diggs was convicted of possession of a firearm and ammunition by a person prohibited. In his direct appeal to the Delaware Supreme Court, Diggs claimed the Superior Court erred when it denied his motion to suppress the evidence seized from him - the firearm and ammunition - following an investigative detention and frisk that was, in Diggs’s view, unsupported by reasonable suspicion. More specifically, Diggs challenged the court’s conclusion that the tip upon which the police were acting came from a “citizen informant” and therefore was presumptively reliable. Diggs also contended the Superior Court’s suppression-hearing factual determinations were flawed because the court failed to draw a “lost and/or missing evidence” inference as a result of the police’s failure to collect and preserve certain evidence. Although the Supreme Court agreed, in part, with Diggs’s criticism of the Superior Court’s “citizen-informant” analysis, it disagreed with his conclusion that his seizure was not supported by sufficient reasonable suspicion. Likewise, the Court rejected Diggs’s contention that the Superior Court’s failure to draw an adverse inference against the prosecution - an inference that Diggs did not urge the court to draw at trial - was plainly erroneous. Hence, the Court affirmed the Superior Court judgment. View "Diggs v. Delaware" on Justia Law

Appellant Laura Allen appealed a Family Court Ancillary Order determining the division of property following her divorce from Appellee Charlene Scott. Allen claimed the trial court abused its discretion in designating funds used to purchase real property in Colorado as “marital” because the parties’ Ancillary Pretrial Stipulation described the funds as “premarital.” Allen further contended the Family Court abused its discretion in dividing certain pieces of marital property in the marital estate 60/40 in Scott’s favor contending that the court’s decision was not based on a logical or orderly process and was tainted by the court’s error on the first issue. After review, the Delaware Supreme Court held: (1) because both parties stated in the Ancillary Pretrial Stipulation that the funds used to purchase the Colorado property were premarital in character, and because neither party moved to amend the stipulation to revise that characterization until after the evidentiary record had closed, there was no triable issue on that question; and (2) there was no abuse of discretion in the Family Court’s distribution of the remaining marital property. Judgment was reversed and the matter remanded for consideration of Scott’s alternative contention that the down payment for the Colorado property was a gift unto the marriage. The Family Court retains the discretion to adjust that distribution to the extent its decision on remand regarding the Colorado down payment funds affects the other 11 Del. C. 1315 factors. View "Allen v. Scott" on Justia Law

Appellant Kili Mayfield was convicted at a bench trial for two counts of first-degree rape, four counts of second-degree rape, one count of first-degree kidnapping, one count of strangulation, and one counts of third-degree assault. In pre-trial proceedings, he was initially represented by counsel from the Public Defender Division of the Office of Defense Services. Several months before trial, Mayfield filed a motion indicating he wished to waive his right to counsel and proceed pro se. The Superior Court held a hearing and granted the motion. On appeal, Mayfield did not dispute that the Superior Court did not err in granting his motion to waive counsel and proceed pro se. At a conference held the day before his scheduled trial date, however, Mayfield informed the trial judge for the first time that he had decided that representing himself was not in his best interest. He requested time to retain private counsel. In the alternative, he requested that the Public Defender’s Office be reappointed to represent him at trial. After fully considering Mayfield’s requests, the judge determined that trial should go forward as scheduled the next day, that a continuance should be denied, and that his request for counsel should, therefore, be denied. The judge noted that Mayfield had been "vigorous" in his own defense, his filings showing he had "gone through all the discovery materials and prepared himself." The court concluded, “Mayfield’s request and the basis for his request are not outweighed by the other prejudice that would be visited by a continuance.” Mayfield’s bench trial began as scheduled the next day and resulted in the aforementioned convictions. The Delaware Supreme Court affirmed, finding the Superior Court acted within its discretion when it denied Mayfield’s request for counsel and a continuance. View "Mayfield v. Delaware" on Justia Law

The two equal stockholders of UIP Companies, Inc. were deadlocked and could not elect new directors. One of the stockholders, Marion Coster, filed suit in the Court of Chancery and requested appointment of a custodian for UIP. In response, the three-person UIP board of directors — composed of the other equal stockholder and board chairman, Steven Schwat, and the two other directors aligned with him— voted to issue a one-third interest in UIP stock to their fellow director, Peter Bonnell, who was also a friend of Schwat and long-time UIP employee (the “Stock Sale”). Coster filed a second action in the Court of Chancery, claiming that the board breached its fiduciary duties by approving the Stock Sale. She asked the court to cancel the Stock Sale. After consolidating the two actions, the Court of Chancery found what was apparent given the timing of the Stock Sale: the conflicted UIP board issued stock to Bonnell to dilute Coster’s UIP interest below 50%, break the stockholder deadlock for electing directors, and end the Custodian Action. Ultimately, however, the court decided not to cancel the Stock Sale. The Delaware Supreme Court reversed the Court of Chancery on the conclusive effect of its entire fairness review and remanded for the court to consider the board’s motivations and purpose for the Stock Sale. "If the board approved the Stock Sale for inequitable reasons, the Court of Chancery should have cancelled the Stock Sale. And if the board, acting in good faith, approved the Stock Sale for the 'primary purpose of thwarting' Coster’s vote to elect directors or reduce her leverage as an equal stockholder, it must 'demonstrat[e] a compelling justification for such action' to withstand judicial scrutiny." View "Coster v. UIP Companies, Inc." on Justia Law

