State Supreme Court Data Tracker

Summary of Case Context & Holding1108 Ariola, LLC (1108 Ariola), and other taxpayers (Taxpayers), which held long-term leases on property owned by Escambia County, Florida, brought an action to enjoin county officials from collecting ad valorem taxes on certain improvements made to their properties. The circuit court granted the injunctions, however, the court of appeals reversed finding that the Taxpayers qualified as "equitable owners" of the land (as well as any improvements) given the benefits that Taxpayers had under their leases, including that they could mortgage their leases without the lessors' prior approval and sublet, assign or rent the land, and additionally, that they received the full benefit of any capital gains or appreciation in property value. Accordingly, the court of appeals found that the officials' collection of ad valorem taxes on certain improvements to the properties was appropriate. The Supreme Court agreed, highlighting that a lessee did not need to have a perpetual lease of underlying real property or the right to ultimately purchase the property in order to be considered an "equitable owner[]" of the property. The Supreme Court emphasized that Fla. Stat. § 196.199(2)(b) recognized that regardless of how legal title on a property is held, improvements on lands owned by a governmental entity may—for ad valorem tax purposes—be “owned” by the lessee of the lands.

Summary of Case Context & HoldingIn 2006, Nevada voters amended the state constitution by enacting the Minimum Wage Amendment (MWA), requiring that employers provide written notification of wage rate adjustments to each of their employees. In a class action suit, certain cab drivers alleged that a taxi company failed to pay its drivers the minimum wage under the MWA. The Supreme Court affirmed the district court's decision to grant summary judgment for the taxi drivers using reasonable approximation evidence when the employer failed to disclose the drivers' hours worked as required by statute.

Summary of Case Context & HoldingA severely autistic child appealed, with his parents testifying, a reduction by the Minnesota Department of Human Services (DHS) from 462 minutes to 390 minutes per day following a health care assessment of the amount of personal care assistant (PCA) services that he received under the state medical assistance program under Minn. Stat. § 256B.0659 due to the statutory amendments that limited PCA time for activities of daily living. The district court reversed the DHS' decision on the ground that the statute does not require the child to be physically incapable of mobility to be eligible for covered services. The court of appeals reversed and reinstated the DHS Commissioner's decision because the child is physically able to begin and complete moving from place to place without assistance. The child sought review which was granted. The Supreme Court affirmed, holding that: (1) the child was not dependent in mobility activity of daily living and under Minn. Stat. § 256B.0659, subd. 2(b)(6), the word “mobility” means the physical ability to move from one location to another location; and (2) a determination by the DHS Commissioner to reduce the child's PCA time since the child was not dependent in the mobility activity of daily living was well-supported by the record.

Summary of Case Context & HoldingUnder the South Carolina Constitution, the General Assembly is required to provide a system of public schools throughout the state. In 1999, the Supreme Court first heard a challenge from school districts claiming that the General Assembly had failed to meet this standard by underfunding the system as a whole. In the original case (Abbeville I), the Court held that the terms of the South Carolina Constitution required that the General Assembly "provide for the opportunity for each child to receive a minimally adequate education." On remand, the trial court found that the districts had safe facilities, that the statewide curriculum standards were sufficient, and that standards for teacher licensure were adequate. The trial court, therefore, found that the "inputs" into the educational system were sufficient to satisfy the constitutional requirement, with the only exception being a lack of early childhood intervention programs. The school districts appealed, and the State cross-appealed. On appeal, the Court considered whether students in South Carolina were given the opportunity to receive a minimally adequate education. First, the Court reviewed the "inputs" of the education system and the governing laws that determine academic standards and funding, teacher qualifications, and curricular requirements. The Court held that the General Assembly, through these laws, had implemented a comprehensive education regime that matched nationwide standards. Next, the Court considered the outcomes, or "outputs," that this educational regime produced in the districts. The Court found that the test results and report cards of students in the districts indicated a failed system, despite rising graduation rates and increased educational funding over the previous decade and a half. The Court further reviewed other factors that could affect the success of students in these districts, including transportation options provided by the district, teacher quality standards, and school district size. In concluding its review, the Court held that the State's educational funding scheme was a "fractured formula denying students in the Plaintiff Districts the constitutionally required opportunity." Nonetheless, the Court acknowledged that a judicially created solution would not meet the needs of the circumstances and acknowledged that the duty and the tools to solve this issue lay with the legislature. Justice Kittredge dissented, arguing that the original Abbeville I ruling had not only created a nonjusticiable standard, but had also improperly decided a political question outside the realm of the judiciary.

