Justia Delaware Supreme Court Opinion Summaries

The case involves a challenge to two Delaware voting statutes: one allowing absentee voters to request "permanent absentee" status, and the other authorizing qualified, registered voters to vote in person at least 10 days before an election. The plaintiffs, a citizen who plans to serve as an election inspector and a Delaware State Senator, argued that these statutes conflict with the Delaware Constitution's provisions governing elections and voting.The case was initially filed in the Court of Chancery, which dismissed it on jurisdictional grounds. The plaintiffs then pursued their claims in the Superior Court. The Superior Court found that the plaintiffs had standing to bring the case and ruled in their favor, declaring the challenged statutes unconstitutional.On appeal, the Supreme Court of the State of Delaware reversed the Superior Court's decision. The Supreme Court found that neither plaintiff had standing to challenge the statutes. The court held that the State Senator, who was not up for re-election until 2026, did not face an imminent or particularized harm. The court also found that the citizen, who planned to serve as an election inspector, did not have standing because his role as an inspector did not give him the authority to turn away lawful voters based on his personal belief that the challenged statutes were invalid. Finally, the court rejected the plaintiffs' claim that they had standing as registered voters, finding that their alleged injury was a generalized grievance shared by all voters, not a particularized harm. As a result of these findings, the court did not address the merits of the plaintiffs' constitutional claims. View "Albence v. Mennella" on Justia Law

The case involves Carl Fowler, an employee at Perdue, Inc., who contracted COVID-19 and sought compensation from his employer. Fowler worked at Perdue from January 2020 until late March 2020. In March 2020, Fowler developed COVID-19 symptoms and was later diagnosed with the virus. He was hospitalized for over two months and suffered severe health complications. Fowler claimed that he contracted the virus at work, specifically in the company's cafeteria, which he described as crowded and likened to a "sardine can."The Industrial Accident Board of the State of Delaware initially denied Fowler's claim, finding that he failed to present sufficient evidence that COVID-19 was a compensable occupational disease. The Superior Court affirmed this decision. Fowler then appealed to the Supreme Court of the State of Delaware.The Supreme Court affirmed the lower court's decision. The court found that while Fowler had established that the cafeteria at Perdue presented a hazard greater than that attending employment in general, he failed to show that the cafeteria was a hazard "distinct from" that attending employment in general. The court concluded that Fowler failed to establish the necessary relationship between his work environment at Perdue and COVID-19 as a "natural incident to" that employment. Therefore, the court held that Fowler's COVID-19 infection was not an occupational disease under these circumstances. View "Fowler v. Perdue, Inc." on Justia Law

In December 2017, Antoine Terry was found dead from multiple gunshot wounds in New Castle, Delaware. The police arrested Terry’s friend, Shaheed Matthews, for the murder. In 2019, Matthews was tried for murder and possession of a firearm during the commission of a felony. The State's case relied on circumstantial evidence, including evidence from Matthews’s cellphone, witness testimony, video camera footage, and gunshot residue found on Matthews’s jacket. Matthews was convicted and sentenced to life plus three years in prison.Matthews appealed his conviction, arguing that his trial counsel was ineffective for failing to move to suppress evidence obtained from his cellphone. The Superior Court denied Matthews’s motion, concluding that Matthews had provided valid consent for the search of his cellphone and that the cellphone evidence had no bearing on the outcome of the case. Matthews appealed this decision to the Supreme Court of the State of Delaware.The Supreme Court of the State of Delaware reversed the Superior Court's decision. The court found that Matthews did not provide valid consent for the search of his cellphone and that the warrant obtained by police to search Matthews’s cellphone was an unconstitutional general warrant. The court also found that the cellphone evidence was material and significant to the State's case. Therefore, the court concluded that Matthews’s trial counsel’s failure to move to suppress the evidence obtained from his cellphone constituted deficient performance and prejudiced Matthews. The court vacated Matthews’s convictions and remanded the case to the Superior Court for a new trial. View "Matthews v. State" on Justia Law

