Delphi Petroleum, Inc. v. Magellan Terminal Holdings, L.P., 47, 2017

Delphi purchased storage services from Magellan under Terminalling Agreements (2005 and 2011) for petroleum products; contracts required Magellan to heat heavy‑oil tanks and Delphi to reimburse fuel costs plus 18%.
Magellan measured tank‑heating fuel with meters (2005–2010) despite a 2005 agreement reference to gauges; Delphi alleged overbilling for heating fuel.
On the eve of trial Magellan voluntarily refunded $421,603 for 2007–2010 tank‑heating charges; trial found additional overcharges for 2005–2006 totaling $114,547, for a total overcharge award of $536,150.
The Superior Court awarded statutory pre‑judgment interest on the full $536,150 beginning September 25, 2013 (date Delphi made a large payment to Magellan); Delphi challenged the choice of start date.
During negotiation of the 2011 agreement, Delphi sought to add “Receipts and” to a truck delivery clause; Magellan (via Beall) emailed agreement to the change. Delphi later sought to deliver product to the terminal by truck; Magellan required terminal modifications and fees, which Delphi declined, and sued for breach and fraud based on the pre‑contract email.
Trial court found Magellan committed fraud by Beall’s email and awarded $2,500 (mitigated by cost of modification); trial court also held the contract unambiguous as not permitting deliveries to the terminal by truck (a ruling Delphi did not appeal).

Issue	Plaintiff's Argument	Defendant's Argument	Held
When should pre‑judgment interest run on the tank‑heating overcharges?	Delphi: interest should run from the dates Delphi paid the invoices that contained the overcharges (i.e., payment dates 2005–2010).	Magellan: interest should run from Sept. 25, 2013 because Delphi’s account was net negative before then, and earlier interest would be a windfall.	Court (Del. Supreme Court): Reversed Superior Court; interest runs from the dates Delphi paid the overcharged invoices. Case remanded to determine exact dates/amounts.
Whether Magellan fraudulently induced Delphi to sign the 2011 agreement by email accepting truck‑receipt language while knowing Delphi could not deliver by truck	Delphi: Beall’s email falsely represented Magellan’s agreement and Magellan had a duty to disclose that the terminal could not accept truck deliveries; Delphi relied and was induced.	Magellan: The email merely accepted proposed contractual language; no affirmative duty to disclose; contract was unambiguous and did not permit deliveries to the terminal by truck.	Court: Reversed fraud finding. Beall’s email was not a false representation and no duty to disclose existed; trial court erred in finding fraud.

Brandywine Smyrna, Inc. v. Millennium Builders, LLC, 34 A.3d 482 (Del. 2011) (explaining purposes of prejudgment interest)
Moskowitz v. Wilmington, 391 A.2d 209 (Del. 1978) (prejudgment interest accrues from date payment was due)
Levitt v. Bouvier, 287 A.2d 671 (Del. 1972) (standard of appellate review for bench trial findings)
Stephenson v. Capano Dev., Inc., 462 A.2d 1069 (Del. 1983) (elements of common law fraud require a false representation)
Prairie Capital III, L.P. v. Double E. Holding Corp., 132 A.3d 35 (Del. Ch. 2015) (discussing when an affirmative duty to disclose arises in business transactions)