Justia Delaware Supreme Court Opinion Summaries

The Supreme Court of the State of Delaware examined the Adult Expungement Reform Act and the Clean Slate Act, which expanded eligibility for expungement and created an automatic expungement process for certain Delaware criminal records. The Acts are applicable to "all criminal cases brought and convictions entered in a court in this State" and limit expungement to individuals with "no prior or subsequent convictions." The three petitioners, Alex Osgood, Osama Qaiymah, and Eric Fritz, requested expungement of their criminal records. However, the Superior Court denied their requests due to their prior or subsequent misdemeanor convictions from other states.The issue the Supreme Court had to decide was whether the phrase "prior or subsequent convictions" in the Acts includes out-of-state convictions. The court ruled that "prior or subsequent convictions" refers only to Delaware convictions, not to out-of-state convictions. The court reversed the Superior Court's decision and remanded the case for further proceedings in line with its opinion.In reaching its decision, the court considered the specific language of the Acts, their purpose and legislative intent, as well as practical considerations. The court also noted that including out-of-state convictions could lead to inconsistencies and impracticalities. View "Osgood v. State" on Justia Law

Defendant-appellant Larry Martin appealed the sentence he received after pleading guilty to one count of Stalking and two counts of Non-Compliance with Bond (“NCB”). The trial court entered its first sentencing order on August 12, 2022, followed by three corrected sentencing orders, entered on September 8, September 21, and October 17, 2022, respectively. It was undisputed that the trial court’s first sentencing order was illegal because it imposed a sentence that exceeded the maximum lawful sentence for Stalking, which was three years at Level V supervision. In an email dated August 29, 2022, Martin’s trial counsel informed the trial court of the illegality of the sentence, and that the State recommended that the trial court fix its error by redistributing Martin’s five-year prison sentence across the Stalking conviction and the two NCB convictions. In a corrected sentencing order, issued on September 8, 2022, the trial court reduced Martin’s sentence for Stalking to three years of incarceration at Level V supervision, to bring it in line with the lawful maximum sentence. The trial court then added one year of incarceration at Level V supervision, suspended for probation, to the suspended fines for each NCB conviction. It was undisputed that if this had been the original sentence, Martin’s sentence would have been lawful. Martin appealed the trial court’s sentencing order insofar as it modified his sentence for the NCB convictions, arguing that by increasing his sentence for the NCB convictions, the trial court effectively resentenced him for those convictions despite the fact that he had already served them. This was because those sentences consisted solely of fines that were suspended when imposed and as such, were completed as of the date of the sentence. According to Martin, he completed his sentence for both NCB convictions on August 12, 2022, and any subsequent resentencing was barred by principles of double jeopardy. The Delaware Supreme Court was not persuaded by this argument and affirmed the sentence imposed by the trial court in its September 8, 2022 sentencing order, as modified by the September 21, 2022 and October 17, 2022 sentencing orders. View "Martin v. Delaware" on Justia Law

After arresting Aaron Garnett in whose care were three young children, the police promptly sought to locate the children’s parent or guardian. This search, initiated before sunrise on a cold and rainy day, led the police to a house where they were told the children’s mother lived and was sleeping. Once there, the police knocked, then banged, on the front door and loudly announced their presence. When no one answered, one of the officers went to the rear of the house where, after another round of knocking and announcing, the officer noticed the back door was unlocked. He pushed open the unlocked door and, peering into the interior of the residence with the benefit of a flashlight, saw a motionless body under a blanket at the foot of a stairway. Joined now by fellow officers, he entered the residence and found the lifeless body of Naquita Hill, the mother of one of the children whose welfare had motivated the police’s visit. Seven or so hours later, Garnett confessed that, during a heated argument, he had choked Hill until she slumped to the floor and beat her with his fist after that. After a jury trial, Garnett was convicted of Naquita Hill’s murder. He appealed, but the Delaware Supreme Court found no reversible error and affirmed Garnett's conviction. View "Garnett v. Delaware" on Justia Law

