Delaware Case Commentaries

Delaware Supreme Court Extends Rite Aid’s “Specific-and-Individualized Injury” Test to Property Damage and Endorsements – Commentary on In re CVS Opioid Insurance Litigation (2025)

Date: Aug 25, 2025

Delaware Supreme Court Extends Rite Aid’s “Specific-and-Individualized Injury” Test to Property Damage and Endorsements Introduction In In re CVS Opioid Insurance Litigation, No. 482, 2024 (Aug. 18,...

Scarborough Refined: Delaware Supreme Court Clarifies Strickland-Prejudice Analysis for Missed Plea-Withdrawal Motions

Date: Aug 15, 2025

Scarborough Refined: Delaware Supreme Court Clarifies Strickland-Prejudice Analysis for Missed Plea-Withdrawal Motions Introduction In Smith v. State, No. 179, 2024 (Del. Aug. 14, 2025), the Supreme...

“Only the Named Insured May Exhaust the SIR” – Delaware Supreme Court’s Definitive Guidance in In Re Aearo Technologies LLC Insurance Appeals

Date: Aug 13, 2025

“Only the Named Insured May Exhaust the SIR” – Delaware Supreme Court’s Definitive Guidance in In Re Aearo Technologies LLC Insurance Appeals 1. Introduction The Supreme Court of Delaware, sitting en...

Zimmer v. Nichols: Delineating Temporal Boundaries for Equitable Fee-Shifting in Delaware Family Litigation

Date: Aug 12, 2025

Zimmer v. Nichols: Delineating Temporal Boundaries for Equitable Fee-Shifting in Delaware Family Litigation Introduction Zimmer v. Nichols, decided by the Supreme Court of Delaware on 11 August 2025,...

Stevens v. State: Expert Testimony as a Sufficient Foundation for LC-MS/MS Blood-Toxicology Evidence

Date: Aug 12, 2025

Stevens v. State: Expert Testimony as a Sufficient Foundation for LC-MS/MS Blood-Toxicology Evidence Introduction In Stevens v. State, the Supreme Court of Delaware addressed whether the State must...

The “Brewster Rule”: Exceptions Remain a Mandatory Prerequisite to Appellate Review After the 2024 Amendments to Court of Chancery Rule 144

Date: Aug 9, 2025

The “Brewster Rule”: Exceptions Remain a Mandatory Prerequisite to Appellate Review After the 2024 Amendments to Court of Chancery Rule 144 1. Introduction In In the Matter of Rolf D. Brewster, a...

Kirby v. Perkins: Delaware Supreme Court Clarifies Best-Interests Analysis and Limits Reliance on Third-Party Funding in School-Choice Custody Disputes

Date: Aug 7, 2025

Kirby v. Perkins: Delaware Supreme Court Clarifies Best-Interests Analysis and Limits Reliance on Third-Party Funding in School-Choice Custody Disputes 1. Introduction Kirby v. Perkins, Supreme Court...

Gustave v. State — Clarifying Jury Access to a Defendant’s Recorded Admissions and the Threshold for Mistrial/New-Trial Relief after Exhibit Errors

Date: Jul 30, 2025

Gustave v. State — Clarifying Jury Access to a Defendant’s Recorded Admissions and the Threshold for Mistrial/New-Trial Relief after Exhibit Errors Introduction Gustave v. State, No. 382, 2024 (Del....

Ryan v. Sea Colony: Pleading-Stage Burden to Prove Agency When Enforcing Liability Waivers

Date: Jul 29, 2025

Ryan v. Sea Colony (Del. 2025): Delaware Supreme Court Clarifies that Defendants Must Plead—and Ultimately Prove—Agency Before Invoking Third-Party Liability Waivers Introduction Colleen Ryan, a...

No “Lucid Purpose” Filter: Delaware Supreme Court Re-Affirms the Low “Credible-Basis” Threshold Under 8 Del. C. § 220

Date: Jul 29, 2025

No “Lucid Purpose” Filter: Delaware Supreme Court Re-Affirms the Low “Credible-Basis” Threshold Under 8 Del. C. § 220 Introduction In Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018...