Summary of Case Context & HoldingGovernor Abbott issued Proclamation No. 41-3720 on March 13, 2020, declaring COVID-19 an imminent disaster and activating his statutory powers under the Texas Disaster Act. Among these powers, Governor Abbott amended election procedures to facilitate mail-in voting. Specifically, on July 27, 2020,Govenor Abbott expanded the window for hand-delivering mail-in ballots and increased early voting days. Subsequently, on October 1, 2020, Governor Abbott refined these provisions by limiting early mail-in ballot drop-off locations to one per county to enhance ballot security (the October Proclamation). The Plaintiffs contended that the October Proclamation exceeded the Governor's statutory authority and infringed upon voters' constitutional rights by disproportionately burdening voters in larger counties. A trial court granted a temporary injunction against the October Proclamation, which was affirmed by the court of appeals. However, the Supreme Court of Texas reversed, holding that the October Proclamation was issued within Governor Abbott's authority and that the alterations to election procedures did not constitute a severe burden on the right to vote. Specifically, the Court held that Governor Abbott did not exceed his authority by issuing the October Proclamation. In addition, the October Proclamation was not a “severe” restriction on voting, and thus strict scrutiny did not apply. Further, applying the rational basis test, the October Proclamation was rationally related to an important interest. Accordingly, the Court held that the October Proclamation did not unconstitutionally discriminate against voters of large counties.

Summary of Case Context & HoldingIn the aftermath of the COVID-19 pandemic, Texas governor Greg Abbott issued executive orders to prevent local governments from imposing pandemic-related restrictions. Included in those executive orders was GA-38, which prohibited local mask requirements. Local governments sued the Governor to prevent enforcement of the executive action and to prevent future orders prohibiting mask mandates. The Court considered a case brought by Harris County, but simultaneously considered cases brought by Dallas County and the City of San Antonio. Before beginning its analysis of the facts, the Court emphasized that conflicting state and local orders must result in the state order controlling, as the local government’s power flows through the state. Here, Harris County had three separate mask mandates that had gone into effect and were the subject of the litigation: (1) that masks be worn in county-owned buildings; (2) that all county employees wear masks in county buildings; and (3) that schools follow the CDC’s mask mandate recommendations. Although each requirement separately claimed support in state laws or regulations, each came into conflict with GA-38. Harris County sued the Governor and the Attorney General, seeking an injunction to prevent the enforcement of GA-38 alongside an injunction against future executive orders. The Court first reviewed the Texas Disaster Act, which controls the ways in which state and local authorities respond to disasters. Specifically, the Court noted that the Disaster Act appoints certain members of local government as the Governor’s “designated agents,” and although that status allows broad authority in responding to disasters, it also allows the Governor to overrule certain actions, including mask mandates that these designated agents enact. As a result, the Governor had the right to overturn the mask mandate requiring that masks be worn in all county-owned buildings which was enacted by the County Judge. The Court then turned to the two other mask mandates, which the Governor argued were preempted by GA-38. Here, the Court considered provisions in the Disaster Act which provide the Governor with the authority to control “the movement of persons” and “the occupancy of premises” within a disaster area. The Court emphasized that this case was not about individual liberties, but rather the “internal command structure” of the government in the event of a disaster. The Court held that if local orders were given priority over Governor orders then the authorities granted to the Governor under the Disaster Act would be entirely ineffective. As a result, the Court held that Governor actions pursuant to the Disaster Act must preempt the mandates at issue here.