A Delaware Family Court terminated Carter Ralston’s parental rights in his daughter who, at the time, had been in the State’s custody for over a year. The court’s decision was based primarily on Ralston’s failure to make progress on a case plan established by the Department of Services for Children, Youth, and Their Families (the “Department”). Ralston was incarcerated throughout most of the proceedings, but the case plan aimed to reunify him with his daughter. After the court terminated his parental rights, Ralston moved for relief from the order on the grounds that, since the order’s issuance, he had been released from prison and had completed the requirements of his case plan. The Family Court denied that motion, concluding that evidence of Ralston’s post-termination compliance with the case plan did not constitute “newly discovered evidence” under Family Court Civil Rule 60. Ralston appealed. Having considered each of Ralston’s arguments, the Delaware Supreme Court concluded the Family Court’s decision should be affirmed. "Although disposing of the guardianship petition before terminating Mr. Ralston’s parental rights would have been the better practice, the procedural sequence was not so deficient that it violated Mr. Ralston’s due process rights. As to the remaining issues, the Family Court correctly applied the law and did not abuse its discretion." View "Ralston v. Division of Services for Children, Youth and Their Families" on Justia Law

Defendant-appellant Shamayah Thomas (“Thomas”) was convicted after a bench trial of Stalking and related acts of intimidation and harassment. Before his bench trial, Thomas filed a pro se Motion to Dismiss Current Counsel and/or to Appoint New Counsel on grounds that his then-current counsel was not following his instructions regarding his pretrial defense (the “First Motion to Dismiss Current Counsel”). Also before trial, Thomas’ counsel filed a motion to suppress digital evidence (the “Motion to Suppress”) collected from Thomas’s pink iPhone (“Pink iPhone”), alleging that law enforcement seized the phone without a warrant and, alternatively, that the search warrant issued following the seizure of the Pink iPhone (“Search Warrant”) was constitutionally defective. The trial court denied Thomas’ motion for new counsel pursuant to Superior Court Rule 47; the court granted in part, and denied in part, the Motion to Suppress, ultimately admitting certain evidence extracted from the Pink iPhone. After trial, but before his sentencing, Thomas filed a second motion to dismiss current counsel and/or appoint new counsel. Although the Superior Court prothonotary’s office failed to direct the second motion to dismiss counsel to defense counsel or to the trial judge, the trial court addressed the motion at Thomas’ sentencing hearing. Given the option of either delaying sentencing and proceeding pro se, or proceeding with his then-current counsel, Thomas chose to proceed with sentencing as scheduled, represented by his then-current counsel. On appeal, Thomas argued the Superior Court: (1) erred when it categorized the Pink iPhone Search Warrant as an overbroad warrant as opposed to an unconstitutional general warrant; and (2) failed to adequately address Thomas’ Motions to Dismiss Counsel. Thomas asked the Delaware Supreme Court to reverse his convictions and remand for a new trial. Finding no reversible error, the Supreme Court affirmed the trial court. View "Thomas v. Delaware" on Justia Law

In 2013, defendant-appellant Darnell Martin received an unconditional gubernatorial pardon for his previous criminal convictions, which included several felony convictions. Several years later, Martin was arrested and charged with new offenses. After his convictions for those charges were affirmed on direct appeal, he filed a motion for postconviction relief, arguing that his trial counsel was ineffective. More than two years passed as the parties briefed Martin’s motion and the trial court considered it. During that time, Martin served his prison sentence and his term of probation. He was discharged from probation while the postconviction motion was under advisement with the Superior Court. After Martin’s probation was discharged, the Superior Court dismissed his postconviction motion as moot, concluding that he no longer was “in custody” as required by Rule 61(a) and, given his extensive criminal history, he would not suffer any collateral consequences as a result of the convictions he was challenging. When the Superior Court dismissed the motion, it was not aware that Martin’s previous convictions had been pardoned. Martin appealed, and the Delaware Supreme Court remanded to the Superior Court to further consider the effect of Martin’s pardon, including whether a pardoned defendant suffers collateral consequences in the same manner as a first-time felon and therefore should not have his postconviction motion mooted if he is released from custody before the motion is resolved. The Superior Court concluded the collateral consequences doctrine, which the Supreme Court adopted more than 50 years ago based on United States Supreme Court precedent, has no continuing application in postconviction proceedings in Delaware. Martin’s appeal then returned to the Supreme Court, where he again challenged dismissal of his motion and the Superior Court’s application of the mootness doctrine. Having carefully considered the Superior Court’s decision and the parties’ submissions, the Delaware Supreme Court concluded the Superior Court erred in dismissing Martin’s postconviction motion as moot. View "Martin v. Delaware" on Justia Law