Appellant, Concerned Citizens of the Estates of Fairway Village, was an unincorporated association composed of people who own property in Fairway Village (the “Community”), a planned residential community located in Ocean View, Delaware. Appellants Julius and Peggy Solomon, Edward Leary, Kenneth and Denise Smith, and Terry and Carmela Thornes (collectively, the “Homeowners”) owned properties in the Community and were members of Concerned Citizens of the Estates of Fairway Village. Appellee Fairway Cap, LLC was the Community's developer. Demand for vacant townhomes in the Community was weaker than the developers expected. In the winter of 2016, Fairway Cap, LLC hired a real estate consultant who recommended converting unsold townhome lots into a rental community. Fairway Cap, LLC accepted the advice, secured funding, and began working on the rental properties. Appellee Fairway Village Construction, Inc. was an entity involved in the construction. The Homeowners discovered the plan after seeing an advertisement for “The Reserve at Fairway Village,” a forthcoming rental community. The Homeowners raised various objections to the rental community, including that the proposed units did not conform with existing dwellings and would lower property values. The Town of Ocean View and Fairway Cap, LLC rejected all the objections, concluding that the planned construction complied with the housing code and was allowed under the Community’s governing documents. This appeal presented two questions for the Delaware Supreme Court's review: (1) whether the Court of Chancery erred by holding that the Community’s governing documents allowed the developer to build rental properties; and (2) whether the Court of Chancery erred by awarding damages for a wrongful injunction after releasing the bond posted with the court. Finding no reversible error, the Supreme Court affirmed the Court of Chancery's judgment. View "Concerned Citizens of the Estates of Fairway Village v. Fairway Cap" on Justia Law

In January 2006, two armed assailants fatally shot Tameka Giles in the back after a botched robbery attempt while she was walking with her husband. After multiple police interrogations in the two years following the murder, Ronald Harris repeatedly told police he knew nothing about the crime and had not been involved. But on the eve of trial and after jury selection, Harris was offered and accepted a plea deal in exchange for testimony against Mark Purnell. Purnell’s court-appointed trial attorney was the same advocate who represented Dawan Harris in a weapons prosecution earlier in the murder investigation. The trial judge did not permit him to withdraw when he brought the conflict to the State’s and court’s attention. Trial counsel failed to investigate evidentiary leads implicating Dawan Harris, did not call him as a witness, and failed to present even then-known or obvious evidence and argument to the jury that would have inculpated his former client. The jury convicted Purnell of Second Degree Murder and all other charges after more than a day of deliberation, and he was sentenced to forty-five years of unsuspended Level V incarceration. In 2009, based on narrow issues presented to the Delaware Supreme Court (which did not include the conflict), his conviction and sentence were upheld. Following the denial of his direct appeal, Purnell filed a pro se Rule 61 motion raising ten grounds for relief, of which the first was an objection to his trial counsel’s conflict of interest. Postconviction counsel filed an amended motion asserting only three grounds, and did not include the conflict claim. The Superior Court denied Purnell’s motion and, again without having the conflict brought to the Supreme Court's attention, the Supreme Court affirmed that denial in 2014. Because postconviction counsel died a few weeks prior to oral argument before the Supreme Court in 2014, it was unknown why the conflict issue was not included in the amended motion. Due to that omission, the conflict claim went before the Supreme Court as one of Purnell’s grounds in an untimely, successive Rule 61 motion. "Ordinarily, having clarified the standards for newness and persuasiveness necessary for relief, we would remand the matter to the Superior Court for an evidentiary hearing and a decision guided by those rulings. But because Purnell has spent more than fourteen years in prison for murder based on a manifestly unfair trial and conviction, and based on his new evidence, viewed as a part of the entire evidentiary record, we are convinced that in this extraordinary case remand for an evidentiary hearing would serve no useful purpose. Instead, we reverse and remand for a new trial." View "Purnell v. Delaware" on Justia Law