Summary of Case Context & HoldingA patient sued the hospital emergency room for medical malpractice, alleging the staff did not find a surgeon for his hand injury in a timely manner. The trial court entered summary judgment in favor of the hospital staff, finding that the staff was entitled to immunity arising out of the provision of emergency medical care. The Supreme Court held that (1) Ga. Code Ann. § 51-1-29.5, which provides for immunity for providers of emergency medical care unless they act with gross negligence, applied to the facts of this case; (2) the statutory phrase “bona fide emergency services” in Ga. Code Ann § 51-1-29.5(5) means a genuine or actual emergency service, so the providers would be immune from claims unless the Plaintiff could prove by clear and convincing evidence that the providers acted with gross negligence; and (3) a genuine issue of material fact existed about the staff’s gross negligence because the evidence did not preclude a jury's ability to find, by clear and convincing evidence, that the providers acted with gross negligence in their efforts to find a hand surgeon. The Supreme Court reasoned that, based on the plain language of the statute and the undisputed facts, there was no dispute that the staff provided emergency medical care because the injury occurred after the onset of a medical or traumatic condition and that the patient needed emergency surgery to fix it. The Supreme Court looked to legislative intent and the dictionary definition of “bona fide” to determine the meaning of the statute. With regard to the gross negligence issue, the Supreme Court reasoned that there could have been gross negligence because, despite evidence that the providers took some action to find a hand surgeon, there were additional acts they did not do to find a surgeon on time.

Summary of Case Context & HoldingIn this case, inmate petitioners filed an emergency petition to enjoin several sections of the Timely Justice Act of 2013 (Act) for unconstitutionality. This Act sought to reduce delays and ensure quicker resolutions in death penalty cases. The petitioner likened the Act to the Death Penalty Reform Act (DPRA) which had a similar goal and was ultimately found to be unconstitutional and voided. However, here the Court distinguished the Act determining that unlike the DRPA, the Act's provisions do not impede on or regulate the procedural rules and judicial processes of the Supreme Court. The Supreme Court further held that the Act does not violate the due process, equal protection, or the Eighth Amendment ban on cruel and unusual punishment, as alleged, and is subsequently constitutional.

Summary of Case Context & HoldingAbel, a female graduate student of Asian Indian descent, who provided services for hospital through unpaid practicum program, brought action against a private university and hospital alleging race discrimination and sex discrimination in violation of the Minnesota Human Rights Act (MHRA) with respect to employment, education, public accommodation, and other claims. The district court granted in part the hospital's motion to dismiss for failure to state a claim and granted the university's motion for judgment on the pleadings, and the court of appeals affirmed because it determined the MHRA claim was time-barred. The Supreme Court affirmed in part and reversed in part, holding that the district court erred in dismissing Plaintiff's employment discrimination claim under the MHRA and Plaintiff's common-law negligence claims. The Supreme Court held that: (i) the student's allegations supported the "continuing violations doctrine" as a basis for equitably tolling the limitations period for an employment discrimination claim and the Respondent has not met its burden of showing that Abel's employment discrimination claim is barred by the statute of limitations; and (ii) as a matter of first impression, absence of compensation was not dispositive in determining whether student had employment relationship with the hospital.

Summary of Case Context & HoldingPlaintiffs, medical practices in North Carolina that provide care to Medicaid-eligible patients pursuant to Medicaid contracts with the state, filed a class action lawsuit against the North Carolina Department of Health and Human Services, the entity administering the state's Medicaid plan, when NCTracks—the new system the state used to manage reimbursement payments to health care providers for services provided to Medicaid recipients—experienced more than 3,200 software errors resulting in delayed, incorrectly paid or unpaid reimbursements. The Supreme Court held the trial court did not err in dismissing the Plaintiffs' actions due to their failure to exhaust administrative remedies in seeking damages for denied Medicare reimbursement claims.

Summary of Case Context & HoldingPlaintiff, the ACLU of Montana, petitioned the Supreme Court to have the ballot statement and fiscal note approved by the Attorney General for the "Montana Locker Room Privacy Act" to be legally insufficient under Mont. Code Ann. § 13-27-312. The initiative would require government entities to designate a protected facility in a government building or public school for use only by members of one sex, and prohibit persons from using a protected facility other than the facility that is designated for that person's sex. Upon review, the Supreme Court agreed with the ACLU that the statement and fiscal note were deficient on five grounds: (1) by omitting in the statement a specific definition of "sex" would impede voters from understanding how the initiative may apply to transgender and intersex individuals; (2) by only referring to "government entities," the statement fails to disclose that the initiative applies to the various forms of local government and to public institutions of higher education; (3) the statement is unclear as to how many protected facilities would be created in each government building; (4) the ballot statement refers to "civil penalties if a governmental entity fails to provide such privacy," but it does not acknowledge the extent of government liability the initiative creates; and (5) the fiscal statement prepared by the Attorney General includes only one part of the costs of the initiative. The Supreme Court thus declared the ballot statement and fiscal note as legally insufficient under Montana law.

