Opinions Digested in Delaware Law Weekly for the Issue of
  July 23rd, 2008

 


DELAWARE SUPREME COURT

APPEALS

Procedure • Failure to Prosecute • Dismissal of Appeal

Abili v. Gemcraft Homes Delaware, Inc. DeFAX Case No. D63311 (Del. Supr. July 2, 2008).

The Supreme Court dismissed the instant appeal for failure to prosecute where appellants filed the appeal more than six months ago but took no further action to prosecute the appeal. Appeal dismissed.
 

FAMILY LAW

Parental Rights • Termination • Mother's Circumstances

Harper v. Division of Family Services DeFAX Case No. D63308 (Del. Supr. June 30, 2008).

Termination of mother's parental rights was proper where the record supported the Family Court's conclusion that mother's financial and cognitive limitations prevented her from protecting and providing for the child on a permanent and independent basis. Affirmed.
 

LANDLORD/TENANT LAW

Commercial Leases • Renewal • No-Waiver Provision • Past Defaults

Rehoboth Mall Limited Partnership v. NPC International, Inc. DeFAX Case No. D63312 (Del. Supr. July 2, 2008).

Given the prospective language used in the no-waiver provision of the lease, landlord could not deny tenant a second renewal of the lease where the tenant had committed no defaults during the first renewal period and where the defaults at issue happened during the initial lease term. Affirmed.
 


DELAWARE SUPERIOR COURT

CIVIL PRACTICE

Dismissal • Failure to Prosecute • Previous Neglect • 'Lemon Law' Case

Gregory v. Hyundai Motor America DeFAX Case No. D63313 (Del. Super. July 2, 2008).

Despite evidence of plaintiff's previous neglect, the Superior Court declined to dismiss this "Lemon Law" case at this time because Delaware favors giving the litigant his day in court, defendant did not suffer prejudice as the result of plaintiff's neglect and plaintiff had more recently shown diligence in pursuing the matter. Motion to dismiss denied.
 

INSURANCE LAW

Coverage • Excess D&O Policy • Fraud Exclusion • Applicability

AT&T v. Clarendon America Ins. Co. DeFAX Case No. D63307 (Del. Super. June 25, 2008).

Concluding that New York law applied in this dispute over an excess D&O policy's coverage for payment of the defense costs and settlement of securities litigation, the Superior Court determined that insurer was liable since the applicable fraud exclusion pertained only to adjudicated fraud. Motion for partial summary judgment granted.
 


INDUSTRIAL ACCIDENT BOARD

WORKERS' COMPENSATION

Causation • Carpal Tunnel Syndrome • Repetitive Stress • Medical Evidence

Schavelin v. Green Acres Health DeFAX Case No. D63309 (IAB April 23, 2008).

Claimant, a certified nursing assistant, failed to satisfy her burden of proof on causation where employer's expert gave persuasive testimony that he was familiar with claimant's job duties and that such duties could not have caused her carpal tunnel syndrome. Petition to determine compensation due denied.
 

WORKERS' COMPENSATION

Scope of Employment • Going-and-Coming Rule • Exception • Injury • Parking Lot

Russ v. Eagle Transportation DeFAX Case No. D63310 (IAB April 18, 2008).

Claimant's injury, suffered 20 minutes before her shift while in a parking lot technically owned by a business that leased space to employer, who condoned its employees' use of the lot, occurred during the course of claimant's employment since the premises- rule exception to the going-and-coming rule applied. Decision on course and scope of employment issued.