American Civil Liberties Union of Delaware v. The Town of Fenwick Island

Superior Court of Delaware·Decided May 26, 2026·No. S25C-12-003 CAK·Published

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

AMERICAN CIVIL LIBERTIES : UNION OF DELAWARE, :

:

Plaintiff, : C.A. No. S25C-12-003 CAK :

v. :

:

THE TOWN OF FENWICK ISLAND, :

:

Defendant. :

:

Submitted: May 21, 2026

Decided: May 26, 2026

UPON DEFENDANT’S MOTION TO DISMISS Granted

MEMORANDUM OPINION AND ORDER

Andrew Bernstein, Esquire, American Civil Liberties Union, 100 W. 10th Street #706, Wilmington, DE 19801; Attorney for Plaintiff.

Luke W. Mette, Esquire, Joseph Grubb, Esquire, Mark A. Denney, Esquire, Brockstedt Mandalas Federico, 1413 Savannah Road, Suite 1, Lewes, DE 19958; Attorneys for Defendant.

KARSNITZ, R.J.

INTRODUCTION

What is a “person?” When one cuts to the heart of this case, that is the question. The philosopher Diogo Joao Baptista Gomes of Brachtenbach, Luxembourg has answered the question as follows:

The question of what a person is isn’t exclusive to philosophy.

Consequently, there are many answers. In a physiological and biological context, a person is a human being with certain essential physiological and biological characteristics.

Legally, the answer is broader. According to the law, a person is anyone or anything that can initiate and be subject to legal proceedings. By this conception, any adult, corporation, or institution is a person, but a minor is not a person, a fetus is not a person, and a humanoid robot … is not a person. This highlights that legal personhood is dependent solely on legal recognition.

In this sense a legal person is like a political person. A political person is anyone who has citizenship. The humanoid robot … has been granted citizenship in Saudi Arabia, which demonstrates the contingency of political personhood. Moreover, there is no shortage of people who have had their citizenship stripped, whose political personhood is therefore non-existent.

In philosophy, a human being is a person if they’re a moral agent, making moral judgements and taking moral actions. Metaphysically, the set of criteria for personhood include rationality or logical reasoning, consciousness, self-consciousness, use of language, ability to initiate action, moral agency, and intelligence. The humanoid robot or a young child may meet sufficient criteria here. A corporation or institution does not.

In practice, however, only legal and political personhood are of significance, and these are contingent on recognition by political or legal institutions. However, metaphysical and moral personhood provide an intellectual foundation upon which to discuss legal and

political personhood. Therefore, I suggest that a person in its full sense – both theoretically and practically – is a metaphysical and moral being with legal and political recognition. The former is sufficient for theoretical personhood and the latter is sufficient for practical personhood, and both are necessary for full personhood. [emphasis supplied]1

In 2008, the Delaware General Assembly amended the Charter of the Town of Fenwick Island (“Fenwick”), a small coastal community,2 to allow Fenwick to expand its voter registration rolls to allow individuals to cast votes on behalf of trusts, limited liability companies, partnerships, and corporations that own property in Fenwick. Today, the overwhelming majority of legal entity property owners in Fenwick registered to vote, and on whose behalf votes are cast, are trusts.

In this action, the American Civil Liberties Union of Delaware, a corporation (“Plaintiff”), challenges these provisions, asserting that Fenwick’s Charter violates the Elections Clause of the Delaware Constitution by way of “vote dilution;” i.e., the dilution of votes of human beings by votes of artificial legal entities.

PROCEDURAL BACKGROUND

Plaintiff filed its Complaint on December 4, 2025, seeking (1) a declaratory judgment that “non-human artificial entity voting” in Fenwick’s municipal elections violates the Elections Clause of the Delaware Constitution, and (2) an order

1 Philosophy Now, Issue 149, April/May 2022.

2 76 Del. Laws, ch. 363 (2008).

permanently enjoining Fenwick from “counting ballots cast by non-human artificial entities” in upcoming3 and future Fenwick elections. By way of a Stipulated Order dated January 14, 2026, Defendant’s motion to dismiss (the “Motion”) under Superior Court Civil Rule 12(b), and opening brief in support thereof, were due on or before February 16, 2026. Defendant filed the Motion under Superior Court Civil Rules 12(b)(1) and 12(b)(6), together with its opening brief in support thereof, on February 16, 2026. Plaintiff filed its Answering Brief on March 2, 2026. Defendant filed its Reply brief on March 19, 2026. I held oral argument on the Motion on May 4, 2026. In a May 6, 2026, letter, Plaintiff requested to take a deposition of a Fenwick official, but also stated that, from Plaintiff’s perspective, the Motion had been fully briefed and argued and was ripe for decision without regard to the deposition. The tight timeline made it imperative for the resolution of the matter ahead of Fenwick’s next scheduled election. On May 21, 2026, I clarified that Plaintiff had my permission to take the deposition, and that I was not awaiting the deposition to issue my decision on the Motion. This is my decision on the Motion.

BASIS FOR DECISION

In its Motion, Defendant seeks dismissal on four grounds under Superior Court Civil Rules 12(b)(1) and 12(b)(6): (1) Plaintiff lacks standing to bring this Complaint, (2) I lack subject matter jurisdiction as a court of law to issue the

3 The next Fenwick election is scheduled for August 1, 2026.

injunction Plaintiff seeks in the Complaint, (3) Plaintiff has failed to join other Delaware municipalities which are necessary parties to this litigation, and (4) the Complaint fails to state a claim upon which relief can be granted. Even if I were to decide all of the first three issues in favor of Plaintiff, if I decide the fourth issue against Plaintiff, that decision is dispositive of the case. I express no opinion either way as to the first three issues. Rather, as a matter of judicial economy, I consider only the fourth issue, which is dispositive.

OVERVIEW OF CERTAIN PROVISIONS OF THE DELAWARE CONSTITUTION AND CODE AND THE CHARTER AND CODE OF FENWICK

The Elections Clause of the Delaware Constutuion states, in its entirety: “All elections shall be free and equal.”4 The clause is eloquent in its simplicity but lacks specific direction in application.

Under Delaware’s “Home Rule” statute for municipalities, the State of Delaware defines “qualified voters” to mean “those persons who, under the terms of a municipal charter, shall be authorized to vote in elections within that municipal corporation.”5 For all Delaware municipalities other than the City of Wilmington, Delaware by statute has set forth voter eligibility criteria as follows: “(a) Voter eligibility shall

4 DEL CONST. art. I, § 3.

5 22 Del. C. § 801(4).

be as specified within the town charter; provided however, that in no event shall a municipality impose a durational residency requirement in excess of 30 days.”6 Fenwick was incorporated in 1953 by an act of the Delaware General Assembly.7 Like other Delaware municipalities, Fenwick has amended its charter by acts of the General Assembly “so as to have and assume all powers which, under the Constitution of the State, it would be competent for the General Assembly to grant by specific enumeration and which are not denied by statute.”8 Fenwick’s Charter provides that bona fide residents who are registered to vote “shall have one vote.”9 Nonresident voting in Fenwick has been authorized since Fenwick was incorporated in 1953. 10 In 2008, the General Assembly amended Fenwick’s Charter11 to provide, in relevant part, what remains today as Section 9A (2-4) (emphasis added):

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American Civil Liberties Union of Delaware v. The Town of Fenwick Island, (Del. Ct. App. 2026).

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