Supreme Court of Delaware
James E. Berry v. State Farm Mutual Automobile Insurance Company
December 18, 2025
Summary
The Court affirmed dismissal of Berry’s first-party UIM action because Delaware’s long-arm statute does not confer specific jurisdiction over State Farm for a Maryland policy issued to a Maryland resident. The injury occurred in Delaware, but Berry’s remaining dispute concerned contractual obligations under an out-of-state policy, not tortious conduct by State Farm in Delaware. The Court declined to consider Berry’s additional statutory argument because he had not presented it below.