Huggins v. Benson
K24C-03-020 NEP
| Del. Super. Ct. | Sep 25, 2024Background
- Chad Huggins (Plaintiff) filed an action for ejectment and damages under 10 Del. C. § 6701, alleging he holds legal title to a property from which he is out of possession.
- Andrea Benson (Defendant) filed an amended answer and asserted counterclaims, conceding at oral argument that Huggins is the record owner.
- Plaintiff moved for partial summary judgment on the ejectment issue; Defendant moved to transfer her equitable counterclaims and defenses to the Delaware Court of Chancery.
- Plaintiff’s complaint included a deed evidencing legal title; Defendant did not challenge the validity of the title but asserted equitable grounds for possession.
- Superior Court had previously denied a motion to transfer the entire action, clarifying it couldn’t hear purely equitable claims but didn’t dismiss them.
- The Court granted Plaintiff’s motion for partial summary judgment (on ejectment) but emphasized the ruling is interlocutory, pending a future bench trial on damages and final order.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Entitlement to summary judgment on ejectment | Clearly holds title; no fact dispute | Possession claim based on equitable rights | Summary judgment granted (interlocutory) |
| Whether equitable defenses/counterclaims may be heard in ejectment | Not legal defenses; not for Superior Ct. | Equitable claims should be transferred | Transfer denied without prejudice |
| Effect of the interlocutory decision | Title resolved, but no immediate possession | Decision not final, so no transfer yet | Ruling is not final; both sides must wait |
| Jurisdiction over equitable counterclaims | Superior Court cannot hear them | Chancery should handle equitable counterclaims | Superior Court lacks jurisdiction now |
Key Cases Cited
- Moore v. Sizemore, 405 A.2d 679 (Del. 1979) (summary judgment standard in Delaware courts)
- Nelson v. Russo, 844 A.2d 301 (Del. 2004) (elements of ejectment action under Delaware law)
