State v. Cabela's Inc.

CourtSuperior Court of Delaware
DecidedSeptember 30, 2024
DocketN23M-06-118 JRJ
StatusPublished

This text of State v. Cabela's Inc. (State v. Cabela's Inc.) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Cabela's Inc., (Del. Ct. App. 2024).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

STATE OF DELAWARE, ex rel. ) KATHLEEN JENNINGS, Attorney ) General of the State of Delaware, ) ) Petitioner, ) ) v. ) C.A. N23M-06-118 JRJ ) CABELA’S INC., BPS DIRECT, LLC ) (d/b/a BASS PRO SHOPS), GREAT ) OUTDOORS GROUP, LLC, and ) GREAT AMERICAN OUTDOORS ) GROUP, LLC, ) ) Respondents. )

Date Submitted: July 18, 2024 Date Decided: August 8, 2024 Date Issued: August 20, 2024 Date Corrected: September 30, 2024

Upon Consideration of Petitioner’s Motion to Enforce Subpoena Duces Tecum, GRANTED Upon Consideration of Respondents’ Motion to Quash, DENIED

MEMORANDUM OPINION

 This written decision follows the Court’s August 8, 2024 Oral Ruling on the motions. The title

page has been corrected to (1) reflect the “Date Decided” is August 8, not August 9, and (2) the date of the Oral Ruling is August 8, not August 9. Evelyn H. Brantley, Esquire, Owen P. Lefkon, Esquire, Christian D. Wright, Esquire, Deputy Attorneys General, Delaware Department of Justice, Wilmington, Delaware. Attorneys for Petitioner. Francis G.X. Pileggi, Esquire, Andrew A. Ralli, Esquire, Lewis Brisbois Bisgaard & Smith LLP, Wilmington, Delaware, Alexander D. MacMullan, Esquire, Lewis Brisbois Bisgaard & Smith LLP, Wayne, Pennsylvania (pro hac vice). Attorneys for Respondents.

JURDEN, P.J. I. INTRODUCTION This civil action arises from an investigation initiated by the Department of

Justice (“DOJ”) after it received information regarding significant quantities of

ammunition stolen from a Cabela’s sale floor.1 The DOJ seeks to investigate, among

other things, Cabela’s’ loss prevention policies.2 On March 3, 2023, the DOJ issued

a Subpoena Duces Tecum (the “Subpoena”) to Respondents (collectively

“Cabela’s”).3 In response to the Subpoena, Cabela’s produced 2 documents–a one-

page job description and a heavily redacted one-page “loss data” report–and 53

pages of objections. As a result, the DOJ filed this Motion to Enforce Subpoena

Duces Tecum (“Motion to Enforce”),4 and Respondents, in turn, filed their

Opposition5 and a Motion to Quash the Revised Subpoena (“Motion to Quash”).6

For the reasons set forth below, the Petitioner’s Motion to Enforce is GRANTED,

and Respondents’ Motion to Quash is DENIED.

1 Petitioner’s Mot. to Enforce Subpoena Duces Tecum ¶ 3, Trans. ID 70247906 (June 23, 2023) (hereinafter “Mot. to Enforce”). 2 Id. 3 Id. ¶ 6. 4 See id. 5 Respondents’ Answering Br. in Opp’n of Petitioner’s Mot. to Enforce, Trans. ID 72769895 (Apr. 17, 2024) (hereinafter “Opp’n to Mot. to Enforce”). 6 Respondents’ Opening Br. in Support of Mot. to Quash, Trans. ID 72769858 (Apr. 17, 2024) (hereinafter “Mot. to Quash”). II. BACKGROUND

On February 15, 2023, the DOJ issued a Subpoena Duces Tecum to

Respondents citing possible violations of “10 Del. C. § 3930 and/or other laws.”7

Following the issuance of the subpoena, the parties engaged in discussions which

resulted in the DOJ withdrawing the subpoena and issuing a second subpoena on

March 3, 2023 with a return date of March 17, 2023.8 The March 3 Subpoena, in

response to Cabela’s’ request for elaboration concerning the “other laws” referenced

in the first subpoena, cites possible violations of the following statutes: 10 Del. C. §

