Justia Delaware Supreme Court Opinion Summaries

At issue in this appeal was whether five beneficiaries of a Delaware trust could recover on their $88 million judgment against the individual trust established by a brother to one beneficiary and uncle to the rest. The judgment arose from the trustee's alleged bad faith and willful misconduct in handling the estate. A Master held that a spendthrift clause in the trustee's Trust precluded the beneficiaries from obtaining relief against the Trustee's interest. The Court of Chancery found that the beneficiaries' notice of exceptions to the Master's final report on the spendthrift issue was late, and that they forfeited their right to challenge the ruling. The beneficiaries appealed, arguing the Court of Chancery erred by not considering the merits to the beneficiaries' exceptions to the Master's ruling on the spendthrift issue. View "Mennen. v. Fiduciary Trust International of Delaware" on Justia Law

Defendant-appellant Joel Stevenson appealed convictions for first- and second-degree unlawful sexual contact and two counts of sex offender unlawful sexual conduct with a child. On appeal of those convictions, Stevenson argued that the trial court abused its discretion in admitting certain out-of-court statements of three child witnesses rebutting defendant's allegation that the State improperly influenced the witnesses' testimony. After review of the record, the Delaware found no merit to defendant's arguments and affirmed his convictions. View "Stevenson v. Delaware" on Justia Law

This was a case between the owner of a manufactured homes community, Bon Ayre Land, LLC (Landowner), and an association that represented the affected homeowners, Bon Ayre Community Association (HOA) about what Delaware law required the Landowner to show to increase rent above inflation. Their dispute arose under Chapter 70 of Title 25 of the Delaware Code, commonly known as the "Rent Justification Act." To raise rent by more than inflation, the Act set out three conditions a landowner had to satisfy. One condition required the owner show that the proposed increase was directly related to operating, maintaining or improving the manufactured home community, and justified by one or more factors listed under subsection (c). The one factor at issue here was market rent: that rent which would result from market forces absent an unequal bargaining position between the community owner and the home owners. Among its many arguments, the Landowner argued that the Superior Court erred in giving effect to the word "and," and that the Landowner ought to have been allowed to justify a rent increase based on market rent alone. The Landowner admitted that it failed to present any evidence of its proposed rent increases being directly related to operating, maintaining or improving the community. But, the Landowner argued that the Act could not be read sensibly as it was plainly written and that the term "and" in section 7042(a)(2) should have been read as "or." Contrary to the Landowner's argument, the Delaware Supreme Court found nothing "absurd" about the use of "and" in joining section 7042's three conditions. "Consistent with proper principles of interpretation, the Superior Court gave effect to the clear language of the Act and gave it an interpretation that is consistent with the Act's stated purpose." Because the Landowner concededly made no showing that its proposed rental increase was directly related to operating, maintaining or improving the community, the Superior Court properly reversed the arbitrator's ruling that the Landowner could raise rents in excess of CPI-U. View "Bon Ayre Land, LLC v. Bon Ayre Community Association" on Justia Law

Viking Pump, Inc. and Warren Pumps, LLC sought to recover under insurance policies issued to a third company, Houdaille Industries, Inc. In the 1980's, Viking and Warren acquired pump manufacturing businesses from Houdaille. As a result, Viking and Warren were confronted with potential liability flowing from personal injury claims made by plaintiffs alleging damages in connection with asbestos exposure claims dating back to when the pump manufacturing businesses were owned by Houdaille. Houdaille had purchased occurrence-based primary and umbrella insurance from Liberty Mutual Insurance Company. Above the Liberty umbrella layer, Houdaille purchased layers of excess insurance. In total, Houdaille purchased 35 excess policies through 20 different carriers (the "Excess Policies"). Viking and Warren sought to fund the liabilities arising from the Houdaille-Era Claims using the comprehensive insurance program originally purchased by Houdaille. The insurance companies that issued the Excess Policies (the "Excess Insurers") contended that Viking and Warren were not entitled to use the Excess Policies to respond to the claims. The Excess Insurers also disputed the extent of any coverage available, particularly with respect to defense costs. The Supreme Court held, after careful consideration of the policies at issue: (1) the Superior Court correctly held that the 1980-1985 Liberty Primary Policies were exhausted; (2) the Superior Court held that 33 of the Excess Policies at issue in this appeal provided coverage to Viking and Warren for their defense costs, with many payments contingent on insurer consent; (3) the Court of Chancery correctly held that there were valid assignments of insurance rights to Warren and Viking under the Excess Policies; (4) the Superior Court was affirmed in part and reversed in part with respect to its determination of the Excess Policies' coverage for defense costs; and (5) the Superior Court erred with respect to the trigger of coverage under the Excess Policies. View "In Re Viking Pump, Inc. and Warren Pumps, LLC Insurance Appeals" on Justia Law

On June 24, 2013, a Grand Jury indicted appellant Kahlil Lewis on charges of second degree murder, two counts of possession of a firearm during the commission of a felony, first degree reckless endangering, and possession of a firearm by a person prohibited. In December, the State filed an information charging Lewis with an additional crime, possession of a firearm by a person prohibited - negligently causing death. A few days later, the Grand Jury re-indicted Lewis. The re-indictment repeated the charges in the original indictment, and added the new charge under 11 Del. C. 1448(e)(2). In this appeal, the issue presented for the Supreme Court's review concerned whether the Grand Jury properly indicted appellee for a crime under a criminal statute mistakenly repealed by the General Assembly. Appellant argued the Grand Jury improperly indicted him for an additional crime as part of a renewed indictment incorporating earlier charges because the General Assembly repealed the statute covering the added crime before he was re-indicted. The General Assembly discovered the mistake but did not re-enact the repealed subsection until after the re-indictment. The Delaware Supreme Court held, after review and consistent with decisions interpreting a similar federal saving statute, that Delaware’s criminal saving statute permitted the State to prosecute crimes under a repealed criminal statute when the crimes were committed before the statute’s repeal. Because Lewis committed the crime before the statute was repealed, he was still subject to prosecution under the later repealed statute. Lewis also raised other arguments on appeal, but the Court found no merit to those arguments and affirmed Lewis' convictions. View "Lewis v. Delaware" on Justia Law

