Walls v. Pressley
CourtSuperior Court of Delaware
Date FiledAugust 5, 2026
DocketK24A-12-002 NEP
StatusPublished
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Full Opinion
IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
JOSEPH M. WALLS, )
)
Plaintiff, )
v. )
)
) C.A. No. K24A-12-002 NEP
WALLACE E. PRESSLEY, III, )
)
Defendant. )
)
)
Submitted: July 15, 2026
Decided: August 5, 2026
ORDER
Upon Plaintiff’s Motion for Reargument
DENIED
Plaintiff Joseph M. Walls (“Plaintiff”) has filed a “Motion for Reargument of
Adams v. Carney Denial Decision.” For the reasons that follow, Plaintiff’s motion
is DENIED.
1. On July 1, 2026, the Court held a status conference concerning
Plaintiff’s requests to issue subpoenas after the close of discovery.1 Although the
Court permitted Plaintiff to request issuance of the subpoenas, it ruled that, because
the subpoenas were not properly requested before discovery closed and the resulting
delay prejudiced the Defendants, Plaintiff could not use any information obtained
1
D.I. 133. Citations in the form of “D.I. ___” refer to docket items.
through the subpoenas to oppose Defendant’s forthcoming motion for summary
judgment.2
2. Immediately after the Court announced its ruling, Plaintiff orally
moved for the Court to recuse itself and withdraw from the case under Adams v.
Carney.3 The Court denied the oral motion as without merit.
3. On July 7, 2026, Plaintiff filed the instant Motion for Reargument,
contending that the political-balance provisions governing this judicial officer’s
2017 appointment were unconstitutional and therefore rendered his appointment,
and by extension, his rulings in this action, invalid.4 Plaintiff asks that this judicial
officer recuse himself, that another judge vacate his prior rulings, and that the matter
be reassigned.5
4. A motion for reargument “provide[s] the trial court with an opportunity
to reconsider a matter and to correct any alleged legal or factual errors prior to an
appeal.”6 Rule 59(e) of the Delaware Superior Court Civil Rules governs a motion
for reargument and requires the motion to be filed within five days of the decision.7
A motion for reargument “will be granted ‘only if the Court has overlooked
precedent or legal principles, or the Court has misapprehended the law or the facts
such as would have changed the outcome of the underlying decision.’”8 The moving
2
Id.
3
See Adams v. Carney, 2017 WL 6033650, at *1 (D. Del. Dec. 6, 2017), clarified by 2018 WL
2411219 (D. Del. May 23, 2018), aff'd in part, rev'd in part sub nom. Adams v. Gov. of Delaware,
922 F.3d 166 (3d Cir. 2019), reversed, vacated and remanded sub nom. Carney v. Adams, 592
U.S. 53 (2020).
4
Mot. for Reargument of Adams v. Carney Denial Decision 3 (D.I. 136).
5
Id. at 4.
6
Bowen v. E.I. duPont de Nemours & Co., Inc., 879 A.2d 920, 921 (Del. 2005) (citing Hessler,
Inc. v. Farrell, 260 A.2d 701, 702 (Del. 1969)).
7
Del. Super. Ct. Civ. R. 59(e).
8
Snipe v. Boulden Servs., LLC, 2024 WL 550095, at *1 (Del. Super. Feb. 8, 2024) (quoting State
v. Brinkley, 132 A.3d 839, 842 (Del. Super. 2016)).
2
party bears a “heavy burden” to demonstrate such grounds.9 A motion for
reargument should not be used for raising new arguments or rehashing arguments
previously made.10 “Such tactics frustrate the efficient use of judicial resources,
place the opposing party in an unfair position, and stymie ‘the orderly process of
reaching closure on the issues.’”11
5. In support of reargument, Plaintiff relies principally on the original
2017 ruling by the United States District Court for the District of Delaware in Adams
v. Carney and alleges that this judicial officer’s appointment violated the First and
Fourteenth Amendments of the United States Constitution because he was appointed
to fill a seat reserved for a Republican under Article IV, § 3 of the Delaware
Constitution.12 Plaintiff further alleges that, because the Adams litigation was
pending at the time, this judicial officer knew or should have known of the alleged
defect in his appointment.13 Plaintiff does not mention that the Third Circuit’s partial
affirmance of the District Court’s clarified decision was ultimately reversed by the
United States Supreme Court.14
6. The Court need not reach, and does not decide, the constitutional
premise underlying Plaintiff’s request. The instant motion identifies no precedent,
legal principle, or material fact that the Court overlooked or misapprehended when
9
Milton v. Alfred I. duPont Hosp. for Children, 2024 WL 4524850, at *1 (Del. Super. Oct. 17,
2024).
10
Bd. of Managers of the Del. Crim. Just. Info. Sys. v. Gannett Co., 2003 WL 1579170, at *1 (Del.
Super. Jan. 17, 2003); Feenix Payment Sys., LLC v. Blum, 2024 WL 3424038, at *1 (Del. Super.
July 16, 2024); Kennedy v. Invacare Corp., 2006 WL 488590, at *1 (Del. Super. Jan. 31, 2006).
11
Feenix, 2024 WL 3424038, at *1 (quoting Plummer v. Sherman, 2004 WL 63414, at *2 (Del.
Super. Jan. 14, 2004)).
12
Mot. for Reargument of Adams v. Carney Denial Decision 3 (D.I. 136).
13
Id.
14
See supra note 3.
3
it denied Plaintiff’s oral motion.15 Accordingly, Plaintiff has not established grounds
for reargument.
7. Additionally, the Court notes that Plaintiff did not raise this challenge
in any pleading filed between the commencement of this action in December 2024
and the July 1, 2026, status conference. Plaintiff instead asserted his motion for the
first time orally at the conclusion of that conference, immediately after the Court
announced a ruling adverse to him. Notwithstanding Plaintiff’s failure to raise this
argument at any point prior to the status conference, and his apparent motivation for
doing so in response to the Court’s ruling, the instant Motion for Reargument merely
repackages Plaintiff’s oral motion and cites no authority the Court had not already
considered when it issued its denial.
8. Rule 59(e) is not a vehicle for presenting available arguments belatedly
or rehashing a position the Court has already rejected. Plaintiff has therefore failed
to carry the heavy burden required for reargument.16
9. Given that Plaintiff has not shown that the Court overlooked
controlling precedent or legal principles or misapprehended any material law or fact,
his Motion for Reargument must be denied. The Court declines to revisit its denial
of Plaintiff’s oral motion or disturb its prior rulings.
WHEREFORE, Plaintiff’s Motion for Reargument is hereby DENIED.
IT IS SO ORDERED.
15
Plaintiff has advanced no claim of personal bias or prejudice on the part of this judicial officer.
See Los v. Los, 595 A.2d 381, 384 (Del. 1991).
16
See supra note 9.
4
NEP
oc: Prothonotary
cc: Counsel of Record
cc: Joseph M. Walls (mail and email)
5