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Huggins v. Benson
K24C-03-020 NEP
| Del. Super. Ct. | Sep 25, 2024
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Background

  • 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)
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Case Details

Case Name: Huggins v. Benson
Court Name: Superior Court of Delaware
Date Published: Sep 25, 2024
Docket Number: K24C-03-020 NEP
Court Abbreviation: Del. Super. Ct.