Justia Civil Procedure Opinion Summaries

Harrison Sanders and Trinity Turner, divorced parents of two children, were involved in a legal dispute over compliance with a Family Court Order of Protection From Abuse (PFA Order) against Turner. The PFA Order required Turner to undergo evaluations by a certified treatment program and obtain a psychological evaluation. Turner failed to comply, leading to a contempt finding and a daily fine of $200 until compliance.The Family Court Commissioner found Turner in contempt twice. The first contempt order imposed a daily fine for noncompliance, and the second contempt order calculated the total fine at $51,200 for continued noncompliance. Initially, the Commissioner directed that the fine be paid to Sanders. Turner sought review by a Family Court Judge, who upheld the contempt finding and fine amount but ruled that the fine should be paid to the court, not Sanders. Sanders filed a motion for reargument, which the court denied, maintaining that the fine was to be paid to the court as it was intended to coerce compliance with the court's order.The Supreme Court of Delaware reviewed the case and affirmed the Family Court's decision. The court held that coercive contempt fines, unless compensatory in nature, should be paid to the court. The court reasoned that it is the court's authority being vindicated through such fines, not the rights of a private litigant. The court also addressed procedural arguments, concluding that the Family Court Judge had the authority to review and modify the Commissioner’s orders and that Sanders suffered no prejudice from the court’s decision to consider the payment recipient issue. The Supreme Court denied Sanders' request for attorneys' fees, affirming the Family Court's judgment. View "Sanders v. Turner" on Justia Law

The case involves a challenge to two Delaware voting statutes: one allowing absentee voters to request "permanent absentee" status, and the other authorizing qualified, registered voters to vote in person at least 10 days before an election. The plaintiffs, a citizen who plans to serve as an election inspector and a Delaware State Senator, argued that these statutes conflict with the Delaware Constitution's provisions governing elections and voting.The case was initially filed in the Court of Chancery, which dismissed it on jurisdictional grounds. The plaintiffs then pursued their claims in the Superior Court. The Superior Court found that the plaintiffs had standing to bring the case and ruled in their favor, declaring the challenged statutes unconstitutional.On appeal, the Supreme Court of the State of Delaware reversed the Superior Court's decision. The Supreme Court found that neither plaintiff had standing to challenge the statutes. The court held that the State Senator, who was not up for re-election until 2026, did not face an imminent or particularized harm. The court also found that the citizen, who planned to serve as an election inspector, did not have standing because his role as an inspector did not give him the authority to turn away lawful voters based on his personal belief that the challenged statutes were invalid. Finally, the court rejected the plaintiffs' claim that they had standing as registered voters, finding that their alleged injury was a generalized grievance shared by all voters, not a particularized harm. As a result of these findings, the court did not address the merits of the plaintiffs' constitutional claims. View "Albence v. Mennella" on Justia Law

The case involves a plaintiff who was bitten by a dog at a facility operated by an animal welfare organization. The plaintiff filed a lawsuit against the organization, invoking Delaware's "dog bite statute," which imposes strict liability on a dog owner for any injury caused by the dog. The Superior Court of Delaware granted summary judgment in favor of the organization, ruling that the statute does not apply to animal welfare organizations. The court reasoned that the statute was intended to target irresponsible dog owners who keep vicious dogs as pets, not organizations like the defendant.The Superior Court's decision was based on its interpretation of the legislative intent behind the dog bite statute. The court also held that the plaintiff could not establish negligence on the part of the organization without expert testimony, as the standard of care applicable to animal shelters was outside the common knowledge of laypersons.The plaintiff appealed the decision to the Supreme Court of the State of Delaware. The Supreme Court disagreed with the lower court's interpretation of the dog bite statute. It found that the statute unambiguously imposes strict liability on any person who owns, keeps, harbors, or is the custodian of a dog, without any exception for animal welfare organizations. The court also disagreed with the lower court's requirement for expert testimony to establish negligence, ruling that the standard of care in handling a domestic animal with known vicious propensities is within the common knowledge of laypersons. The Supreme Court reversed the Superior Court's decision and remanded the case for further proceedings. View "Riad v. Brandywine Valley SPCA, Inc." on Justia Law

The case involves Ferrellgas Partners L.P. and its subsidiaries (collectively "Ferrellgas") and Zurich American Insurance Company ("Zurich"). Ferrellgas had an insurance policy with Zurich, which included a provision for the advancement of defense costs for litigation. Ferrellgas was involved in a separate lawsuit with Eddystone Rail Company, LLC ("Eddystone") over a breach of contract. Ferrellgas sought to have Zurich cover the defense costs for the Eddystone litigation under their insurance policy.In the lower court, the Superior Court of the State of Delaware, Ferrellgas filed a motion for summary judgment seeking a declaratory relief obligating Zurich to advance defense costs for the Eddystone litigation. Zurich also filed a motion for summary judgment seeking a declaration that it had no obligation to advance defense costs. The Superior Court denied Ferrellgas' motion and granted Zurich's motion, finding that the Eddystone litigation was excluded from coverage under the Zurich policy.On appeal, the Supreme Court of the State of Delaware affirmed the decision of the Superior Court. The Supreme Court found that the Eddystone litigation was a claim seeking relief for a breach of contract that occurred after the commencement of the Run-Off Coverage Period in the Zurich policy. As such, Zurich had no duty to advance defense costs for this matter due to the Run-Off Exclusion in the policy. The court also found that Ferrellgas' appeal was timely filed. View "Ferrellgas Partners, L.P. v. Zurich American Insurance Company" on Justia Law