Summary of Case Context & HoldingThe "Building Our Future Act" enacted in August 2012 authorizes New Jersey to subsidize capital improvement projects for higher education institutions. The American Civil Liberties Union of New Jersey brought an action against the New Jersey Secretary of Higher Education in her official capacity, alleging that the award of grants to a yeshiva and theological seminary violated provisions of the state constitution, including Article I, paragraph 3 (the government cannot force payment of taxes to support places of worship or "maintenance of any minister or ministry"). Factual disputes at issue involved: (1) the sectarian nature of the institutions; (2) whether the grant money would necessarily be used for "maintenance of any minister or ministry;" and (3) the adequacy of promised restrictions against sectarian use of grant proceeds. The Supreme Court held that the record on appeal was insufficient to allow for meaningful appellate review, so it vacated and remanded the matter for further fact-finding.

Summary of Case Context & HoldingOn October 17, 2022, the American Civil Liberties Union (ACLU) of Nevada filed an emergency petition for writ of mandamus with the Supreme Court pursuant to Nevada Rule of Appellate Procedure 17(a)(2), which gives the Supreme Court jurisdiction over "[c]ases involving ballot or election questions." The ACLU challenged three changes that Nye County Clerk's Office and Interim County Clerk Mark Kampf intended to implement for the 2022 election related to the county's hand ballot counting process, limits to ADA-compliant voting machines, and changes to its process for signature verification. The ACLU first argued that the county's plan to verify ballots by hand count (which involved each ballot being read aloud to verify the ballot was being read correctly) violated Nevada law by prematurely revealing election results because Nevada law prohibits the release of mail ballot voting results until the close of polls and all votes were cast. Second, the ACLU argued that the county's plan to limit use of ADA-compliant voting machines to those with "special needs" violated federal law which requires voters with disabilities to be afforded the same level of access and poll workers would be in a position to assess whether someone has "special needs," which would violate the privacy of the voter. Lastly, the ACLU also argued that the county's process for signature verification was too vague because the county's planned process did not explain what "stringent signature verification" entails (and, for example, if the voter was only permitted to verify their identity with an ID card, the ACLU argued this would violate state law). On October 21, 2022, the Supreme Court granted in part the ACLU's emergency petition requiring that the county comply with the first and third issues. According to the Supreme Court, the county's plan for hand-counting ballots violated state law "prohibit[ing] the release or dissemination of results before the polls have closed" and, on the issue of signature verification, the Court said the county was required by state law to permit voters to verify their identify in three different ways but here the county's plan only permitted voters to use an ID for verification. The Supreme Court denied the ACLU's motion with respect to ADA-compliant voting machines because the county said it would not deny anyone who felt special assistance was required use of the machines (and thus poll workers would not have responsibility for determining eligibility of voting machine use). Following the Supreme Court's order, the Secretary of State asked the county to explain how it planned to comply with the order; the county said it was not "explicitly bar[red]" from reading ballots aloud and planned to ensure election results were not prematurely learned by engaging the count in multiple rooms simultaneously and requiring observers to certify "they will not undertake any efforts to interfere with, obstruct or otherwise impede the election or its processes." On October 27, 2022, the ACLU filed an emergency motion for clarification regarding the County's compliance with the Supreme Court's order and, the same day, the Supreme Court granted the ACLU's motion, noting its prior concern about the read-aloud requirement and reiterated its directive from its prior order that "the ability of observers to hear the read-aloud sections on ballot violates [state law prohibiting the early release of voting results]."

