Daniel J. Layton
| Daniel J. Layton | |
|---|---|
|
Attorney General of Delaware (1932–1933) Chief Justice of Delaware Supreme Court (1933–1945) |
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| Personal details | |
| Born |
July 9, 1879 Georgetown, Delaware |
| Died | May 13, 1960 (aged 80) Georgetown, Delaware |
| Political party | Republican |
| Residence | Georgetown, Delaware |
Daniel John Layton (August 1, 1879 – May 13, 1960) served on the Delaware Supreme Court as Chief Justice from 1933 to 1945 and earlier as attorney general of Delaware from late 1932 until his nomination. He was a native of Sussex County, Delaware and the son of U.S. Representative Caleb R. Layton.
Layton studied at the University of Pennsylvania, where he also pitched for the baseball team. Following graduation from the University of Pennsylvania Law School and service in the offices of Ward & Gray in Wilmington, Layton was admitted to the Delaware bar in 1903. Layton then practiced law in Wilmington until 1915, when he returned to Georgetown to practice until his election as attorney general and later elevation to the Supreme Court.
Two weeks after the expiration of the second term of James Pennewill, the previous Chief Justice, Governor C. Douglass Buck announced the appointment of Daniel J. Layton to replace him. Having been elected attorney general the previous November, and after having served in office for only six months, Layton resigned from that position to become chief justice. Governor Buck reappointed Josiah O. Wolcott as chancellor, as well as William Watson Harrington and Charles S. Richards as associate justices of the Supreme Court. In addition to these associate justices, Layton's colleagues in the law courts during his tenure as chief justice also included Richard S. Rodney, David J. Reinhardt, and Charles L. Terry. The resident judge of New Castle County, David J. Reinhardt, died in 1935 after two years of service and was replaced Frank L. Speakman.
During Layton's 12 years as chief justice he wrote 221 of the 511 opinions produced by Delaware's law courts, including 49 of the 106 opinions issued by the Supreme Court. One of Layton's landmark decisions was Guth v. Loft in 1939. In this case Layton defined the relationship between corporate opportunities and the duty of loyalty for Delaware corporations. It was notable in its deviation from the 200 year precedent from Keech v. Sandford that a fiduciary should leave open no possibility of conflict of interest between his private dealings and the job he is entrusted to do. Another of Layton's landmark decisions was Bovay v. H.M. Byllesby & Co. in 1944, which reversed the chancellor's previous dismissal of a suit for an accounting and finding the complaint to state a claim for fraud and unfair dealing against corporate officers and directors for breach of trust, not "mere torts."
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