Trustee Lacks Standing to Assert Claims as a Third-Party Nonclient

Respondents' Failed to Show Petitioner Were Aware of Their Determination

Matter of Galloway III

Where DOJ special counsel report did not contradict the University of Delaware's assertions in its affidavit in support of its invocation of its exemption under the Delaware Freedom of Information Act, the court found no basis to reopen petitioners' complaint where university averred that it had not used public funds to acquire former legislator's working papers.

Court denied motion to vacate judgment dismissing action to enforce information rights on res judicata grounds where existence of underlying clinical trial data had been known to parties in prior action, where they could have sued to enforce their information rights.

Court found plaintiffs to be inadequate class representatives because they either simultaneously pursued individual claims that created a conflict of interest or because they were pro se litigants unqualified to represent a class.

Court found no error in excluding portion of property from farmland exemption where evidence supported the finding that the enclosed portion was not being used for farming purposes.