Summary of Case Context & HoldingOn November 14, 2022, the American Civil Liberties Union (ACLU) filed an emergency petition for writ of mandamus challenging Nye County's plan to conduct a hand count of ballots following machine tabulation as part of the county's effort to move away from the use of electronic voting machines. The ACLU alleged a number of violations of state law related to the county's plan to conduct a hand count of ballots including: (1) the County did not receive timely approval from the Secretary of State of its hand count process as instructed by state law; (2) state law does not allow for a parallel hand count; and (3) state law only provides for three circumstances where ballots may be counted again (hand counts during an audit, recounts by defeated candidate, and election contests) and Nye County's hand count did not fall into any of these categories. The ACLU also argued that Nye County "unlawfully moved location of the hand count after the . . . deadline for obtaining approval of counting places," expressing concerns about ballot security and other lack of process measures. On November 14, the Supreme Court denied the ACLU's petition, holding that the ACLU "ha[d] not demonstrated that [the Supreme Court's] extraordinary intervention [was] warranted at this time" as the ACLU "pointed to no law clearly prohibiting the parallel hand count or precluding any post-deadline revision to secondary vote-counting plans approved by the Secretary." The Supreme Court also stated that there were a number of factual questions at issue that were not appropriate for resolution at the Supreme Court.

Summary of Case Context & HoldingIn litigation related to a natural gas explosion, the excavation contractor's insurer sued the contractor's pollution liability insurer asserting that it owed a duty to defend and indemnify the insured. The Supreme Court held that the natural gas that escaped from the pipeline was a "contaminant" and therefore met the "pollution condition" of the contractor's pollution liability policy, and that the policy did not require the contaminating substance to do the damage to the property to trigger coverage.

Summary of Case Context & HoldingIn March 2020, Congress passed the Coronavirus Aid, Relief and Economic Security Act (the CARES Act) that, in part, appropriated federal funds to support the national education system. As part of these appropriations, the CARES Act allocated money to the Governor's Emergency Education Relief (GEER) Fund. GEER funds were awarded to South Carolina to be distributed at the discretion of the Governor. Under the CARES Act, GEER funds could be used to provide grants to (1) local educational agencies; (2) institutions of high education; and (3) a broad range of education-related entities that were essential to carrying out emergency educational services. In May 2020, the Governor announced the Safe Access to Flexible Education (SAFE) Grants Program, which would distribute $32 million of federally granted GEER funds. Under the SAFE program, families with students interested in attending participating private or independent schools would be eligible to apply for need-based grants of up to $6,500 per student to cover the cost of tuition. All grant money would be directed to the schools themselves. Petitioners sought an injunction preventing the distribution of GEER funds through the SAFE Grants Program, arguing that the scheme violated the South Carolina Constitution, which prohibits the use of "public funds . . . for the direct benefit" of religious or private educational institutions. The Supreme Court held that the GEER funds received under the CARES Act were public funds, as they were deposited directly into the State Treasury, then distributed from it according to the state executive's directive. Further, while the Governor argued that SAFE grants were made for the direct benefit of the student and that the school was only an indirect beneficiary, the Court disagreed. The Court held that because the funds were paid directly to the institutions, they were in outright disagreement with the intentions of the state constitution. Further, the aid was only available to students attending select private schools approved by the Governor's office, depriving families of their independent choice of which school to attend. Finally, the Governor argued that the CARES Act granted him absolute discretion in distributing GEER funds, preempting the South Carolina Constitution. The Court held that the educational provisions under the CARES Act contained no clear statement of intent to preempt state law, and to otherwise read one in would go against traditional understandings of preemption.

Summary of Case Context & HoldingLowndes County and Advanced Disposal Services Middle Georgia sought injunctions prohibiting non-exclusive solid waste collector from providing collection and disposal services in violation of a newly enacted county ordinance. The Supreme Court held that enforcement of county's solid waste ordinance, pursuant to which county commissioners authorized an exclusive franchise for the collection and disposal of solid waste from residents of unincorporated county, would not violate non-exclusive waste collector's due process rights to continue its existing business, because the ordinance's authorization of an exclusive franchise was reasonably related to county's goal of providing complete, uniform, and affordable solid waste collection services to county residents.

