Justia Delaware Court of Chancery Opinion Summaries

Articles Posted in Constitutional Law
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The Court of Chancery dismissed for lack of subject matter jurisdiction this case brought by Plaintiffs, two religious leaders, challenging restrictions that the Governor imposed on houses of worship during the COVID-19 pandemic, holding that Plaintiffs failed to show any basis for relief.Plaintiffs asserted that they suffered harm as a result of the challenged restrictions and that the restrictions triggered, but could not survive, strict scrutiny. Plaintiffs sought as a remedy a declaration that the challenged restrictions were unconstitutional and a permanent injunction prohibiting the Governor from implementing similar restrictions in the future. The Court of Chancery granted the Governor's motion to dismiss, holding that Plaintiffs did not establish a reasonable apprehension that the Governor would engage in conduct that would warrant a permanent injunction and therefore did not make the necessary showing. View "In Re Covid-Related Restrictions On Religious Services" on Justia Law

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The Master of Chancery determined that Meghan Kelly's complaint against Donald Trump, in his individual capacity and in his official capacity as President of the United States, must be dismissed as legally frivolous under 10 Del. C. 8803(c).In her complaint, Kelly brought three counts alleging that Trump violated her religious freedom. Among other relief, Kelly sought relief permanently enjoining and restraining Trump from forcing religious views or sponsoring religion and from persecuting those with diverse religious beliefs while he serves as President of the United States. Kelly's primary claim was that, through Trump's deception, he was misleading people, deceiving them to sin, and dooming them to hell, and therefore, Kelly will not be able to love them for eternity. The Master in Chancery recommended that the Court dismiss the complaint as legally frivolous, holding that the complaint failed to state a claim upon which relief may be granted. View "Kelly v. Trump" on Justia Law

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The Court of Chancery denied that motion to dismiss filed by Defendants in this case claiming that Delaware’s public schools are failing to educate low-income students, students with disabilities, and students whose first language is not English (collectively, Disadvantaged Students), holding that Plaintiffs stated justiciable claims.Plaintiffs filed this lawsuit against the Governor, the Secretary of Education, and the State Treasurer, arguing that the State was not providing Disadvantaged Students adequate funding, appropriate classroom environments, and educational services and seeking declaratory judgments and equitable relief compelling the State to comply with its constitutional obligations. Defendants filed a motion to dismiss. The Court of Chancery denied the motion, holding (1) the complaint’s allegations supported a reasonable inference that the State is violating the Education Clause by failing to provide a general and efficient system of public schools that educates Disadvantaged Students and that Delaware’s public schools fall short of that mark; and (2) the public schools’ constitutional obligation is one that the judiciary can enforce. View "Delawareans for Educational Opportunity v. Carney" on Justia Law

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11 Del. C. 4121(u) mandates GPS monitoring of all Tier III sex offenders granted parole or probation without reference to the offenders’ risks of recidivism. Tier III sex offenders are those convicted of the most serious sex crimes. Plaintiffs in this case were Tier III sex offenders that challenged the constitutionality of section 4121(u), claiming that the statute violates the Fourth Amendment and the Ex Post Facto Clause of the Federal Constitution, as well as Del. Const. art. I, 6. The Court of Chancery granted summary judgment in favor of Defendant, the Commissioner of the Delaware Department of Correction, holding that the challenged statute is not unconstitutional. View "Doe v. Coupe" on Justia Law

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Plaintiffs, a current and a former inmate at the JTVCC, filed suit challenging the constitutionality of a Delaware statute, 11 Del. C. 4322(c) & (d), that denies inmates access to certain Department of Correction policies and procedures. The court concluded that plaintiffs have not satisfied their burden of establishing standing because the complaint does not allege a legally protected interest affected by, or an injury-in-fact caused by, Sections 4322(c) & (d). Even if plaintiffs had standing, plaintiffs' constitutional challenges lack merit. The court concluded that the DOC is not constitutionally obliged to promulgate internal policies and procedures; the single-subject provision at issue is not implicated by Section 4322; and plaintiff's motion to amend is futile. Accordingly, the court granted defendants' motion to dismiss and denied plaintiffs' motions for summary judgment and to amend. View "Hall v. Coupe" on Justia Law

