On December 18, 2014, in the decision of Morgan v. Carpenter, C.A. No. 9324-ML (Del. Ch. Dec. 18, 2014), the Master in Chancery issued a Final Report recommending that the causes of action raised in the complaint be dismissed for lack of subject matter jurisdiction. The Master found that the sole cause of action seeking equitable relief failed to state a claim under Court of Chancery Rule 12(b)(6), and that the remaining causes of action in the complaint solely seek monetary damages that are legal in nature.
This report is a reminder that the Court of Chancery is a court of equity and may only exercise jurisdiction over monetary claims when there is also equitable relief before the Court. Otherwise the complaint will be dismissed without prejudice to re-file the action in the appropriate forum (i.e. the Superior Court).