The case involves NGL Energy Partners LP and NGL Energy Holdings LLC (collectively, "NGL") and LCT Capital, LLC ("LCT"). NGL, entities in the energy sector, engaged LCT, a financial advisory services provider, for services related to NGL's 2014 acquisition of TransMontaigne Inc. However, the parties failed to agree on payment terms, leading LCT to file a lawsuit in 2015. The Superior Court held a jury trial in July 2018, which resulted in a $36 million verdict in LCT's favor.NGL appealed the Superior Court's decision, challenging the $36 million final judgment and a set of evidentiary rulings. LCT cross-appealed, contesting the Superior Court's methodology for computing post-judgment interest. NGL argued that the Superior Court erred by admitting evidence and arguments about the value/benefit supposedly gained by NGL in the Transaction, asserting that such evidence is prejudicial and irrelevant to a quantum meruit claim. NGL also argued that the Superior Court erred by admitting evidence of benefit-of-the-bargain or expectancy damages when assessing the quantum meruit value of LCT’s services.The Supreme Court of the State of Delaware affirmed the Superior Court’s evidentiary rulings and rejected NGL's contention that the Superior Court incorrectly allowed LCT to recover benefit-of-the bargain/expectancy damages. However, the Supreme Court disagreed with the Superior Court’s post-judgment interest determination. The Supreme Court held that prejudgment interest is part of the judgment upon which post-judgment interest accrues under Section 2301(a). Therefore, the Supreme Court reversed the Superior Court as to this issue and remanded the case to the Superior Court for entry of judgment consistent with its opinion. View "NGL Energy Partners LP v. LCT Capital, LLC" on Justia Law

In this case, the Supreme Court of the State of Delaware reversed a lower court’s decision to terminate a biological father’s parental rights to his child. The father, Jack Mitchell, had consented to the child's guardianship by Rachel and Joshua Thayer, following the unexpected death of the child's mother. Six months later, the Thayers petitioned to terminate Mitchell’s parental rights on grounds of intentional abandonment. The Family Court granted their petition, finding clear and convincing evidence of abandonment and deciding termination was in the child’s best interests. However, the Supreme Court found that the evidence did not meet the high standard of clear and convincing proof of intentional abandonment required to terminate Mitchell's parental rights. The court noted that Mitchell had expressed a desire for reunification with his child and had taken steps toward that goal. The Supreme Court therefore reversed the Family Court’s decision and remanded the case for further proceedings regarding Mitchell's petition to rescind the Thayers' guardianship. View "Mitchell v. Thayer" on Justia Law

In the State of Delaware, a lawsuit was brought by two non-profit organizations against multiple public officials, including tax collectors in Delaware's three counties. The organizations sought increased funding for Delaware’s public schools. The Court of Chancery held that the organizations were entitled to attorneys’ fees and expenses. On appeal, the Supreme Court of Delaware held that the Court of Chancery erred in its application of the "common benefit doctrine" and its expansion of a precedent case, Korn v. New Castle County, beyond taxpayer suits. The Supreme Court affirmed the Chancery Court's award of expenses, but reversed the award of attorneys' fees. The Supreme Court held that the litigation brought by the organizations was to compel the defendant county governments to comply with the law, a benefit that did not warrant an exception to the "American Rule" which states that each party bears its own attorneys' fees, absent certain exceptions. The Court also held that, even if this case were a taxpayer suit, it does not meet the standard set forth in Korn because there was not a quantifiable, non-speculative monetary benefit for all taxpayers. View "In re Delaware Public Schools Litigation" on Justia Law

The Supreme Court of the State of Delaware upheld a lower court's decision regarding a dispute between the Salt Meadows Homeowners Association (Salt Meadows) and Zonko Builders, Inc. (Zonko). Salt Meadows accused Zonko of faulty construction leading to water damage in the condominium complex built by Zonko. The Superior Court found Zonko liable but left the question of damages to a jury, which awarded Salt Meadows $11.3 million in general damages and $1.6 million for specific repair costs. However, the Superior Court later reduced the general damage award to $8.3 million, citing unsupported, speculative, and excessive damage claims. The court also granted Zonko's motion for judgment as a matter of law related to the specific repair costs, finding that Salt Meadows expanded its claims without sufficient evidence. On appeal, the Supreme Court affirmed the Superior Court's decision, agreeing that Salt Meadows' damage claims were speculative and unsupported. The court also agreed with the lower court's calculation of pre-judgment interest from the date the damages were discovered, not from the date of Zonko's negligent construction. The court further affirmed the calculation of post-judgment interest from the date of the verdict, as agreed upon by both parties. View "Salt Meadows Homeowners Association, Inc. v. Zonko Builders, Inc." 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

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