Collins J. Seitz

The case concerned equity holders in BioTE Holdings, LLC who alleged that company insiders breached fiduciary duties by structuring a de-SPAC recapitalization transaction that diluted their interests and diverted value to themselves. The Court of Chancery dismissed the complaint, in part for lack of standing after the plaintiffs sold their converted equity. On appeal, the Delaware Supreme Court affirmed the dismissal, holding that even assuming the claims were direct rather than derivative, the plaintiffs lost standing once they sold the shares because such claims travel with the equity under Delaware precedent. The court rejected arguments that the recapitalization or conversion altered this outcome or that the claims survived the sale.

business & regulatoryprocedure

The case concerns a shareholder derivative action brought on behalf of Regions Financial Corporation and Regions Bank against certain directors, alleging that they breached their fiduciary duties under Caremark and Massey theories by failing to promptly address illegal overdraft fee practices after a 2019 whistleblower complaint, resulting in a $191 million CFPB consent order. The Court of Chancery denied the defendants' motion to dismiss in part, holding that the plaintiff had adequately pleaded demand futility, and later denied the defendants' application to certify an interlocutory appeal. The Delaware Supreme Court refused the interlocutory appeal, agreeing that it failed to satisfy Rule 42(b) standards because the cited factors did not support review, the litigation would not terminate, and the benefits did not outweigh the inefficiency and costs. The court exercised its discretion to conclude that exceptional circumstances meriting interlocutory review were absent.

business & regulatoryprocedure

The case involves Derrick Caudle appealing the Superior Court of Delaware's denial of his motion for correction of an illegal sentence under Cr. ID No. 1802012108. The Delaware Supreme Court reviewed the opening brief, motion to affirm, and the record on appeal. It decided to affirm the lower court's May 20, 2025 order, concluding that the judgment below should be upheld. The core reasoning was that the appeal lacked merit warranting reversal after consideration of the submitted materials.

criminal lawprocedure

Kenneth Wygand sued Presidio, Inc. in Delaware Superior Court over an unspecified dispute. The Superior Court granted the defendant's motion for summary judgment and denied the plaintiff's motion. On appeal, the Delaware Supreme Court affirmed the lower court's March 24, 2025 order, concluding that the judgment should stand based on the record and the trial court's reasoning.

procedurebusiness & regulatory

The case involved Jesse R. Longfellow appealing from the Superior Court of Delaware's denial of his motion for correction of an illegal sentence in a criminal matter. The Delaware Supreme Court considered the opening brief, the motion to affirm, and the record on appeal. The court affirmed the judgment below, adopting the reasoning of the Superior Court's June 27, 2025 order that denied the motion. It granted the motion to affirm and upheld the lower court's decision without further elaboration.

criminal lawprocedure

The case was an appeal to the Delaware Supreme Court by Two Rivers Farm, LLC from a Court of Chancery ruling in its dispute with plaintiff Melissa Garlington. The Supreme Court affirmed the Chancery judgment in favor of Garlington after reviewing the parties' briefs, the record, and oral argument. The affirmance was based directly on the reasons set forth in the Court of Chancery's April 7, 2025 Letter Opinion.

business & regulatoryproperty

The case concerned the termination of parental rights of Shelby Davis (Mother) with respect to her daughter born in June 2024. The Family Court granted the petition of the Department of Services for Children, Youth and Their Families after finding the child dependent due to the mother's positive drug test at birth, history of substance abuse and mental health issues, unsuitable housing, and prior involuntary terminations of her parental rights to other children; it excused case planning and changed the permanency goal to termination under 13 Del. C. § 1103(a)(5) and (a)(7). Mother appealed, but her counsel filed a no-merit brief under Supreme Court Rule 26.1(c); the Delaware Supreme Court reviewed the record and affirmed the Family Court's judgment, concluding that the factual findings were supported by clear and convincing evidence and that there was no error in the application of the law.

family law

The case involved Michael T. Fields appealing from the Superior Court of Delaware's denial of his motions to correct an illegal sentence in a criminal proceeding. The Delaware Supreme Court reviewed the opening brief, the motion to affirm, and the record on appeal. It affirmed the judgment below on the basis of the Superior Court’s June 30, 2025 order. The court granted the motion to affirm and upheld the lower court's ruling without further elaboration.

criminal lawprocedure

This case is an appeal to the Delaware Supreme Court from the Family Court in a divorce proceeding between Neil Vincent and Samantha Vincent, focusing on the division of a Fidelity account and related motions. The Supreme Court affirmed the Family Court's orders dated February 5, 2025, and March 26, 2025, denying the appellant's motions to control the account and to admit additional documents on appeal. The court reasoned that the appellant failed to show reversible error in the division of the account and that interim control should remain with the appellee to protect its value, with the appellee required to provide account statements. Regarding the documents, the court held that appellate review is limited to matters considered by the trial court, and the Family Court did not abuse its discretion in excluding documents not produced during discovery.

family lawpropertyprocedure

This case was a class action filed in the Delaware Court of Chancery by Faiz Khan and Ralph Finger against Warburg Pincus investment funds and related companies including Walgreens and Village Practice Management. The plaintiffs challenged certain corporate transactions or conduct involving the defendants. The Court of Chancery issued a memorandum opinion on April 30, 2025, disposing of the claims. On appeal, the Delaware Supreme Court reviewed the parties' briefs, the record, and oral argument before affirming the lower court's judgment in full, adopting its reasoning without elaboration.