The case involves a plaintiff who was bitten by a dog at a facility operated by an animal welfare organization. The plaintiff filed a lawsuit against the organization, invoking Delaware's "dog bite statute," which imposes strict liability on a dog owner for any injury caused by the dog. The Superior Court of Delaware granted summary judgment in favor of the organization, ruling that the statute does not apply to animal welfare organizations. The court reasoned that the statute was intended to target irresponsible dog owners who keep vicious dogs as pets, not organizations like the defendant.The Superior Court's decision was based on its interpretation of the legislative intent behind the dog bite statute. The court also held that the plaintiff could not establish negligence on the part of the organization without expert testimony, as the standard of care applicable to animal shelters was outside the common knowledge of laypersons.The plaintiff appealed the decision to the Supreme Court of the State of Delaware. The Supreme Court disagreed with the lower court's interpretation of the dog bite statute. It found that the statute unambiguously imposes strict liability on any person who owns, keeps, harbors, or is the custodian of a dog, without any exception for animal welfare organizations. The court also disagreed with the lower court's requirement for expert testimony to establish negligence, ruling that the standard of care in handling a domestic animal with known vicious propensities is within the common knowledge of laypersons. The Supreme Court reversed the Superior Court's decision and remanded the case for further proceedings. View "Riad v. Brandywine Valley SPCA, Inc." on Justia Law

The case involves Ferrellgas Partners L.P. and its subsidiaries (collectively "Ferrellgas") and Zurich American Insurance Company ("Zurich"). Ferrellgas had an insurance policy with Zurich, which included a provision for the advancement of defense costs for litigation. Ferrellgas was involved in a separate lawsuit with Eddystone Rail Company, LLC ("Eddystone") over a breach of contract. Ferrellgas sought to have Zurich cover the defense costs for the Eddystone litigation under their insurance policy.In the lower court, the Superior Court of the State of Delaware, Ferrellgas filed a motion for summary judgment seeking a declaratory relief obligating Zurich to advance defense costs for the Eddystone litigation. Zurich also filed a motion for summary judgment seeking a declaration that it had no obligation to advance defense costs. The Superior Court denied Ferrellgas' motion and granted Zurich's motion, finding that the Eddystone litigation was excluded from coverage under the Zurich policy.On appeal, the Supreme Court of the State of Delaware affirmed the decision of the Superior Court. The Supreme Court found that the Eddystone litigation was a claim seeking relief for a breach of contract that occurred after the commencement of the Run-Off Coverage Period in the Zurich policy. As such, Zurich had no duty to advance defense costs for this matter due to the Run-Off Exclusion in the policy. The court also found that Ferrellgas' appeal was timely filed. View "Ferrellgas Partners, L.P. v. Zurich American Insurance Company" on Justia Law

The case revolves around Deonta Carney, who was indicted for crimes stemming from three separate incidents. In one of these incidents, Carney and an accomplice allegedly robbed a man named Angelo Flores of his dirt bikes. Although Carney did not physically hold the firearm used in the robbery, he was charged with possession of a firearm by a person prohibited due to his involvement in the crime. Initially, Carney rejected a plea offer from the State, but he changed his mind and accepted a revised plea offer on the morning of the trial when he learned that the victim had appeared to testify. However, before sentencing, Carney attempted to withdraw his guilty plea, arguing that he was "legally innocent" of the firearm possession charge because he did not physically hold the gun during the robbery.The Superior Court of the State of Delaware denied Carney's motion to withdraw his guilty plea. The court found no procedural defects in the plea colloquy and determined that Carney's plea was entered knowingly, intelligently, and voluntarily. The court also concluded that Carney had effective legal counsel throughout the proceedings and that granting the motion would prejudice the State. Regarding Carney's claim of innocence, the court found that Carney's plea colloquy statements were inconsistent with his later innocence assertion. The court also determined that there was sufficient factual basis to convict Carney of the firearms charge because he had constructive possession of the firearm during the robbery.Carney appealed to the Supreme Court of the State of Delaware, arguing that the Superior Court exceeded its discretion when it denied his motion to withdraw his guilty plea. However, the Supreme Court affirmed the Superior Court's judgment, concluding that the lower court did not exceed its discretion when it found that Carney did not present a fair and just reason to withdraw his guilty plea. The Supreme Court agreed with the lower court's assessment that Carney's claim of innocence was weak and that his involvement in the robbery was sufficient to establish constructive possession of the firearm. View "Carney v. State" on Justia Law

The case involves NGL Energy Partners LP and NGL Energy Holdings LLC (collectively, "NGL") and LCT Capital, LLC ("LCT"). NGL, entities in the energy sector, engaged LCT, a financial advisory services provider, for services related to NGL's 2014 acquisition of TransMontaigne Inc. However, the parties failed to agree on payment terms, leading LCT to file a lawsuit in 2015. The Superior Court held a jury trial in July 2018, which resulted in a $36 million verdict in LCT's favor.NGL appealed the Superior Court's decision, challenging the $36 million final judgment and a set of evidentiary rulings. LCT cross-appealed, contesting the Superior Court's methodology for computing post-judgment interest. NGL argued that the Superior Court erred by admitting evidence and arguments about the value/benefit supposedly gained by NGL in the Transaction, asserting that such evidence is prejudicial and irrelevant to a quantum meruit claim. NGL also argued that the Superior Court erred by admitting evidence of benefit-of-the-bargain or expectancy damages when assessing the quantum meruit value of LCT’s services.The Supreme Court of the State of Delaware affirmed the Superior Court’s evidentiary rulings and rejected NGL's contention that the Superior Court incorrectly allowed LCT to recover benefit-of-the bargain/expectancy damages. However, the Supreme Court disagreed with the Superior Court’s post-judgment interest determination. The Supreme Court held that prejudgment interest is part of the judgment upon which post-judgment interest accrues under Section 2301(a). Therefore, the Supreme Court reversed the Superior Court as to this issue and remanded the case to the Superior Court for entry of judgment consistent with its opinion. View "NGL Energy Partners LP v. LCT Capital, LLC" on Justia Law

