Magistrates in Chancery
The Court of Chancery currently consists of one Chancellor, six Vice Chancellors, and three Magistrates in Chancery. The Magistrates in Chancery are selected by and serve at the pleasure of the Chancellor.
Magistrates in Chancery are judicial officers who preside over a full docket of cases consisting of traditional matters in equity–including matters involving wills and trusts, real property, and adult guardianships–as well as corporate and contract disputes.
The Magistrates in Chancery are indispensable to the Court of Chancery maintaining its current caseload. Although final reports issued by the Magistrates in Chancery are subject to an exceptions process, the Court strongly encourages litigants appearing before the Magistrates in Chancery to submit the matter for a final decision by the Magistrate in Chancery pursuant to Court of Chancery Rule 144(h). Under that rule, litigants may waive the right to seek further judicial review of the Magistrate in Chancery’s final decision at the trial level while preserving their ability to directly appeal to the Delaware Supreme Court.
History of the Magistrates (Masters) in the Court of Chancery
The title of Master in Chancery “is one of the oldest institutions in Anglo-American law, the origin of which is lost in the Dark Ages.” Bryant, James R. “The Office of Master in Chancery: Early English Development.” American Bar Association Journal 40, no. 6 (1954): 498–533. “Delaware's equity court traces its jurisdiction and powers to the High Court of Chancery in Great Britain at the time of the American Revolution. Under English chancery court practice, even before the Revolution, masters were appointed by the court and given authority to examine witnesses and prepare reports of their findings in the cause referred to them.” DiGiacobbe v. Sestak, 743 A.2d 180, 182 (Del. 1999). The earliest reference to the title of Master in Chancery in Delaware case law appears in the 1816 Delaware Supreme Court decision, Bauduy v. Du Pont, et al., 3 Del. Cas. 227 (Del. 1816). The Court of Chancery has appointed full-time Masters in Chancery since the 1980s.
In 2023, the title of “Master in Chancery” was changed to “Magistrate in Chancery” due to the connection of the word “master” to slavery. Although the title “Master in Chancery” has no link to that historical context, the Court of Chancery is sensitive to the title’s negative connotations and therefore proposed “Magistrate in Chancery” as a suitable and modern substitute title. This change in title also reflects the Court initiatives to broaden the judicial role and function of the Magistrate in Chancery position.
Past Magistrates (Masters) of the Court of Chancery
Chief Magistrate Patricia W. Griffin
(Magistrate in Chancery from 2017 to 2022)
The Honorable Patricia W. Griffin served as a Magistrate (Master) in Chancery from 2017 to 2022, and continues to serve as a Magistrate in Chancery in a retired capacity. Magistrate Griffin’s service to the Delaware courts began in 1993 at the Justice of the Peace Court where she served as Chief Magistrate for 12 years, becoming the first woman in Delaware history to serve as a presiding judge over a branch of the courts. In 2005, Magistrate Griffin began a 12-year stay in the Administrative Office of the Courts as State Court Administrator, until her appointment to the Court of Chancery in 2017. During her tenure at the Administrative Office of the Courts, Magistrate Griffin focused on enhancing services provided by the AOC, including by improving the court’s accessibility to litigants with psychiatric impairments and enhancing language access and interpretation services. Magistrate Griffin also served as President and Board member of the Conference of State Court Administrators and Vice Chair of the Board of Directors for the National Center for State Courts. Magistrate Griffin received her Juris Doctor from Washington and Lee University and earned her bachelor’s degree from Duke University.
Vice Chancellor Morgan T. Zurn
(Magistrate in Chancery from 2016 to 2018)
The Honorable Morgan T. Zurn served as a Magistrate (Master) in Chancery from 2016 to 2018. She currently serves as a Vice Chancellor of the Court of Chancery. Before joining the Court of Chancery as a Magistrate in Chancery, Vice Chancellor Zurn was first a patent litigator and then a Deputy Attorney General at the Delaware Department of Justice. Vice Chancellor Zurn served as a judicial law clerk to the Honorable Richard G. Andrews of the United States District Court for the District of Delaware. She holds a Juris Doctorate, cum laude, and a Master's degree in bioethics from the University of Pennsylvania, and holds a B.A., with distinction, from the University of Virginia. She has been admitted to practice before the United States Patent and Trademark Office. Vice Chancellor Zurn is a member of the Delaware State Bar Association and the Richard S. Rodney American Inn of Court.
Justice Abigail M. LeGrow
(Magistrate in Chancery from 2011 to 2016)
The Honorable Abigail M. LeGrow served as a Magistrate (Master) in Chancery from 2011 to 2016. She currently serves as Justice of the Supreme Court of Delaware. She previously served as a Judge of the Superior Court of Delaware from February 2016 to May 2023, where she was a member of the Superior Court’s Complex Commercial Litigation Division. Before joining the Court of Chancery as a Magistrate in Chancery, Justice LeGrow practiced law at Potter Anderson & Corroon LLP, where she specialized in corporate and commercial litigation. Justice LeGrow received her J.D., summa cum laude, from the Pennsylvania State University Dickinson School of Law and her B.A. in Political Science, summa cum laude, from Susquehanna University. While in law school, Justice LeGrow was an editor of the Penn State Law Review and a recipient of the Walter Harrison Hitchler Award and the American Bankruptcy Law Journal Prize. After graduating from law school, she served as a law clerk to the Honorable Jack B. Jacobs of the Delaware Supreme Court.
Magistrate in Chancery Kim E. Ayvazian
(Magistrate in Chancery from 2006 to 2017)
The Honorable Kim E. Ayvazian served as a Magistrate (Master) in Chancery from 2006 to 2017. Before joining the Court of Chancery, she was a Deputy Attorney General in the Appeals Unit of the Delaware Department of Justice, and a judicial law clerk. She received a B.A. in History from Yale University in 1975 and a J.D. from the University of Chicago Law School in 1986.
Vice Chancellor Sam Glasscock, III
(Magistrate in Chancery from 1999 to 2011)
The Honorable Sam Glasscock, III served as a Magistrate (Master) in Chancery from 1999 to 2011. He currently serves as a Vice Chancellor of the Court of Chancery. Before joining the Court of Chancery as a Magistrate in Chancery, Vice Chancellor Glasscock worked as a judicial clerk, as an associate at Prickett, Jones, Elliott, Kristol & Schnee in the litigation section, as a Superior Court special discovery master and as a Deputy Attorney General in the Appeals Unit of the Department of Justice. He received a B.A. in History from the University of Delaware in 1979, a J.D. from Duke University in 1983 and a Master's Degree in Marine Policy from the University of Delaware in 1989.
Magistrate in Chancery Richard C. Kiger
(Magistrate in Chancery from 1984 to 1998)
The Honorable Richard C. Kiger served as a Magistrate (Master) in Chancery from 1984 to 1998. Before joining the Court of Chancery, he was Assistant City Solicitor for the City of Wilmington from 1982 to 1984, Assistant County Attorney from 1977 to 1981, and served as a law clerk in the Delaware Court of Chancery from 1976 to 1977. He received a B.A. from the University of Delaware in 1972 and a J.D. from the Pennsylvania State University Dickinson School of Law in 1976.
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