Baize v. Vincent

Summary

The Delaware Supreme Court affirmed a Superior Court judgment entered after a jury found Joseph and Danielle Vincent not liable for malicious prosecution and defamation. The court held that Baize’s evidentiary and subpoena arguments were not fairly presented below and did not warrant review under the interests-of-justice exception to Supreme Court Rule 8.

Holdings

1. The court would not consider the argument because Baize did not present it to the trial court and did not satisfy the demanding interests-of-justice exception to Supreme Court Rule 8.
2. The court would not consider the challenge because Baize did not object to the subpoena being quashed in the trial court and did not satisfy the interests-of-justice exception.

Questions Presented

1. Whether the Supreme Court should consider Baize's argument that the expungement motion was admissible because it contained admissions by a party opponent when that argument was not presented to the trial court.
2. Whether the Supreme Court should consider Baize's challenge to the quashing of his subpoena when he did not object to the order in the trial court.
3. Whether the interests-of-justice exception to Delaware Supreme Court Rule 8 warranted review of either unpreserved claim.

Disposition

affirmed