Supreme Court of Delaware

Schiavo v. TD Bank USA National Association and Clover Network, LLC.

June 16, 2025

Summary

The Court dismissed Schiavo’s appeal because the Superior Court’s civil contempt orders were interlocutory and did not qualify for review under the collateral-order doctrine. Schiavo was a party to the underlying litigation, so the orders did not bind a nonparty as required for collateral-order jurisdiction. The Court also noted that the appeal was taken without compliance with the procedure governing interlocutory appeals.