The Delaware Call v. Delaware State Police

CourtSuperior Court of Delaware
DecidedSeptember 4, 2025
DocketK24A-02-002 JJC
StatusPublished

This text of The Delaware Call v. Delaware State Police (The Delaware Call v. Delaware State Police) 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
The Delaware Call v. Delaware State Police, (Del. Ct. App. 2025).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

ROBERT E. VANELLA, on behalf of : THE DELAWARE CALL, : : C.A. No. K24A-02-002 Appellant, : : v. : : CHRISTINA DURAN, in her official : Capacity as FOIA Coordinator for : DELAWARE DEPARTMENT OF : SAFETY AND HOMELAND : SECURITY, DELAWARE STATE : POLICE, : : Appellee. :

Submitted: June 25, 2025 Decided: September 4, 2025

OPINION

Dwayne Bensing, Esquire, and Jared Silberglied, Esquire, ACLU Foundation of Delaware, Inc., Wilmington, Delaware, Attorneys for the Appellant.

Joseph Handlon, Deputy Attorney General, State of Delaware Department of Justice, Wilmington, Delaware, Attorney for the Appellee.

CLARK, R.J. 1 Appellant Robert E. Vanella, on behalf of The Delaware Call (hereinafter, referenced interchangeably as “Mr. Vanella” or “Delaware Call”) made a Delaware Freedom of Information Act (“FOIA” or the “Act”) request for records from the Delaware State Police (“DSP”). DSP declined to produce the requested records. Mr. Vanella then petitioned the Chief Deputy Attorney General (hereinafter, the “Chief Deputy”) to challenge DSP’s denial, which the Chief Deputy sustained. Mr. Vanella then appealed the Chief Deputy’s adverse decision to the Superior Court. In that appeal, he prevailed, in part, for the reasons explained in the Court’s 2024 Opinion.1 Mr. Vanella now seeks over one hundred thousand dollars in attorneys’ fees and costs on behalf of Delaware Call for what he alleges to have been a successful appeal. To this end, he contends that Delaware Call meets the definition of a “successful plaintiff of any action brought under [Section 10005]” and is therefore entitled to fee recovery under 29 Del. C. § 10005(d) (hereinafter, “Subsection 10005(d)” or simply “Subsection (d)”). To date, no Delaware court has determined whether a prevailing appellant can recover attorneys’ fees under the Act. Delaware’s FOIA statute, codified at 29 Del. C. Ch. 100, provides two separate and distinct mechanisms (referenced interchangeably hereafter as two separate “mechanisms,” “routes,” or “tracks”) to challenge alleged FOIA violations. The first mechanism permits a citizen to do so by filing a lawsuit. The second mechanism, at issue in this case, involves first filing an extrajudicial petition for review by the chief deputy. Then, either party may appeal the chief deputy’s decision to the Superior Court with some qualifications not relevant to Mr. Vanella’s motion. The first of these two mechanisms—a FOIA lawsuit—unquestionably permits fee recovery under Subsection 10005(d). The availability of potential cost and fee

1 Vanella on Behalf of Delaware Call v. Duran, 2024 WL 5201305 (Del. Super. Dec. 23, 2024). 2 recovery under the second mechanism—the petition and appeal route—is the subject of this decision. The parties’ briefing and argument approach this motion in two ways. First, they dispute whether Subsection (d) permits an award of attorneys’ fees in an appeal under any circumstances. Second, they dispute whether Delaware Call achieved “success” in the underlying appeal, which would be necessary for fee recovery. Here, the Court need only address the threshold question—namely, whether Delaware’s FOIA statute permits a successful appellant to recover attorneys’ fees. The controlling provision, Subsection 10005(d), does not facially answer the question. It is ambiguous on the point because one reasonable reading would permit fee recovery for this on-the-record appeal, while another would not. When resolving that ambiguity, FOIA does not permit recovery of fees for Delaware Call’s on-the- record appeal, however. It does not because (1) Subsection (d) does not plainly say so, (2) fee recovery must be strictly construed against awarding costs and fees because of the State’s sovereign immunity, and (3) the intrinsic and extrinsic aids of statutory construction do not demonstrate the General Assembly’s intent to permit the recovery. As a result, Delaware Call’s motion for fees and costs must be denied.