business & regulatory

In Henry v. State, Jhalir Henry was convicted after a bench trial of first-degree murder, possession of a firearm during the commission of a felony, possession of a firearm by a person prohibited, and conspiracy first-degree for the fatal shooting of Corey Mumford at an apartment complex. The Superior Court denied Henry's motion for judgment of acquittal, and on appeal, the Delaware Supreme Court affirmed the conviction. The court held that the evidence supported Henry's liability as an accomplice, finding that he was an active participant throughout the events and did not terminate his complicity before the offense was committed, as required by statute.

criminal law

This case was a consolidated stockholder litigation filed in the Delaware Court of Chancery against Straight Path Communications Inc. The Delaware Supreme Court affirmed the Court of Chancery's judgment after reviewing the parties' briefs, the record, and oral argument. The affirmance rested entirely on the reasons stated in the Chancery Court's Memorandum Opinion dated October 3, 2023, and its Final Order and Judgment dated December 16, 2024. No independent analysis or additional grounds were provided by the Supreme Court.

business & regulatory

In this case, Jonathan Johnson, who had pleaded guilty in 2017 to drug dealing cocaine and possession of a firearm during the commission of a felony (PFDCF) and was sentenced as a habitual offender, filed a petition for a writ of habeas corpus in 2025. He argued that his indictment was defective because the PFDCF count lacked details such as the gun's make, model, caliber, and serial number, claiming this deprived the Superior Court of jurisdiction. The Superior Court denied the petition, finding that the indictment substantially followed the statute and provided sufficient notice, and that discovery had supplied additional details before the plea. The Delaware Supreme Court affirmed, holding that habeas corpus relief is limited to reviewing whether the committing court had jurisdiction, which the Superior Court clearly did over felony charges, and that any indictment deficiencies did not affect jurisdiction. The Court also addressed Johnson's history of repetitive filings by noting an existing injunction on future appeals without leave.

criminal lawprocedure

Stephen Wheeler appealed the Superior Court’s denial of his motion to correct an illegal sentence following his 2018 convictions, after a bench trial, for home invasion, first-degree robbery, second-degree assault, and second-degree conspiracy, for which he received sentences including mandatory minimum terms of Level V incarceration. The Delaware Supreme Court affirmed the denial, ruling that Erlinger v. United States—which requires a jury to find beyond a reasonable doubt whether prior offenses occurred on separate occasions for certain federal sentence enhancements—did not apply. The court reasoned that the sentencing judge made no factual findings about Wheeler’s criminal history that increased the applicable minimum or maximum penalties, the sentences stayed within statutory ranges, and the judge’s consideration of aggravating factors such as victim vulnerability and cruelty to exceed non-binding sentencing guidelines did not render the sentences illegal.

criminal lawprocedure

This case was an appeal to the Delaware Supreme Court from a Superior Court criminal matter, in which Santiago Mejia Roblero challenged a lower court ruling. The appellant failed to file the required opening brief by the September 26, 2025 deadline and did not respond to a subsequent delinquency notice or a certified show-cause order directing him to explain why the appeal should not be dismissed. The court determined that the appellant's inaction left the dismissal unopposed and therefore dismissed the appeal pursuant to Supreme Court Rules 3(b)(2) and 29(b).

criminal lawprocedure

This case was an appeal by Devin Harris from a criminal proceeding in Delaware Superior Court. After Harris missed the deadline to file an opening brief, the court issued notices, including one by certified mail that he received, directing him to explain why the appeal should not be dismissed. Harris neither responded to the notice nor filed a brief by the deadline. The Delaware Supreme Court therefore dismissed the appeal as unopposed under Supreme Court Rules 3(b)(2) and 29(b).

criminal lawprocedure

The case involved Oliver Henry appealing the Superior Court's denial of his motion to correct an illegal sentence under Rule 35(a) for his conviction of second-degree murder. The Delaware Supreme Court affirmed the lower court's decision, upholding the sentence imposed. The court reasoned that the sentence fell within the statutory range authorized for the offense, and thus did not violate the principles established in Apprendi v. New Jersey or Blakely v. Washington, particularly given the non-binding nature of Delaware's sentencing guidelines.

criminal lawprocedure

The case involved Oliver Henry appealing the Superior Court’s denial of his motion under Superior Court Rule of Criminal Procedure 35(a) challenging his sentence for second-degree murder. The Delaware Supreme Court affirmed the lower court’s decision, holding that the sentence was not illegal. The court reasoned that the imposed sentence fell within the statutory range authorized for the offense. It further noted that the U.S. Supreme Court decisions in Apprendi v. New Jersey and Blakely v. Washington did not render the sentence invalid because Delaware’s sentencing guidelines are voluntary and nonbinding.

criminal law

In Edwards v. State, defendant Bryan Edwards appealed the Superior Court of Delaware's denial of his motion filed under Superior Court Rule of Criminal Procedure 35(a). The Delaware Supreme Court reviewed the opening brief, the State's motion to affirm, and the appellate record before concluding that the Superior Court's July 11, 2025 order should stand. The Court therefore granted the motion to affirm and upheld the judgment below without further elaboration of its own reasoning.

criminal lawprocedure

The case involved several property owner associations challenging House Bill 242, which allows New Castle County school districts to create temporary split-rate property tax systems distinguishing between residential and non-residential properties to address assessment issues in school funding. The plaintiffs contended that the legislation violated the uniformity clause in Article VIII of the Delaware Constitution and a revenue neutrality requirement tied to tax projections in the bill. The Delaware Supreme Court affirmed the Court of Chancery's decision upholding the law against constitutional and statutory challenges. The court reasoned that the uniformity clause permits the General Assembly to authorize different tax rates for distinct property classes, and the revenue neutrality provision applies only to the school districts' initial rate calculations based on then-current data, allowing later county corrections for classification errors without violating the statute.

taxesproperty