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Plaintiffs, a towing company and its owner, filed a complaint against the Division of State Police, Department of Safety and Homeland Security, State of Delaware, alleging that Defendants discriminated against the owner on the basis of her sex and against the company as a minority-owned business and that Defendants treated Plaintiffs differently for arbitrary or malicious reasons by not assigning the towing company, the only female-owned towing company in Delaware, additional territory. The Court of Chancery granted Defendants’ motion to dismiss, holding that Defendants established that the complaint alleged facts that showed it was filed too late and Plaintiffs failed to carry their burden of pleading facts demonstrating that tolling applies. View "First State Towing, LLC v. Div. of State Police" on Justia Law

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Plaintiffs, a towing company and its owner, filed a complaint against the Division of State Police, Department of Safety and Homeland Security, State of Delaware, alleging that Defendants discriminated against the owner on the basis of her sex and against the company as a minority-owned business and that Defendants treated Plaintiffs differently for arbitrary or malicious reasons by not assigning the towing company, the only female-owned towing company in Delaware, additional territory. The Court of Chancery granted Defendants’ motion to dismiss, holding that Defendants established that the complaint alleged facts that showed it was filed too late and Plaintiffs failed to carry their burden of pleading facts demonstrating that tolling applies. View "First State Towing, LLC v. Div. of State Police" on Justia Law

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In 2015, Red Clay Consolidated School District (Red Clay) sought approval from voters to increase certain school-related property taxes. The referendum passed. Plaintiffs were residents of Red Clay who opposed the tax increase but did not vote because they were unable to access the polls. Plaintiffs brought this complaint asserting that Red Clay deprived them of their right to vote without due process of law and denied them equal protection, in violation of the Fourteenth Amendment, and that Red Clay violated Del. Const. art. I, 3, which states that all elections shall be free and equal. Specifically, Plaintiffs asserted that Red Clay raised impediments to voting by elderly and disabled residents, who Red Clay believed would oppose the tax increase. Red Clay filed a motion to dismiss the complaint for failure to state a claim. The Court of Chancery denied Red Clay’s motion, concluding that Plaintiffs pled sufficient facts to move beyond the pleading stage. View "Young v. Red Clay Consolidated Sch. Dist." on Justia Law

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Trusts that owned fifty percent of the common stock of nominal defendant IMS alleged that two of the company's three most senior officers mismanaged the company in breach of their fiduciary duties. Trusts moved to compel IMS to produce the senior officers' work email accounts. The senior officers asserted the attorney-client privilege but did not invoke the work product doctrine. The court concluded that the In re Asia Global Crossing, Ltd. factors weighed in favor of production, absent a statutory override that could alter the common law result. Because IMS conducted its business in Maryland, the federal government and the State of Maryland were the sovereigns whose laws IMS must follow when dealing with its employees' email. The Federal Wiretap Act, 18 U.S.C. 2510 et seq.; the Federal Store Communications Act, 18 U.S.C. 2701; the Maryland Wiretap Act, Md. Code, Cts. & Jud. Proc. 10-401 to 10-414; and the Maryland Stored Communications Act, Md. Code, Cts. & Jud. Proc. 10-4A-01 to 10-4A-08, did not change the common law privilege analysis. Accordingly, the court granted the motion to compel. View "In re Info. Mgmt. Servs., Inc. Derivative Litigation" on Justia Law

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Petitioners, residents of New Castle County, befriended a stray dog called Maggie. They later turned Maggie over to the Kent County Society for the Prevention of Cruelty to Animals (SPCA). Subsequently, Petitioners told the SCPA they would like to adopt Maggie. After concluding that the SPCA had euthanized Maggie, Petitioners filed this action, seeking to compel the SPCA to comply with the state's Shelter Standards Law, including strict compliance with its euthanasia requirements. The SPCA moved to dismiss the action, claiming, among other things, that Petitioners lacked standing to pursue their claims. The Court of Chancery dismissed the action, concluding that Petitioners failed to satisfy the "legally protected interest" element of standing because they did not own Maggie, and their statement of interest to adopt Maggie was not sufficient to create a reasonably conceivable legally protected interest in Maggie. View "Gittman-Crowther v. Kent County Society for the Prevention of Cruelty to Animals" on Justia Law