The issue this case presented for the Delaware Supreme Court's review stemmed from a failed, multibillion-dollar merger (the “Merger”) of two fuel pipeline giants - The Williams Companies, Inc. (“Williams”) and Energy Transfer LP (“ETE”). The parties spent a decade litigating over various fees to which they argued they were entitled under the Merger Agreement. ETE continued to assert its entitlement to a $1.48 billion breakup fee, despite being the party who terminated the Merger. It also disputed that it had to pay Williams a $410 million reimbursement fee, which it was required to pay if the Merger failed and certain conditions were met. Finally, ETE argued a related $85 million attorney’s fee award was unreasonable. But the Supreme Court found no error with the Court of Chancery’s opinions that held ETE was not entitled to an over-one-billion-dollar fee and find that ETE had to pay Williams the $410 million reimbursement fee and the related $85 million in attorney’s fees. View "Energy Transfer, LP v. The Williams Companies, Inc." on Justia Law

Guaranteed Rate, Inc., a mortgage lender, purchased two types of insurance policies from ACE American Insurance Company: management liability and professional liability. Guaranteed Rate sought coverage under the policies for an investigation and eventual settlement of claims brought by the federal government under the False Claims Act. ACE denied coverage under both policies. According to ACE, the Professional Liability Policy expressly excluded False Claims Act charges. ACE also contended that the False Claims Act charges arose from Guaranteed Rate’s professional services, which were excluded under the Management Liability Policy. Only the Management Liability Policy was at issue in this appeal. In Guaranteed Rate’s suit against ACE, a Delaware superior court held that the False Claims Act investigation and settlement did not arise out of Guaranteed Rate’s professional services. Instead, it arose out of false certifications made to the government. Thus, the Management Liability Policy covered the loss. To this, the Delaware Supreme Court agreed with the superior court. View "ACE American Insurance Company v. Guaranteed Rate, Inc." on Justia Law

Respondent-appellant Michael Killen appealed a Family Court order awarding alimony to his ex-wife, Candice Alben, and directing Killen to maintain a pre-existing life insurance policy during the alimony period with Alben as the sole beneficiary. Killen challenged aspects of both rulings on appeal. With respect to the alimony award, Killen argued the Family Court designated the incorrect date for his payment obligations to begin. The parties continued to reside in the marital residence after their divorce and through the date of trial. Before the matter was submitted, the parties agreed to sell the home and to divide the proceeds at the court’s direction. The court’s order directed the parties to continue to split household expenses while they resided together and required Killen to begin making alimony payments upon the residence’s sale. Killen argues that his alimony obligations instead should commence on the divorce date. With respect to the insurance policy, Killen argues the Family Court directed the policy’s continued maintenance based on an inadequate record: the Family Court ordered the policy’s maintenance sua sponte. Regarding Killen's first contention, the Delaware Supreme Court concluded the Family Court did not abuse its discretion. On the other hand, the Family Court did not have a sufficient factual record to order Killen to maintain the policy with Alben as the sole beneficiary. The case was remanded for further proceedings. View "Killen v. Alben" on Justia Law

Defendants-appellants and cross-appellees, Gregory Holifield (“Holifield”) and GH Blue Holdings, LLC (“Blue”), appealed a Court of Chancery memorandum opinion in favor of plaintiff- appellee and cross-appellant, XRI Investment Holdings LLC (“XRI”). The issue this case presented was whether Holifield validly transferred his limited liability membership units in XRI to Blue on June 6, 2018. The resolution of that issue bore on the ultimate dispute between the parties (not at issue here) on whether XRI validly delivered to Holifield a strict foreclosure notice purporting to foreclose on the XRI membership units, or whether such notice was incorrectly delivered to him because Blue was, in fact, the owner of the units following the transfer. Following a one-day trial, the Court of Chancery determined that the transfer of the units from Holifield to Blue was invalid because it was not a permitted transfer under XRI’s limited liability company agreement, which provided that noncompliant transfers of XRI interests were “void.” The trial court, in interpreting the Delaware Supreme Court's holding in CompoSecure, L.L.C. v. CardUX, LLC, 206 A.3d 807 (Del. 2018), held that the use of the word “void” in XRI’s LLC agreement rendered the transfer incurably void, such that affirmative defenses did not apply. Despite this holding, the trial court, in dicta, further found that XRI had acquiesced in the transfer. The Delaware Supreme Court affirmed Court of Chancery’s judgment with respect to the Blue Transfer, but reversed the judgment insofar as it precluded XRI’s recovery for breach of contract damages and recoupment of legal expenses advanced to Holifield. The Court held that the trial court’s finding of acquiescence as to only one of the alleged breaches did not bar either remedy, and the Court remanded the case for the trial court to make further determinations. View "Holifield v. XRI Investment Holdings LLC" on Justia Law