Justia Delaware Supreme Court Opinion Summaries

RAA appealed from a final judgment of the Superior Court that dismissed its complaint pursuant to Rule 12(b)(6). RAA's complaint alleged that Savage told RAA, one of several potential bidders for Savage, at the outset of their discussions that there was "no significant unrecorded liabilities or claims against Savage," but then during RAA's due diligence into Savage, Savage disclosed three such matters, which caused RAA to abandon negotiations for the transactions. The complaint contended that had RAA known of those matters at the outset, it never would have proceeded to consider purchasing Savage. Therefore, according to RAA, Savage should be liable for the entirety of RAA's alleged $1.2 million in due diligence and negotiation costs. The court held that, under Paragraphs 7 and 8 of the non-disclosure agreement (NDA), RAA acknowledged that in the event no final "Sale Agreement" on a transaction was reached, Savage would have no liability, and could not be sued, for any allegedly inaccurate or incomplete information provided by Savage to RAA during the due diligence process. The court also held that RAA could not rely on the peculiar-knowledge exception to support its claims. Finally, the court held that, when Savage and RAA entered into the NDA, both parties knew how the non-reliance clauses had been construed by Delaware courts. Accordingly, the court affirmed the judgment. View "RAA Management, LLC v. Savage Sports Holdings, Inc." on Justia Law

The court reviewed the Superior Court's denial of a motion to suppress stemming from a traffic stop. Because the officer lacked reasonable suspicion, the court reversed the trial judge's denial of the motion to suppress drugs discovered in defendant's bag. Defendant's continued detention constituted an impermissible seizure, and the questioning itself violated even the limited rights possessed by a probationer. Accordingly, the court reversed the judgment. View "Murray v. State" on Justia Law

Defendant was found guilty on four charges related to the sexual assault of two minors. At issue was the use of out-of-court statements in criminal prosecutions. The court found that, in this case, the inadmissible comments were made in court, when the interviewer explained the protocol used for interviewing children about sexual abuse. The interviewer offered her opinion that the protocol made it "very obvious when [children] are being truthful." Therefore, that was impermissible vouching and required reversal. View "Richardson v. State" on Justia Law

A monition action was brought by the City against defendant for the collection of taxes and charges. The real property was sold at a sheriff's sale to the successful third-party bidder, One-Pie. After confirmation, One-Pie filed a petition for tax deed. The Superior Court confirmed a Commissioner's order denying the petition, because defendant had successfully redeemed the property. One-Pie raised three claims on appeal, contending that the Superior Court erred by: (i) determining that the property had been redeemed properly; (ii) determining that One-Pie lacked standing; and (iii) allowing defendant to use One-Pie's funds for redemption. The court found no merit in the appeal and affirmed the judgment. View "One-Pie Investments, LLC v. Jackson" on Justia Law

The Vice Chancellor made an interim fee award of $2.5 million to plaintiff's attorneys, after the Court of Chancery's decision in Kurz v. Holbrook and the court's decision in Crown EMAK Partners, LLC v. Kurz. Delaware law rewarded plaintiffs' attorneys who provided a benefit to a Delaware corporation, even if the benefit did not produce immediate monetary rewards. The court held that the record supported the Vice Chancellor's factual finding that the voting rights preserved by the litigation were meaningful, and the court declined the invitation to fine tune the amount he awarded. Accordingly, the court affirmed the judgment of the Court of Chancery. View "Emak Worldwide, Inc. v. Kurz, et al." on Justia Law

Father filed a motion to modify a child custody and visitation agreement in the Family Court in order to travel with his three children to certain countries. The trial judge denied father's motion, holding that contract principles governed the agreement and barred the trial court from modifying unambiguous contract language. On appeal, the father claimed that the trial judge erroneously applied contract principles to a custody and visitation agreement instead of applying the best interest of the child test as required under 13 Del. C. 722. Since the modification requested here should have been reviewed under the best interest of the child test, the court reversed and remanded. View "Morrisey v. Morrisey" on Justia Law

This case arose from a dispute over certain property subject to a foreclosure. At issue was whether the parol evidence rule required that a person who claimed to hold a "purchase money mortgage" must prove his purchase money mortgage holder status solely by reference to the mortgage instrument itself. The court concluded that, in this case, the recorded deed and purchase money mortgage established that the sellers' mortgage satisfied, at least prima facie, all three requirements of 25 Del. C. 2108. Moreover, the mortgage contained no subordination language that would relinquish priority to the third party lenders. Therefore, the presumption that the sellers' mortgage was a purchase money mortgage entitled to statutory priority standards stood unrebutted. By applying the parol evidence rule to reach a contrary conclusion, the Superior Court erred as a matter of law. View "Galantino v. Baffone" on Justia Law

Defendant appealed from the judgment of conviction of Carjacking in the Second Degree. On appeal, defendant argued that the Superior Court "relieved the State of its burden to establish every element of an indicted charge beyond [a] reasonable doubt when it erroneously interpreted...the [statutory] language of [Title 11, section 836(a) of the Delaware Code.]" The court concluded that defendant's argument was without merit where the statute was properly construed and affirmed the judgment. View "Dennis v. State" on Justia Law

Defendant was found guilty of Attempted Robbery First Degree. On appeal, defendant argued that statements in closing rebuttal argument, asserting that the State brought Attempted Robbery charges because that was exactly what defendant did, constituted improper vouching for the State's case. The court found that the prosecutor engaged in misconduct which prejudicially affected defendant and therefore reversed and remanded. View "Kirkley v. State" on Justia Law

Mother appealed from a final judgment of the Family Court that terminated her parental rights in her now three-year-old child. Mother raised two arguments on appeal: (1) the Family Court erred, by shifting the burden of proof from the DFS to her, at the termination of parental rights hearing; and (2) the Family Court's factual determination that mother failed to plan for the child was clearly erroneous and not sufficiently supported by the record. The court held that the record reflected that the Family Court properly placed the burden of proof on DFS throughout the termination proceedings and mother had failed to show that the Family Court's "failure to plan" determination was clearly erroneous. Accordingly, concluding that mother's arguments were without merit, the court affirmed the judgment. View "Long v. DFS & Office of Child Advocate" on Justia Law