The Delaware Department of Finance served an administrative subpoena on AT&T Inc. to produce records relating to a financial audit. AT&T refused to produce all of the requested records. The Department responded by filing a complaint in the Court of Chancery to enforce the subpoena. AT&T defended by claiming, among other things, that the subpoena exceeded the Department’s authority and was overbroad. The Court of Chancery held that, although the Department validly issued the subpoena, AT&T “met its burden to show that the scope of the subpoena is so expansive that enforcement would constitute an abuse” of the court’s process. The court noted that it had offered the Department the opportunity to supplement the record to explain why the subpoena should be enforced as written, but the Department declined the invitation. The court therefore quashed the subpoena in its entirety. The Department appealed the court’s decision. The Delaware Supreme Court affirmed the Court of Chancery’s judgment. Recognizing that the procedural and substantive aspects of administrative subpoena enforcement were issues of first impression in Delaware, the Supreme Court adopted the procedures and substance followed by the federal courts in administrative subpoena enforcement proceedings. Because the Court announced new procedural and substantive standards governing administrative subpoenas, it allowed the Department to serve a new subpoena on AT&T that complied with the guidance in the Court’s opinion. View "Delaware Dept of Finance v. AT&T Inc." on Justia Law

Following a bench trial, A.J. McMullen was convicted of Murder in the First Degree and Possession of a Firearm During the Commission of a Felony (“PFDCF”). McMullen appealed his convictions, arguing the superior court improperly admitted cumulative statements from witnesses pursuant to 11 Del. C. 3507, and that the superior court’s verdict was supported by insufficient evidence identifying McMullen as the shooter who took the victim’s life. After review of the record, the Delaware Supreme Court found no merit in either of McMullen’s claims of error. Accordingly, the Court affirmed the superior court’s decisions and judgment of conviction. View "McMullen v. Delaware" on Justia Law

GXP Capital, LLC filed two lawsuits against defendants in different federal courts. GXP alleged defendants violated non-disclosure agreements by using confidential information to buy key assets at bargain prices from GXP’s parent company. Those cases were dismissed for lack of personal and subject matter jurisdiction. GXP then filed a third suit in Delaware Superior Court, which stayed the case on forum non conveniens grounds to allow GXP to file the same case in California state court - a forum the court decided had a greater connection to the dispute and was more convenient for the parties. On appeal GXP argued: (1) the Superior Court did not apply the correct forum non conveniens analysis when Delaware was not the first-filed action, the prior-filed lawsuits have been dismissed, and no litigation was pending in another forum; and (2) defendants waived any inconvenience objections in Delaware under the forum selection clause in their non-disclosure agreements. The Delaware Supreme Court affirmed, finding the trial court properly exercised its discretion in this case’s procedural posture to stay the Delaware case in lieu of dismissal when another forum with jurisdiction existed and that forum was the more convenient forum to resolve the dispute. “And certain of the defendants’ consent to non-exclusive jurisdiction in California did not waive their right to object to venue in other jurisdictions, including Delaware.” View "GXP Capital v. Argonaut Manufacturing Services, et al" on Justia Law

Appeals consolidated for the Delaware Supreme Court’s review centered on the Rent Increase Justification Act, which governed rent increases in manufactured home communities. The Rehoboth Bay Manufactured Home Community (the “Community”) was owned/managed by Hometown Rehoboth Bay, LLC (“Hometown”). The Appellant in Case No. 139, 2020 was Rehoboth Bay Homeowners’ Association (the “HOA”), the homeowners’ association. The Appellants in Case No. 296, 2020 were two individual tenants, John Iacona and Robert Weymouth. Hometown sought to raise the rents in both cases: in case No. 296, 2020, rents would be raised an amount in excess of the Consumer Price Index for this area (the “CPI-U”), for the calendar year 2017; in case No. 139, 2020, for the calendar year 2018. Under the Act, proposed rent increases that exceed the CPI-U must be justified by certain factors. Separate arbitrators in both cases found that a Bulkhead Stabilization project performed by Hometown in phases over more than one year was a capital improvement or rehabilitation work, which, along with other capital improvements and other expenses, justified rent increases in excess of the CPI-U in both years. The Appellants claimed the Superior Court erred by affirming the arbitrators’ decisions that the Bulkhead Stabilization project was a “capital improvement or rehabilitation work” and not “ordinary repair, replacement, and maintenance.” They also claimed the Superior Court should have ruled that the Act did not permit Hometown to incorporate the capital improvement component of the rent increases into each lot’s base rent so as to carry those increases forward into ensuing years. The Delaware Supreme Court concluded the Superior Court’s rulings on the Bulkhead Stabilization project as a capital improvement or rehabilitation work was correct, however, the Act did not permit Hometown to incorporate the capital improvement component of the 2017 and 2018 rent increases into a lot’s base rent for succeeding years after recovering that lot’s full, proportionate share of those costs in those years. Therefore, the Superior Court’s judgment was affirmed in part, reversed in part, and the cases remanded for further proceedings. View "Rehoboth Bay Homeowners' Assoc, et al. v. Hometown Rehoboth Bay" on Justia Law