Justia Delaware Supreme Court Opinion Summaries

The issue on appeal before the Supreme Court in this case was the denial of a postconviction relief motion. Specifically, the issue was whether defense counsel were ineffective during a defendant's first-degree murder trial. Upon review, the Court held that the attorneys' alleged failure to consult with a forensic pathologist or toxicologist, to present more evidence regarding the victim's dominant hand, to investigate ballistics issues, appeal certain issues, and to object to the dismissal of jurors who indicated that they could not impose the death penalty did not prejudice the defendant during his trial's guilt phase. During the penalty phase, however, the postconviction hearing judge failed to reweigh the aggravating evidence against the total mix of mitigating evidence in determining whether the attorneys' failure to present additional evidence during the penalty phase prejudiced the defendant. Accordingly, the Court affirmed in part, and remanded in part so that the postconviction judge could supplement his opinion for further review.View "Ploof v. Delaware" on Justia Law

Defendant-Appellant Parris Hamilton appealed his conviction on two counts of Murder First Degree, two counts of Attempted Murder First Degree, two counts of Kidnapping First Degree, one count of Burglary First Degree, and seven counts of Possession of a Firearm During the Commission of a Felony. On appeal, defendant argued: (1) that the trial court erred when it allowed a nonlegal expert witness to make a misstatement of the law and failed to give a timely and adequate curative instruction; and (2) that the State failed to prove every element of the burglary charge. Finding no merit to Hamilton's claims, the Supreme Court affirmed. View "Hamilton v. Delaware" on Justia Law

Carlyle Investment Management L.L.C. (CIM) and TC Group, L.L.C. (collectively, Plaintiffs) filed suit against defendant-appellant National Industries Group (NIG). Plaintiffs sought a declaratory judgment to enforce the terms of a forum selection clause contained in a Subscription Agreement between Carlyle Capital Corporation, Ltd. (CCC) and NIG. Specifically, they sought an injunction against NIG from proceeding with litigation that it filed against CCC in Kuwait in December, 2009. The Court of Chancery entered a Default Judgment against NIG. As part of the Default Judgment, the Court of Chancery issued an anti-suit injunction. NIG filed a Motion to Vacate the Default Judgment and to Dismiss the Complaint approximately one year later. The Court of Chancery denied the motion. NIG raised several related issues on appeal to the Supreme Court: (1) that the Court of Chancery erred in refusing to vacate the Default Judgment because the Default Judgment was void due to lack of subject matter and personal jurisdiction; (2) that the Court of Chancery's limited subject matter jurisdiction did not encompass actions for which a remedy at law is available or from which no irreparable harm could result; and (3) that the Court of Chancery erred in refusing to vacate the Default Judgment because, in so doing, the court effectively denied NIG the opportunity to litigate its claims against Carlyle. Upon review, the Supreme Court concluded that all of NIG's claims of error were all without merit, and affirmed the Court of Chancery's judgment.View "National Industries Group v. Carlyle Investment Management, L.L.C." on Justia Law

The issue before the Supreme Court in this case was whether the Court of Chancery erred in dismissing a derivative and class action complaint against the general partner and other managers of a limited partnership. The governing limited partnership agreement provided that appellees had no liability for money damages as long as they acted in good faith. The Court of Chancery dismissed the complaint because it failed to allege facts that would support a finding of bad faith. After remand, the Court of Chancery held that appellants waived their alternative claims for reformation or rescission. Upon review of the matter, the Supreme Court affirmed.View "Brinckerhoff v. Enbridge Energy Company, Inc." on Justia Law

Defendant Tyrone Guy appealed the denial of his application for postconviction relief. The issue before the Supreme Court in this case centered on how the procedural bars of Superior Court Criminal Rule 61 applied to his claims, including a claim of ineffective assistance of postconviction counsel. Defendant argued on appeal: (1) that the Superior Court erred during his trial by failing to give the "modified 'Bland'" jury instruction on accomplice testimony mandated by the Supreme Court's 2012 decision in "Brooks v. Delaware"; and (2) that his appointed counsel was ineffective in his first postconviction proceeding for failing to present ten out of eleven claims of ineffective assistance of trial counsel. Upon review, the Court concluded that defendant's claims were untimely and that his first claim was previously adjudicated. Defendant failed to meet the procedural burdens. Accordingly, the Court affirmed the Superior Court's judgment in this case, although it did so on independent and alternative grounds. View "Guy v. Delaware" on Justia Law

