Justia Delaware Supreme Court Opinion Summaries

Plaintiff-appellant Eldon Klaassen appealed a Court of Chancery judgment which held that Klaassen was not the de jure chief executive officer of Allegro Development Corporation. Klaassen claimed that the remaining Allegro directors, by removing him as CEO, violated an equitable notice requirement and also improperly employed deceptive tactics. After a trial and without addressing its merits, the Court of Chancery held that the claim was barred under laches and acquiescence. Upon review of the matter, the Supreme Court affirmed the Court of Chancery: to the extent that Klaassen’s claim was cognizable, it was equitable in nature. Furthermore, the Court concluded that the Court of Chancery properly found that Klaassen acquiesced in his removal as CEO, and was therefore barred from challenging removal. View "Klaassen v. Allegro Development Corporation, et al." on Justia Law

The issue before the Supreme Court in this matter centered on a Court of Chancery decision arising from a 2011 acquisition by MacAndrews & Forbes Holdings, Inc. (M&F), a 43% stockholder in M&F Worldwide Corp (MFW), of the remaining common stock of MFW. M&F’s proposal to take MFW private was made contingent upon two procedural conditions. Appellants initially sought to enjoin the transaction. They withdrew their request for injunctive relief after taking expedited discovery, including several depositions. Appellants then sought post-closing relief against M&F, Ronald Perelman, and MFW’s directors for breach of fiduciary duty. Defendants then moved for summary judgment, which the Court of Chancery granted. Appellants raised two arguments on appeal: (1) the Court of Chancery erred in concluding that no material disputed facts existed regarding the conditions precedent to business judgment review; and (2) the Court of Chancery erred, as a matter of law, in holding that the business judgment standard applied to controller freeze-out mergers where the controller’s proposal is conditioned on both Special Committee approval and a favorable majority-of-the-minority vote.The Supreme Court concluded Defendants’ motion for summary judgment was properly granted on all of those issues. The Court determined that the business judgment rule standard of review applied to this controlling stockholder buyout. View "Kahn, et al v. M&F Worldwide Corp., et al." on Justia Law

A group of Texas plaintiffs alleged that a corporation exposed two employees to chemicals that caused two of the employees' children to suffer from birth defects. The Superior Court judge excluded expert testimony as irrelevant under Delaware law because it would have been insufficient as a matter of Texas law. The judge did not reach the testimony's reliability under Delaware law. Because the plaintiffs waived their argument that California or Delaware substantive law applied, the Supreme Court affirmed the Superior Court judge's ruling that Texas substantive law applies. But before the Court could address whether a judge may consider substantive sufficiency when analyzing procedural admissibility, the case was remanded for the Superior Court judge to determine in the first instance whether the testimony at issue is excludable on reliability grounds.View "Tumlinson, et al. v. Advanced Micro Devices, Inc." on Justia Law

Appellant John Nichols appealed a final Superior Court judgment affirming the order of the State Coastal Zone Industrial Board granting motions to dismiss filed by appellees Diamond State Generation Partners LLC and the Delaware Department of Natural Resources and Environmental Control in response to Nichols' appeal of the grant of a Coastal Zone industrial permit application. Nichols raised two claims on appeal: (1) the Board's vote on whether Nichols had standing to pursue the appeal failed due to the lack of a five-vote majority; and (2) that he possessed standing under the "any person aggrieved" standard of title 7, section 7007(b) of the Delaware Code, or, in the alternative, as a matter of common law. Upon review, the Supreme Court concluded both of Nichols' arguments lacked merit and therefore affirmed the Superior Court.View "Nichols v. State Coastal Zone Industrial Control Board, et al." on Justia Law

Employee-appellant, Gary Andreason appealed a Superior Court judgment affirming two Industrial Accident Board decisions. The first decision awarded compensation to Andreason for his work-related knee and right shoulder injuries, but denied compensation for a separate and unrelated lower back injury. The second decision denied Andreason's reargument motion challenging the Board's denial of compensation for his lower back injury. Andreason argued on appeal to the Supreme Court: (1) the Board erred as a matter of law when it determined that there was no implied agreement to compensate him for his lower back injury; (2) that title 19, section 2322(h) does not apply when compensation is paid as the result of a unilateral mistake. The Court concluded all of Andreason's arguments were without merit. View "Andreason v. Royal Pest Control" on Justia Law