Summary of Case Context & HoldingThe Attorney General of Florida requested an advisory opinion from the Supreme Court of Florida on a proposed citizen-initiated amendment to the state constitution, called the "Amendment to Limit Government Interference with Abortion." This amendment aimed to restrict governmental actions that could prohibit, penalize, delay, or limit abortion before viability or when necessary to protect the patient’s health as determined by their healthcare provider. The Supreme Court of Florida approved the proposed citizen-initiated amendment for placement on the ballot. This approval relied on the proposed amendment's compliance with (1) the single-subject requirement of the Florida Constitution; and (2) the ballot title and summary adhered to the relevant Florida Statute. The single-subject requirement ensures that any proposed amendment or revision addresses only one main issue, preventing the inclusion of unrelated provisions and allowing voters to make clear, focused decisions. The ballot title and summary were an "accurate, objective, and neutral summary of the proposed amendment," ensuring that it would not mislead voters about the amendment's purpose. The various dissents argued that the ballot initiative title and summary fail to adequately apprise voters such that they can make an educated decision.

Summary of Case Context & HoldingThe Attorney General of Florida requested an advisory opinion from the Supreme Court of Florida on a proposed amendment to the state constitution sponsored by Sensible Florida, Inc., called the "Regulate Marijuana in a Manner Similar to Alcohol to Establish Age, Licensing, & Other Restrictions." The Supreme Court of Florida evaluated the proposed amendment by relying on the proposed amendment's compliance with the single-subject requirement of the Florida Constitution and that the ballot title and summary adhered to the requirements laid out in Florida statute. The Florida Supreme Court found that certain language in the ballot summary noting that the proposed amendment regulates marijuana for limited use by persons twenty-one or older was affirmatively misleading and did not comply with statute because it did not place limits on the amount of marijuana a person can grow or possess. Accordingly the Supreme Court determined that the amendment should not be placed on the ballot. The dissent argued that when the title of the initiative is read with the description, the proposed amendment does not disguise the measure as something else or hide the ball and thus the initiative is not "clearly and conclusively defective."

Summary of Case Context & HoldingIn 2018, voters in Florida approved an amendment that restored the voting rights of convicted felons upon completion of all terms of their sentence, including parole or probation. Governor DeSantis asked the Supreme Court to decide whether the “all terms” of a sentence included, as proposed by the state’s Legislature, legal financial obligations (LFOs), including fines, restitution, costs, and fees. The Court held that it did, relying on the plain meaning of “all terms,” which the Court held encompassed LFOs imposed as part of an adjudication of guilt. Although the Court purported to rest exclusively on the amendment's text, the Court also found it “beyond dispute” that inclusion of LFOs in the meaning of “all terms” was intended by the sponsors and supporters of the proposed Amendment. The Court pointed to prior statements by supporters and sponsors of the amendment suggesting that they understood the amendment to require payment of fines. Justice Labarga concurred in part and dissented in part, concluding that “all terms” did include LFOs, but that the term was not unambiguous, and could only be determined because of extrinsic evidence.

Summary of Case Context & HoldingThe Attorney General of Florida requested an advisory opinion from the Supreme Court of Florida on a proposed amendment to the state constitution, named "Adult Personal Use of Marijuana." This amendment aimed to legalize the personal recreational use of marijuana and to allow licensed centers to sell and distribute marijuana for personal use. The Supreme Court of Florida evaluated the proposed amendment by relying of the proposed amendment's compliance with the single-subject requirement of the Florida Constitution and that the ballot title and summary adhered to the applicable Florida Statute, and its validity under the federal constitution. The Florida Supreme Court determined that the amendment complied with the single-subject requirement as it focused only on the single plan of legalizing marijuana for personal use. The Court rejected the argument that the amendment violated this requirement by decriminalizing and commercializing recreational marijuana because any sale and possession are logically related components of a dominant plan or scheme. The Court also determined that the ballot summary met the statutory clarity standard, disagreeing with claims that it was misleading by suggesting existing state-licensed entities were prepared to sell recreational marijuana. Further, the Court held that the amendment was not facially invalid under the United States Constitution and that the amendment was not preempted by the federal Controlled Substances Act. The various dissents argued that the ballot initiative title and summary violated the single subject rule as well as misled voters.