3930, 10 Del. C. ch. 71, 11 Del. C. §§ 603, 604, 1301, 1322.9 The Subpoena includes

an affidavit from Special Investigator, Patrick L. Malone (“Investigator Malone”)

that details an interview Investigator Malone had with a witness concerning large

quantities of ammunition being stolen from the Cabela’s Christiana store.10

On April 3, 2023, the parties entered into a Confidentiality Agreement

pursuant to which Cabela’s produced the two documents referenced above.11 On

7 See Mot. to Enforce, Ex. B. 8 Mot. to Enforce ¶ 6. 9 Id.; see Mot. to Enforce, Ex. C (hereinafter “Subpoena”). 10 See Mot. to Enforce, Ex. A (hereinafter “Malone’s Aff.”). 11 See supra Section I; Mot. to Enforce ¶ 8. On July 22, 2024, Cabela’s provided a copy of this production to the Court for in-camera review. See Letter, Trans. ID 73741079 (July 22, 2024). One page is a job description, and the other is a lone percentage of sales. June 6, 2023, Cabela’s responded to the March 3 Subpoena by providing 53 pages

of objections.12

III. PROCEDURAL HISTORY

On June 23, 2023, the DOJ filed the instant Motion to Enforce.13 On July 21,

2023, Cabela’s removed the action to U.S. District Court for the District of Delaware

(“USDC”), challenging the constitutionality of 10 Del. C. § 3930.14 On January 24,

2024, the USDC remanded the matter back to the Court, finding there was no federal

jurisdiction regarding the constitutionality of 10 Del. C. § 3930 and awarding the

DOJ attorney’s fees and costs.15

Following a February 23, 2024, status conference with the Court,16 the parties

briefed the instant Motions and a motion for a protective order,17 and the Court held

a hearing on all three motions on July 18, 2024.18

12 Mot. to Enforce ¶ 10; Mot. to Enforce, Ex. D (hereinafter “Respondents’ Objections”). The DOJ extended the March 17 due date in the Subpoena to June 6, 2023. 13 Mot. to Enforce. 14 Notice of Removal, Trans. ID 70456473 (July 21, 2023). 15 See Mem. Op. Granting Remand, Trans. ID 71961505 (Feb. 6, 2024); see Delaware ex rel. Jennings v. Cabela’s Inc., 2024 WL 263296 (D. Del. Jan. 24, 2024). 16 Judicial Action Form, Trans. ID 7212558 (Feb. 23, 2024). 17 Motion for Protective Order, Trans. ID 72770537 (Apr. 17, 2024). During Oral Argument the Court directed the parties to further confer regarding the protective order, as such it will not be addressed here, and is still under advisement. 18 Judicial Action Form, Trans. ID 73721346 (July 18, 2024). IV. PARTIES’ CONTENTIONS

A. The DOJ’s Motion to Enforce

The DOJ asserts that pursuant to 29 Del. C. §§ 2504(4) and 2508(a), the

Attorney General (“AG”) has the power to “investigate a crime and other matters of

public concern similar to the powers granted [to] a grand jury[,]”19 and the Subpoena

is enforceable because it meets the three-part test set forth in In re Blue Hen Country

Network (“Blue Hen”).20

Cabela’s argues the Subpoena is unenforceable because (i) “the true basis for

[the] DOJ’s subpoena, SB 302, is unconstitutional,”21 (ii) “the ancillary criminal

statutes” do not apply to Cabela’s and “are unreasonable in scope,”22 (iii) the support

for the Subpoena is “sensational and implausible,”23 and the DOJ has not provided

a “sufficient explanation as to why they are entitled to each category of document

they seek.”24

B. Cabela’s’ Motion to Quash

Cabela’s moves to quash the DOJ’s Subpoena on three bases: “(i) the statute

under which the purported investigation is being conducted is unconstitutional,

rendering the [S]ubpoena invalid, (ii) the remaining criminal statutes used as a basis

19 Mot. to Enforce ¶ 11. 20 See 314 A.2d 197, 201 (Del. Super. 1973); Mot. to Enforce ¶¶ 11-12. 21 Opp’n to Mot. to Enforce 11. 22 Id. at 13. 23 Id. 24 Id. for the investigation have no applicability to Cabela’s, [or] the alleged investigation

and render the [S]ubpoena unreasonable, and (iii) the allegations utilized to launch

the investigation are baseless sensationalism, [and] contradicted by law

enforcement’s own actions in declining to prosecute the source.”25

The DOJ counters that Cabela’s does not have standing to pursue a

constitutional challenge to 10 Del.

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State v. Cabela's Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cabelas-inc-delsuperct-2024.