In a medical malpractice action, the issue before the Supreme Court centered on whether the Superior Court erred by denying appellants' motion for judgment as a matter of law, and by excluding certain evidence. Dr. Jennifer Barlow performed a Caesarean section on Laura Cooney-Koss to deliver her baby. There were no apparent complications from the delivery, and Laura was discharged from the hospital three days later. A month later, Laura experienced heavy vaginal bleeding, and she returned to the hospital. In an attempt to slow or stop her bleeding, a hospital physician determined that Laura would need a dilation and evacuation (D&E) procedure. Dr. A. Diane McCracken performed the D&E; further attempts to stop the bleeding were unsuccessful. McCracken decided to perform a hysterectomy, believing that Laura would die otherwise. The doctor removed Laura's uterus, and Laura eventually stopped bleeding. Laura and her husband, Jerome Koss, filed a complaint against McCracken, Barlow, their employer, All About Women of Christiana Care, Inc., and Christiana Care Health Services, Inc., alleging that McCracken negligently failed to undertake an appropriate number of conservative treatment options to stop Laura's bleeding before performing the hysterectomy, which was unnecessary. After trial, the jury returned a verdict in favor of the Kosses. The Superior Court denied McCracken's motions for judgment as a matter of law or for a new trial. Upon review of the Koss' arguments on appeal, the Supreme Court concluded that the trial court correctly determined that appellees' medical expert evidence supported a verdict in their favor. Thus, its denial of the motion for judgment as a matter of law is affirmed. The trial court's evidentiary rulings, however, constituted an abuse of discretion requiring a new trial. View "Cooney-Koss v. Barlow" on Justia Law

Plaintiff-appellant RBC Capital Markets, LLC (RBC) appealed a Superior Court judgment dismissing its claims against the defendant-appellees U.S. Education Loan Trust IV, LLC and Education Loan Trust IV. RBC sued the Defendants in the Court of Chancery in 2011, alleging that Defendants had been paying excessive fees from the Trust. The court dismissed the Chancery action as barred by the Trust Indenture’s "no-action" clause. Then in 2012, RBC filed this case, claiming that the Defendants had unlawfully failed to pay interest owed to RBC under the Issuer notes that RBC held. The Superior Court dismissed, finding: (1) the complaint failed to state a claim upon which relief can be granted; and (2) that the earlier Court of Chancery judgment of dismissal precluded RBC’s claim as res judicata. Upon review, the Supreme Court concluded the Superior Court erred in dismissing the case. The Court held that RBC’s complaint satisfied Delaware’s "reasonable conceivability" pleading standard, that the claim was not barred by the Trust Indenture’s no-action clause, and that on the current record it could not be determined as a matter of law that RBC’s Superior Court claim was precluded as res judicata. View "RBC Capital Markets, LLC, et al. v. Education Loan Trust IV, et al." on Justia Law

This case was one of thirty-two cases filed against defendant-appellee E.I. DuPont de Demours and Company, Inc. (DuPont) by Argentine nationals who claimed they were exposed to asbestos while working in textile plants in Argentina. Plaintiff-appellant Maria Elena Martinez, widow of an Argentine plant worker, alleged her husband suffered injuries from the asbestos exposure. The Superior Court dismissed plaintiff's complaint for inadequate pleading, failing to state a claim, failing to join necessary parties, and for forum non conveniens. Plaintiff appealed to the Delaware Supreme Court, arguing the Superior Court erred in its ruling. Finding no error, the Supreme Court affirmed the Superior Court. View "Martinez, et al. v. E.I. duPont de Nemours & Company, Inc." on Justia Law

Defendant Ramazn Sahin appealed the denial of his application for post-conviction relief. He claimed he received ineffective assistance of counsel at trial. Finding no merit to defendant's claims, the Supreme Court affirmed the denial. View "Sahin v. Delaware" on Justia Law

A plaintiff who was injured in an accident sought PIP benefits from an insurance carrier. The Superior Court applied Delaware's current three-part test and analyzed: (1) "whether the vehicle was an 'active accessory' in causing the injury," (2) "whether there was an act of independent significance that broke the causal link between use of the vehicle and the injuries inflicted," and (3) "whether the vehicle was used for transportation purposes." After concluding that the insured vehicle was not used for transportation purposes, the court granted the insurance carrier's motion for summary judgment. Upon reexamination of the statutory framework for PIP coverage, the Supreme Court concluded that the test's "transportation purposes" element should have been rejected. Therefore, the Court reversed the Superior Court judgment and remanded the case for further proceedings.View "Kelty v. State Farm Mutual Automobile Insurance Co." on Justia Law