Petitioners-Appellants, tort claimants in lawsuits pending against Krafft-Murphy Company, Inc. in other jurisdictions, sought the appointment of a receiver to enable them lawfully to pursue those claims against the company in those other courts. The company argued argued that because it held no assets other than unexhausted liability insurance policies, Delaware law did not authorize the appointment of a receiver and that it was not necessary to appoint one. The Court of Chancery granted summary judgment in favor of the company. The Petitioners appealed. The case raised two questions of first impression in for the Delaware Court, plus a third question directly addressed by settled Delaware law: (1) does a contingent contractual right, such as an insurance policy, constitute "property"?; (2) does Delaware's statutory corporate dissolution scheme contain a generally applicable statute of limitations that time-bars claims against a dissolved corporation by third parties after the limitations period expires?; and (3) after a three year winding-up period expires, does a dissolved corporation have the power to act absent a court-appointed receiver or trustee? Upon review, the Supreme Court concluded: (1) under 8 Del. C. 279, contingent contractual rights, such as unexhausted insurance policies, constitute "property" of a dissolved corporation, so long as those rights are capable of vesting; (2) Delaware's dissolution statutes impose no generally applicable statute of limitations that would time-bar claims against a dissolved corporation by third parties; and (3) the existence of the "body corporate" continues beyond the expiration of the statutory winding-up period of 8 Del. C. sec. 278 for purposes of conducting litigation commenced before the expiration of that period. But, for litigation commenced after the expiration of that statutory period, a dissolved corporation may act only through a receiver or appointed trustee. Because the judgment of the Court of Chancery rested on legal determinations inconsistent with these holdings, the Supreme Court reversed the judgment and remanded the case for further proceedings. View "Anderson v. Krafft-Murphy Co. Inc." on Justia Law

Plaintiff-Appellants asserted various tort claims against Advanced Micro Devices, Inc. (AMD). AMD moved to exclude certain expert testimony under Delaware Rule of Evidence 702, which the Superior Court granted after determining that the evidence was not relevant. Plaintiff-Appellants appealed to the Supreme Court, which remanded the case to the Superior Court for further findings related to the expert testimony’s admissibility. On remand, the Superior Court found that the expert testimony was unreliable and therefore inadmissible. After review of that decision, the Supreme Court concluded that the Superior Court did not abuse its discretion in finding the expert testimony unreliable, and affirmed its judgment. View "Tumlinson, et al. v. Advanced Micro Devices, Inc." on Justia Law

Claimant-appellee and cross-appellant-appellant Amanda Wyatt appealed a Superior Court judgment reversing an Industrial Accident Board finding that she had a compensable, work-related injury. The employer-appellant and cross-appellee-appellee is Wyatt’s former employer, Rescare Home Care. On appeal, Wyatt argued: (1) the Superior Court erred in reversing the Board’s decision that her injury was a compensable industrial accident, since the Board’s decision was based upon substantial evidence; and (2) the Board erred in denying the medical expenses for her emergency back surgery. After careful consideration, the Supreme Court concluded the Superior Court erred in reversing the Board’s decision that the Claimant had a compensable work related injury. Furthermore, the Court concluded the Board properly determined that her back surgery was not compensable. View "Wyatt v. Rescare Home Care" on Justia Law

The issue before the Supreme Court in this case was an interlocutory appeal by the Court of Chancery of a preliminary injunction halting consummation of a stock purchase agreement under which Vivendi, S.A. would have divested itself of its controlling interest in Appellee Activision Blizzard, Inc., and an Activision stockholder. Appellees convinced the trial court that the company’s charter required that a majority of the public stockholders vote in favor of the transaction. The relevant provision applied to "any merger, business combination, or similar transaction" involving Vivendi and Activision. The trial court held that Activision's purchase of its own stock would be a business combination because significant value would be transferred to Vivendi in exchange for Activision's acquisition of a newly-formed Vivendi subsidiary that held Vivendi's Activision stock. In October 2013, the Supreme Court reversed, and this opinion set forth the basis for its decision. View "Activision Blizzard, Inc., et al. v. Hayes, et al." on Justia Law

This case involved a dispute between two developers over the payment of property assessments allegedly due under certain restrictive covenants. The plaintiff-below, The Reserves Management, LLC appealed two Superior Court rulings that granted summary judgment to defendants R.T. Properties, LLC, Mountain Range, LLC, Fountain, LLC, Waterscape, LLC, and Wind Chop, LLC. In April 2005, Reserves Development LLC, together with The Reserves Development Corporation, entered into a contract to sell seventeen lots to R.T. Properties, LLC. The Sale Agreement recited that R.T. Properties was “acquiring the Property in order to construct homes thereon for sale to the general public.” In November 2005, R.T. Properties transferred all seventeen lots to four affiliated entities—Mountain Range, LLC, Fountain, LLC, Waterscape, LLC, and Wind Chop, LLC. Three years later, the declaration of the sales contract was amended that obligated each lot owner to pay approximately $4,000 to Reserves. In September 2010, Reserves filed an action in the Superior Court against R.T. Properties to enforce the payment of the assessments allegedly due. R.T. Properties moved to dismiss the complaint, claiming that under the Sale Agreement, the payment of assessments for each lot was to be deferred until the lot was transferred to a third party homebuyer and a certificate of occupancy was issued. The Superior Court denied the motion to dismiss, but ultimately granted summary judgment in favor of R.T. Properties with respect to all claimed assessments, except for a sewer connection assessments. Upon review of the matter, the Supreme Court concluded that the trial court erred by granting summary judgment in favor of R.T. Properties on a forbearance agreement defense, because material facts were in dispute. The Court affirmed the trial court in all other respects. View "The Reserves Management Corporation, et al. v. R.T. Properties, LLC, et al." on Justia Law