“The Prevention Doctrine Meets Auto-Insurance”: A Commentary on Mario De Los Santos v. Allstate Property & Casualty Insurance Co.

Date: Jul 26, 2025

“The Prevention Doctrine Meets Auto-Insurance” Delaware Supreme Court Clarifies Section 3915 and Blocks Insurers from Benefiting from Their Own Premium-Collection Errors Introduction In Mario De Los...

Directory Time Limits and Strict Accountability for Pro Hac Vice Admissions: The Delaware Supreme Court’s Decision in IMO John Du Wors

Date: Jul 26, 2025

Directory Time Limits and Strict Accountability for Pro Hac Vice Admissions: The Delaware Supreme Court’s Decision in IMO John Du Wors Introduction In In the Matter of John Du Wors, the Delaware...

Origis USA v. Great American Insurance: Reconciling “No-Action” Clauses with Advancement Duties in Indemnity-Only D&O Policies

Date: Jul 24, 2025

Origis USA v. Great American Insurance: Reconciling “No-Action” Clauses with Advancement Duties in Indemnity-Only D&O Policies 1. Introduction In Origis USA LLC v. Great American Insurance Co., No....

Tisinger v. State: Delaware Supreme Court Re-Affirms the “Bench-Trial Hearsay Presumption” and Refines Brady Disclosure Duties Where Prejudice Is Absent

Date: Jul 23, 2025

Tisinger v. State: Delaware Supreme Court Re-Affirms the “Bench-Trial Hearsay Presumption” and Refines Brady Disclosure Duties Where Prejudice Is Absent Introduction Dominique Tisinger appealed his...

“Implicit-Consequences” Doctrine: When a Guilty Plea Validly Waives Probation-Violation Challenges Without an Express Court Warning (Commentary on Gordon v. State, Del. Supr. Ct. 2025)

Date: Jul 15, 2025

“Implicit-Consequences” Doctrine: When a Guilty Plea Validly Waives Probation-Violation Challenges Without an Express Court Warning Commentary on Gordon v. State (Supreme Court of Delaware, July 14...

“Neutral Narrative” Testimony and the Absence of a Sua Sponte Instruction: The Legacy of Johnson v. State (Del. 2025)

Date: Jul 15, 2025

“Neutral Narrative” Testimony and the Absence of a Sua Sponte Instruction: The Legacy of Johnson v. State (Del. 2025) Introduction Johnson v. State, No. 320, 2024 (Del. July 14, 2025) tackles a...

From “Liberal Thrust” to Rigorous Gate-Keeping: Delaware Supreme Court Aligns D.R.E. 702 with Federal Rule 702 and Mandates Product-Specific Causation — Commentary on In re Zantac (Ranitidine) Litigation

Date: Jul 11, 2025

From “Liberal Thrust” to Rigorous Gate-Keeping: Delaware Supreme Court Aligns D.R.E. 702 with Federal Rule 702 and Mandates Product-Specific Causation — Commentary on In re Zantac (Ranitidine)...

Finality over Formality: Barlow v. State and the Discretion to Deny Plea Withdrawal Without an Evidentiary Hearing

Date: Jul 10, 2025

Finality over Formality: Barlow v. State and the Discretion to Deny Plea Withdrawal Without an Evidentiary Hearing Introduction Barlow v. State, decided by the Supreme Court of Delaware on 8 July...

Washington v. State: Temporal-Proximity Sufficiency & the Narrow Scope of Corpus Delicti in Delaware Concealed-Firearm Prosecutions

Date: Jul 4, 2025

Washington v. State: Temporal-Proximity Sufficiency & the Narrow Scope of Corpus Delicti in Delaware Concealed-Firearm Prosecutions Introduction On 2 July 2025 the Supreme Court of Delaware affirmed...

“More-Than-Enough” Predicate Felonies: Fulton v. State and the Narrow Path to Extraordinary Circumstances under Delaware Rule 35

Date: Jul 4, 2025

“More-Than-Enough” Predicate Felonies: Fulton v. State and the Narrow Path to Extraordinary Circumstances under Delaware Rule 35 Introduction Fulton v. State, No. 123, 2025, decided by the Supreme...