Morabito v. Zigler

CourtSupreme Court of Delaware
DecidedJanuary 6, 2025
Docket101, 2024
StatusPublished

This text of Morabito v. Zigler (Morabito v. Zigler) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morabito v. Zigler, (Del. 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

ANTHONY MORABITO, § § No. 101, 2024 Plaintiff Below, § Appellant, § Court Below–Superior Court § of the State of Delaware v. § § C.A. No. N21C-08-219 RYAN ZIGLER, § § Defendant Below, § Appellee. §

Submitted: October 18, 2024 Decided: January 6, 2025

Before TRAYNOR, LEGROW, and GRIFFITHS, Justices.

ORDER

After considering the parties’ briefs and the record on appeal, it appears to the

Court that:

(1) The plaintiff-below, appellant, Anthony Morabito, sued the defendant-

below, appellee, Ryan Zigler, in the Superior Court for negligence, seeking damages

for injuries that Morabito sustained in a three-car motor vehicle collision.

(2) In February 2024, the case proceeded to a jury trial. The undisputed

evidence showed that: (i) Morabito, Zigler, and Erin Johnson were operating motor

vehicles in the left northbound lane of Route 1 near Christiana Mall during the early

morning hours of September 18, 2019; (ii) Morabito’s car was positioned directly behind Johnson’s vehicle and directly in front of Zigler’s vehicle, and (iii) the three

vehicles were traveling at roughly the same speed—somewhere between 50 and 65

miles per hour—when the traffic in front of them unexpectedly slowed or came to a

stop. Johnson testified that she brought her vehicle to a complete stop in response

to the traffic buildup. Morabito testified that he began to apply his brakes after he

saw Johnson’s brake lights illuminate, but he was struck from behind by Zigler and

pushed into the rear of Johnson’s car. Morabito told the jury that he then drifted past

Johnson’s car and came to a stop on the left shoulder of the highway. Zigler’s version

of events differed: he testified that when he saw Morabito’s vehicle swerve to the

right—into the adjacent line of traffic—he “locked up” his brakes and ran into

Johnson’s vehicle.1 Johnson testified that Zigler helped her out of her car, Zigler’s

car was the only one she saw behind her when she exited her vehicle, and she

assumed Zigler was operating the vehicle that hit hers.

(3) The jury also heard testimony from the investigating police officer,

Detective Michael Adkins. Detective Adkins prepared a police report in connection

with his investigation. In that report, Detective Adkins documented statements made

by the three drivers at the scene: (i) Johnson said that her car was struck from behind

by Morabito’s (not Zigler’s) vehicle; (ii) Morabito said that he was slowing down

and believed that he had ample time to come to a complete stop before hitting

1 App. to Answering Br. at B-0483.

2 Johnson’s car when he was struck from behind by Zigler; and (iii) Zigler said that

he thought that he collided with Johnson’s vehicle and did not remember hitting

Morabito’s vehicle. The only person who received a traffic citation as a result of

Detective Adkins’ investigation was Zigler, whom Detective Adkins cited for

following too closely. The jury also saw photographs of the damage that each of the

three vehicles sustained in the accident and heard extensive expert testimony about

the medical treatment Morabito received for a neck injury that was caused (or

aggravated) by the accident.

(4) At the close of the evidence, Morabito moved for a directed verdict “on

the issues of both liability and whether an injury was sustained during the accident

or caused by the accident.”2 The Superior Court denied the motion, finding that

there were disputed issues of material fact regarding liability and the severity of

Morabito’s injuries. Shortly after the jury began deliberating, it asked to see

Detective Adkins’ police report. Citing 21 Del. C. § 313(b), which prohibits the

introduction of an accident report as evidence in any trial arising out of an accident,

the Superior Court denied the jury’s request. After further deliberation, the jury

awarded Morabito $25,000 in damages and found that Morabito and Zigler were

each 50% at fault for the accident. In accordance with the jury’s findings, the

2 Id. at B-0516.

3 Superior Court entered a judgment in favor of Morabito in the amount of $12,500.

Morabito appealed.

(5) On appeal, Morabito’s overlapping and at times confusing arguments

may be fairly summarized as follows: (i) the trial court improperly hindered the

jury’s ability to hear Detective Adkins’ testimony and review his accident report; (ii)

Morabito should have been allowed to testify as an accident-reconstruction expert

witness; (iii) the jury verdict form was defective; (iv) the evidence did not support

Zigler’s version of events, and the trial court erred by denying Morabito’s motion

for a directed verdict; and (v) the jury instructions were deficient.3 After careful

review, we affirm the Superior Court’s judgment.

(6) As a preliminary matter, we note that Morabito did not provide the

Court with the trial transcript for the Court’s review. An appellant has the burden

of providing “such portions of the trial transcript as would be necessary to provide

this Court with a fair and accurate account of the context in which the claim[s] of

error occurred.”4 Ordinarily, an appellant’s failure to do so would preclude appellate

3 Morabito also asserts claims of professional misconduct against defense counsel and his own attorney. These arguments are outside the scope of this appeal. Moreover, it is clear from Morabito’s submissions that he has reported, or intends to report, the alleged misconduct to the Office of Disciplinary Counsel, the entity responsible for investigating allegations of professional misconduct. 4 Fultz v. State Farm Mut. Auto. Ins. Co., 966 A.2d 347, 2009 WL 189143, at *1 (Del. Jan. 16, 2009) (TABLE).

4 review of his claims.5 Here, however, the Court is able to review Morabito’s claims

because Zigler provided a copy of the trial transcript to the Court.

(7) The record reflects that toward the end of Morabito’s attorney’s re-

direct examination of Detective Adkins, the courthouse fire alarm sounded.

Morabito claims that Detective Adkins’ testimony was cut short by the need to

evacuate the courthouse. Morabito also argues that the jury should have been

permitted to review Detective Adkins’ police report and that the Superior Court

should have “read back” Detective Adkins’ testimony to the jury. The gist of

Morabito’s claims regarding Detective Adkins’ testimony and police report is that

the jury should have heard that Zigler was speeding at the time of the accident. We

review Morabito’s claims regarding this point for plain error because they were not

raised below.6

(8) Plain error is error that is “so clearly prejudicial to substantial rights as

to jeopardize the fairness and integrity of the trial process.”7 There is no such error

here. First, it is clear from the record that Morabito had ample opportunity to elicit

from Detective Adkins any evidence that Morabito deemed necessary to support his

negligence claim against Zigler, including the fact that Detective Adkins issued

5 Id. 6 Del. Supr. Ct. R. 8. 7 Baker v. State, 906 A.2d 139, 150 (Del. 2006) (internal quotation marks and citation omitted).

5 Zigler a traffic citation for following too closely. Moreover, the trial transcript

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Related

Fultz v. State Farm Mutual Automobile Insurance Company
966 A.2d 347 (Supreme Court of Delaware, 2009)
Estate of Eller v. Bartron
31 A.3d 895 (Supreme Court of Delaware, 2011)
Baker v. State
906 A.2d 139 (Supreme Court of Delaware, 2006)

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