Summary of Case Context & HoldingThe Court approved a ballot initiative seeking to “allow[] all registered voters to vote in primaries . . . regardless of political party affiliation.” The Attorney General, the Florida Democratic Party, and the Republican Party of Florida all filed briefs in opposition. The Court used a deferential standard in reviewing the initiative. First, the Court found that the ballot initiative complied with the “single-subject requirement,” as it had a “logical and natural oneness of purpose [in allowing] all registered voters to vote in primary elections for state legislature, governor, and cabinet” and it did not “alter[] or perform[] the functions of multiple branches of government.” Second, the Court rejected the argument that the ballot summary did not explain ramifications or include details of how party nominations occurred. It held that the summary need not be extensive; that the summary clearly and unambiguously explained the initiative’s chief purpose of allowing all registered votes to vote in primary elections; and that the summary included the necessary details of the change in the primary election process. Justice Muñiz’s dissent expressed that the initiative was deceptive in three ways: (1) the summary failed to disclose that it would qualify the Legislature’s discretion to provide for state-run elections to choose political party nominees; (2) the initiative leads voters to believe that party-nominated candidates would necessarily be a feature of the primary election scheme; and (3) the “all voters vote” language wrongly implied that the initiative expanded voting access. Justice Lawson’s concurring opinion responded to the dissent, asserting that the ballot summary sufficiently addressed the “chief purpose” of the initiative and that the initiative “does not strip the Legislature of its powers to provide for state-sponsored elections[;]” that the summary’s reference to “party nominated candidates” and “all voters vote” was not misleading when read in connection with the remainder of the text of the summary.

Summary of Case Context & HoldingThe Court approved a ballot initiative seeking to modify existing text in the Florida Constitution related to the citizenship requirement for voters in Florida elections. The Court did not receive briefs opposing the initiative. Specifically, the ballot initiative sought to replace constitutional text stating that “[e]very citizen of the United States" shall be qualified to vote in Florida elections with text stating that “[o]nly a citizen of the United States” shall be qualified to vote (emphasis added). Using a deferential standard in reviewing the initiative, the Court found in a brief opinion that the ballot initiative met the “single-subject” requirement by neither “logrolling” (i.e. it only made a “minor change to existing constitutional language”) nor “substantially alter[] or perform[] the functions of multiple branches of state government.” It also found that the ballot summary and title met the statutory limits and were “accurate and informative.”

Summary of Case Context & HoldingThe Court approved a ballot initiative seeking to require ballot initiatives to be approved by voters in two sequential elections in order to go into effect. The Court did not receive briefs opposing the initiative. Using a deferential standard in reviewing the initiative, the Court found in a brief opinion that the ballot initiative met the “single-subject” requirement, and that the ballot summary and title met statutory limits and were written in “clear and unambiguous language.”

Summary of Case Context & HoldingThe Court approved a ballot initiative which would require "casino gambling," as defined by the proposal, to be authorized only through the citizens' initiative process. The Court held that (1) the petition satisfied the single-subject requirement because the initiative had "a logical and natural oneness of purpose," namely whether voters wish to authorize casino gambling in Florida through the citizens' initiative process, as opposed to allowing the legislature to authorize it; and (2) the proposal's ballot title and summary provided fair notice of the content of the proposed amendment because the ballot title and summary were reasonably clear, even though the summary did not describe what effect the initiative would have on gambling on tribal lands.

Summary of Case Context & HoldingThe Court approved a ballot initiative proposing to amend the state constitution to restore the voting rights of individuals convicted of felonies. The Court concluded that the initiative satisfied the single-subject requirement because it addressed whether to allow restoration of voting rights to individuals with felony convictions once the individuals had completed all terms of their sentences, and a provision excluding individuals with murder and felony sex offenses was directly connected to the initiative's purpose. Lastly, the ballot title and summary were sufficiently clear in educating the voters about the content of the proposed amendment.