The case involves BitGo Holdings, Inc. and Galaxy Digital Holdings Ltd., who entered into a merger agreement. BitGo, a technology company, was required to submit audited financial statements to Galaxy, the acquirer, by a specified date. When BitGo submitted the financial statements, Galaxy claimed they were deficient because they did not apply recently published guidance from the Securities and Exchange Commission’s staff. BitGo disagreed, but submitted a second set of financial statements. Galaxy found fault with the second submission and terminated the merger agreement. BitGo then sued Galaxy for wrongful repudiation and breach of the merger agreement.The Court of Chancery sided with Galaxy and dismissed the complaint. The court found that the financial statements submitted by BitGo did not comply with the requirements of the merger agreement, providing Galaxy with a valid basis to terminate the agreement.On appeal, the Supreme Court of Delaware reversed the decision of the Court of Chancery. The Supreme Court found that the definition of the term “Company 2021 Audited Financial Statements” in the merger agreement was ambiguous. The court concluded that both parties had proffered reasonable interpretations of the merger agreement’s definition. Therefore, the court remanded the case for the consideration of extrinsic evidence to resolve this ambiguity. View "BitGo Holdings, Inc. v. Galaxy Digital Holdings Ltd., et al." on Justia Law

The case involves a group of pension funds (plaintiffs) who filed a lawsuit against Inovalon Holdings, Inc., and its board of directors (defendants), challenging an acquisition of Inovalon by a private equity consortium led by Nordic Capital. The plaintiffs claimed that the defendants breached their fiduciary duties and unjustly enriched themselves through the transaction. They also alleged that the company's charter was violated because the transaction treated Class A and Class B stockholders unequally.In the lower court, the Court of Chancery of the State of Delaware, the defendants moved to dismiss the case. They argued that the transaction satisfied the elements of a legal framework known as MFW, which would subject the board's actions to business judgment review. The Court of Chancery granted the defendants' motions to dismiss in full.On appeal, the Supreme Court of the State of Delaware reversed the decision of the Court of Chancery. The Supreme Court found that the lower court erred in holding that the vote of the minority stockholders was adequately informed. The Supreme Court determined that the proxy statement issued to stockholders failed to adequately disclose certain conflicts of interest of the Special Committee’s advisors. Therefore, the Supreme Court concluded that the transaction did not comply with the MFW framework, and the case was remanded for further proceedings. View "City of Sarasota Firefighters' Pension Fund v. Inovalon Holdings, Inc." on Justia Law

The case revolves around a claim of professional negligence against a law firm, Margolis Edelstein, by its former client, GMG Insurance Agency. Margolis had represented GMG and one of its employees, Howard Wilson, in a non-compete dispute. After GMG failed to fully prevail on a motion for summary judgment and settlement talks broke down, GMG fired Margolis. On the eve of trial, Wilson, represented by separate counsel, filed an affidavit recanting his prior testimony and providing new testimony, which was unfavorable to GMG. GMG then sued Margolis for legal malpractice, asserting that Margolis's negligent representation led to GMG's exposure to the consequences of Wilson's pre-trial change in testimony.The Superior Court granted summary judgment in favor of Margolis, finding that Wilson's affidavit was a superseding cause that broke the causal chain linking Margolis's alleged negligence and GMG's claimed damages. GMG appealed this decision.The Supreme Court of the State of Delaware found that the Superior Court erred in its decision. The Supreme Court held that there were disputes of material fact as to whether Margolis deviated from the requisite standard of care. The court also found that the Superior Court erred by failing to address GMG's contention that, but for Margolis's alleged negligence, GMG would have prevailed on all claims in the previous litigation—a circumstance that would have effectively negated Margolis's superseding cause argument. The Supreme Court reversed the judgment of the Superior Court and remanded the case for further proceedings. View "GMG Insurance Agency v. Edelstein" on Justia Law