I. PROCEDURAL BACKGROUND Delaware Call submitted a FOIA request to DSP. DSP denied it in its entirety.2 When doing so, it invoked several exceptions to FOIA.3 Delaware Call then petitioned the Chief Deputy pursuant to 29 Del. C. §§ 10005(b) and (e) to challenge DSP’s denial.4 The Chief Deputy considered the parties’ positions and determined that DSP had not violated FOIA, and that Delaware Call’s requests were appropriately denied because DSP properly invoked a FOIA exemption as to all of

2 Id. at *1. 3 Id. 4 Id. at *2. 3 Delaware Call’s requests.5 Delaware Call then appealed the Chief Deputy’s decision to the Superior Court.6 On appeal, this Court affirmed the Chief Deputy’s decision, in part, and reversed it, in part. The Court found that DSP had correctly invoked FOIA’s exemptions to some fields of Delaware Call’s request but incorrectly as to others.7 As a result, the Court ordered DSP to produce the non-exempt material.8 Following the Court’s order, the parties stipulated to Mr. Vanella’s “Motion to Set Date to File a Motion for Attorneys’ Fees and Costs” and the Court approved the order which would have been an appropriate procedural path has this been a Federal FOIA appeal.9 Thereafter, Mr. Vanella appealed the Superior Court’s decision.10 The Supreme Court dismissed the appeal as interlocutory, however.11 Mr. Vanella then filed the present motion for fees and costs which the Court now considers. After briefing, the Court heard oral argument on the motion on April 11, 2025, and reserved decision.12 Subsequently, by letter order, the Court requested the

5 Id. 6 C.A. No. K24A-02-002. 7 Vanella, 2024 WL 5201305, at *15. 8 Id. Delaware Call requested the following fields of information: (1) the names of certified DSP troopers, (2) the current salaries of troopers, (3) the current employing State agency and rank of each certified trooper, (4) the past employers and job titles of each certified trooper, (5) troopers’ resumes, (6) a list of formerly certified troopers and current status, and (7) the age, sex, and race of each certified DSP trooper. Of those fields, the Court ordered production of the names of all currently employed DSP troopers, their ranks, and their salary information. 9 D.I. 30; See McDonnell v. United States, 4 F.3d 1227, 1236 (3d Cir. 1993) (recognizing that even if a motion for attorneys’ fees is still pending at the trial court level under Federal FOIA, such motion does not bar an appellate court’s jurisdiction to consider the substance of the appeal so as to better avoid piecemeal litigation); see also Cornish F. Hitchcock, 1 Guidebook to the Freedom of Information and Privacy Acts § 17.5 (updated May 2025) (explaining that in federal FOIA practice, “[a]ttorney fees are normally reserved for the conclusion of a FOIA case. Even when the underlying action has been decided, a petition for attorney fees survives independently . . .. The fact that an attorney fees petition is pending, moreover, has been found not to preclude appellate review of the [trial] court’s decision on the merits.”) (internal quotations and citations omitted). 10 Notice of Appeal (D.I. 31). 11 Vanella on behalf of Delaware Call v. Duran, 2025 WL 733246 (Del. Mar. 7, 2025). 12 D.I. 39. 4 parties’ supplemental positions regarding whether they believed Subsection 10005(d) to be ambiguous.13 The Court also requested the parties’ positions regarding the legislative history of formerly designated Senate Bill No. 103 of the 134th General Assembly (hereinafter, the “1988 Amendment”) – which was the FOIA Amendment that added the fee recovery provision.14

II. THE PARTIES’ CONTENTIONS The parties dispute whether FOIA permits a citizen to recover attorneys’ fees after a successful appeal of a chief deputy’s decision denying a FOIA request.

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The Delaware Call v. Delaware State Police, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-delaware-call-v-delaware-state-police-delsuperct-2025.