Justia Delaware Court of Chancery Opinion Summaries

The case involves a dispute over the funding of Delaware's public schools. The plaintiffs, non-profit organizations with an interest in Delaware's schools, filed a lawsuit in 2018, alleging that the state's public schools were not providing an adequate education for students from low-income households, students with disabilities, and students whose first language is not English. They argued that one of the problems was a broken system for funding the schools, which relied on property taxes. The plaintiffs contended that the three counties in Delaware were using decades-old property valuations, which violated state law and the state constitution.The case was initially heard in the Court of Chancery of the State of Delaware. During discovery, the plaintiffs served requests for admission to the counties, asking them to admit that their decades-old assessments resulted in a lack of uniformity in property taxes and violated state law. The counties denied these requests. At trial, the court found in favor of the plaintiffs, ruling that the counties' assessments violated state law and the state constitution. The court also found that the plaintiffs had proved the facts that were the subject of the requests for admission that the counties had denied.The plaintiffs then requested an award of expenses under Court of Chancery Rule 37(c), which allows the court to order a party to pay the expenses that another party incurred in proving a fact that should have been admitted. The court granted the plaintiffs' request, awarding them expenses of $337,224, which included attorneys’ fees and out-of-pocket costs. Each county was ordered to pay a prorated share of $112,408. View "In re Delaware Public Schools Litigation" on Justia Law

The Supreme Court held that Sussex County, Kent County, and New Castle County use assessment methodologies when preparing their assessment rolls used by school districts in levying local taxes that fail to comply with three legal requirements.Plaintiffs were the NAACP Delaware State Conference of Branches (the NAACP-DE), the Delawareans for Educational Opportunity (the DEO) and the City of Wilmington. The NAACP-DE and the DEO argued that Delaware's public schools failed to provide an adequate education for students from low-income households, students whose first language is not English, and students with disabilities. When school districts levy local taxes, they are required to use the assessment rolls prepared by Delaware's three counties. The NAACP-DE and the DEO argued that when preparing their assessment rolls, the counties failed to comply with 9 Del. C. 8306(a) (the True Value Statute) and Del. Const. art. VIII, 1 (the Uniformity Clause). The City of Wilmington argued that New Castle County also violated its obligations under 22 Del. C. 1101-1104 (the Assessment Roll Statutes). The Supreme Court held (1) Plaintiffs had standing to assert their claims; and (2) all three counties used assessment methodologies that violate the True Value Statute and the Uniformity Clause and that New Castle County violated its obligations under the Assessment Roll Statutes. View "In re Delaware Public Schools Litigation" on Justia Law

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

Plaintiffs in this case were residents of Red Clay who were unable to access the polls during a special election held by Red Clay Consolidated School District in February 2015. In the election, residents were asked to approve an increase in the school-related property taxes paid by owners of non-exempt real estate located within the district. Red Clay prevailed in the special election, but Plaintiffs claimed electoral misconduct. The Court of Chancery declared that Red Clay violated the Elections Clause of the Delaware Constitution but did not award any greater relief because the violations did not warrant invalidating the special election. The court reached this result through a balancing of factors, including the dysfunction in Delaware’s system for funding public schools, which led to Red Clay facing a significant deficit without a favorable vote. View "Young v. Red Clay Consolidated School District" on Justia Law

Maurice J. Moyer Academic Institute (“New Moyer”) is a charter school in the City of Wilmington that serves some of the most economically disadvantaged students in the state. In 2014, the Department of Education, Secretary of Education, and Delaware Board of Education (collectively, Defendants) decided to revoke New Moyer’s charter in June 2016, one year before the charter expired. Defendants based their decision on the fact that New Moyer was the lowest performing charter school in the State based on the State’s testing standards. Plaintiffs - the operator of New Moyer, parents representing several of the school’s students, and the City - sought a preliminary injunction to enjoin Defendants from revoking New Moyer’s charter. The Court of Chancery denied Plaintiffs’ motion for a preliminary injunction, concluding that Plaintiffs failed to demonstrate (1) a reasonable probability that they were denied due process under the Fourteenth Amendment with respect to the decision to revoke the school’s charter; and (2) that Defendants did not exercise due diligence and good faith when they determined that New Moyer failed to satisfy criteria set forth in the Charter School Act. View "In re The New Maurice J. Moyer Academy Inc." on Justia Law

Plaintiff was a senior in the nursing program at Delaware State University (DSU) when she was dismissed for consuming a half of a margarita while on break during a clinical program. Plaintiff filed suit seeking reinstatement in the nursing program. The Court of Chancery granted relief, holding (1) DSU dismissed Plaintiff for academic reasons; (2) because Plaintiff was not fully informed of the charges against her or the severity of the consequences, she was not validly removed from the nursing program; and (3) Plaintiff was duly excluded from the clinical course but not from the nursing program. View "Jenkins v. Del. State Univ." on Justia Law

Plaintiff, a Delaware taxpayer, asserted claims against defendant, the State of Delaware Auditor of Accounts, for claims related to defendant's alleged noncompliance with 29 Del. C. 2906(f), which stated, in part, that the "Auditor of Accounts shall conduct postaudits of local school district tax funds budget and expenditures annually" and for claims related to defendant's alleged violation of Delaware's Freedom of Information Act (FOIA), 29 Del. C. ch. 100., by failing to provide plaintiff with copies of certain employee time sheets which he duly requested. The court held that it lacked subject matter jurisdiction over the audit claims and the FOIA claims must be dismissed because of plaintiff's failure to exhaust administrative remedies. View "Korn v. State of Delaware Auditor of Accounts R. Thomas Wagner, Jr." on Justia Law