Husband-appellant Alexander Jones appealed a Family Court order that entered the parties’ stipulation on property division, awarded wife-appellee Adriana Jones alimony, and ordered Husband to pay Wife an additional monthly amount for unpaid interim alimony. Husband also appealed another Family Court order denying the parties’ motions for reargument. After review of the arguments made on appeal, the Supreme Court found no merit to most of Husband’s contentions, but remanded on his claims regarding Wife’s medical and health insurance expenses. View "Jones v. Jones" on Justia Law

Delaware charged defendant Benjamin Rauf with one count of First Degree Intentional Murder, one count of First Degree Felony Murder, Possession of a Firearm During those Felonies, and First Degree Robbery. The State expressed its intention to seek the death penalty if Rauf was convicted on either of the First Degree Murder counts. In January 2016, the United States Supreme Court held in "Hurst v. Florida" that Florida‘s capital sentencing scheme was unconstitutional. In light of the "Hurst" decision, the trial court in this matter certified five questions of law to the Supreme Court, asking the Supreme Court to address the constitutionality of Delaware's state's death penalty statute; the Superior Court believed that Hurst "reflected an evolution of the law that raised serious questions about the continuing validity of Delaware‘s death penalty statute." After review, the Court concluded that Delaware's death penalty statute conflicted with the Sixth Amendment, and prior cases on the constitutionality of Delaware's capital sentencing scheme were overruled to the extent they were inconsistent with this opinion. View "Rauf v. Delaware" on Justia Law

Tracey West was pulled over by police officer Thomas Gaul when her car was drifting back and forth in the lane. The officer saw the car swerve sharply to avoid hitting a concrete island. When he approached the car, Gaul smelled alcohol. West "staggered out of the car" and failed field sobriety tests. She was charged with an illegal lane change and driving under the influence. Before trial, West moved to suppress the evidence that she was intoxicated. She claimed that Officer Gaul lacked the reasonable suspicion required by the Fourth Amendment to make an investigative stop of her car. Thus, any evidence of her intoxication gathered after the stop should have been suppressed. After hearing testimony from the officer and reviewing the video from the police car camera, the trial judge dismissed the lane change charge, but denied the motion to suppress. The State then introduced at trial the evidence of her intoxicated state, and a jury convicted West of drunk driving. West appealed her conviction to the Superior Court, which affirmed the trial court’s ruling on the community caretaker doctrine, and also found that Officer Gaul had reasonable suspicion to stop West for driving while intoxicated. West then appealed to the Delaware Supreme Court, arguing the community caretaker doctrine did not apply, and Officer Gaul lacked reasonable suspicion as required by the Fourth Amendment for an investigatory stop of her car. Finding no reversible error, the Supreme Court affirmed. View "West v. Delaware" on Justia Law

Defendant-appellee Isaiah McCoy was a pretrial detainee awaiting trial on capital murder and related charges. In May 2010, McCoy was arrested and charged with the murder of James Munford in Dover. He was convicted and sentenced to death at his first trial in June 2012. In January 2015, the Supreme Court reversed his conviction and remanded the case for a new trial. Using a points-based, objective risk assessment tool, the Department of Correction classified him to be held in the maximum security Secured Housing Unit (“SHU”) at James T. Vaughn Correctional Center (“JTVCC”). McCoy filed a motion in the criminal case requesting that he be transferred from the SHU to the prison’s general population on the ground that detention at the SHU was interfering with his Sixth Amendment right to assistance of counsel. The Superior Court, over the State’s objection, granted McCoy’s motion, and McCoy was, in fact, transferred to general population. While McCoy had some complaints about the adequacy of the attorney visitation rooms in the SHU and access to the library, the Superior Court based its order in significant part upon its perception of “the emotional and physical impact that prolonged, solitary placement has had on [McCoy’s] Sixth Amendment right to assistance of counsel . . . .” The Superior Court found there that it had such jurisdiction under 10 Del. C. sec. 542, 11 Del. C. sec. 6504, and several other cases, to order the transfer of a detainee from maximum security to the general population. The State renewed its jurisdictional argument in this case. After review, the Delaware Supreme Court concluded that neither the Sixth Amendment right to assistance of counsel nor the statutes and cases relied upon by the Superior Court granted it the authority to transfer a detainee from one housing unit to another in a criminal case. The order of the Superior Court was, therefore, vacated. View "Delaware v. McCoy" on Justia Law

Milton Taylor was sentenced to death in 2001. He petitioned the Delaware Supreme Court for a writ of mandamus to direct the Superior Court to docket his second motion for post-conviction relief under Superior Court Criminal Rule 61. The State conceded that the writ should be issued. After careful consideration, the Court held that the Superior Court erroneously concluded that it lacked jurisdiction to act in Taylor’s case because of a stay of execution order entered by the United States District Court for the District of Delaware. The Delaware Supreme Court issued the writ. View "Matter of Taylor" on Justia Law