Summary of Case Context & HoldingIn 2015, it was discovered that the State was not listed as an owner of certain ground water rights developed or diverted on private property but used on school trust lands. The State thereafter filed Water Rights Ownership Update Forms with the Water Rights Bureau to add the State as a co-owner on each water right. While the State informed the affected water rights owners of the change, there was no formal process in place for them to object. In response, the legislature passed House Bill 286 (HB 286) to remedy potential due process concerns arising from the involuntary transfers of private water rights. HB 286 created a process by which the State could acquire water rights in privately developed or diverted ground water used on school trust lands. The bill also required the State to rescind any claim to such water rights asserted prior to May 11, 2019—the law's effective date—if it had not complied with the new statutory process. Appellant Advocates for School Trust Lands (Advocates), a non-profit organization working to ensure that the Montana Constitution's trust land commitment is honored, challenged the constitutionality of HB 286 arguing that the bill violates the Montana Constitution and the 1889 Enabling Act by creating a presumption against State ownership in ground water diverted from private property for use on leased school trust land, thereby reducing the value of those lands. The State moved for summary judgment and Advocates moved for partial summary judgement. The district court granted summary judgment to the State on the grounds that Advocates’ claim was unripe and Advocates appealed the district court's decision. The Supreme Court affirmed Advocates' claim was ripe for adjudication. Nevertheless, the Supreme Court found that HB 286 did not violate the State's trust obligations imposed by the Enabling Act or the Constitution because it merely created a process by which the State could acquire water rights in privately developed or diverted ground water used on school trust lands. In support of its holding, the Supreme Court reasoned that HB 286 did not create a presumption against State ownership in ground water diverted from private property for use on leased school trust land because the statute did not grant private landowners anything other than a process, and it did not use the word “presumption” or include other language placing trust ownership at a disadvantage in that process.

Summary of Case Context & HoldingLabor organizations representing public school employees brought actions challenging an amendment to the Public School Employees Retirement Act (PSERA) that altered future healthcare and retirement benefit plans available to public school employees. On consolidation, the court of claims, granted summary disposition in favor of the State. Labor organizations appealed. The court of appeals, affirmed. Labor organizations sought review. The Supreme Court held that (1) the statute amending PSERA by allowing current public school employees to opt out of retiree healthcare benefit did not violate uncompensated taking provisions; (2) the state did not attach an unconstitutional condition by requiring contributions to qualify for retiree healthcare benefits; (3) amending PSERA by allowing current employees to opt out of the retiree healthcare program did not impair obligation of contracts; (4) state pamphlets and brochures did not create enforceable contracts concerning future pension benefits; and (5) the statutes did not violate public school employees' substantive due process rights.

Summary of Case Context & HoldingEmployees brought a class action against their employer, Husco, seeking back pay for meal periods, alleging that Husco owed employees wages for 20-minute meal breaks under Wis. Admin. Code DWD § 274.02, which requires payment for meal breaks under 30 minutes. Husco argued that such meal breaks did not need to be compensated under the terms of the collective bargaining agreement governing the Plaintiffs-employees. The complaint was initially submitted to the Wisconsin Department of Workforce Development, which held that payment of back wages was not required, as the collective bargaining agreement favored the existence of a waiver to the right to payment for the meal breaks. In light of the unfavorable decision, employees brought suit against Husco. The Supreme Court ruled for the employer, holding that the decision of the Department of Workforce Development not to seek recovery of back pay was reasonable given the purpose of the meal break length regulation, which was designed to protect health, safety, and welfare. The Supreme Court held that, in light of that regulatory purpose, "the decision to deny recovery of back pay in this case is reasonable and consistent with the purpose of the regulation because the regulation's purpose is to protect the life, health, safety, and welfare of the employees and to accommodate reasonable departures from the rule on meal break length where, under a [collective bargaining agreement], labor and management have agreed on that issue."

Summary of Case Context & HoldingPetitioners are a group of fifteen inmates who were sentenced to life without parole as minors and have sought reconsideration of their sentences in light of the U.S. Supreme Court’s decision in Miller v. Alabama, 567 U.S. 460 (2012) (holding that mandatory life imprisonment without parole (LWOP) for minors violates the Eighth Amendment). Petitioners argued that Miller applies retroactively and requires the state to reconsider their sentences. The Court agreed, holding that Miller applies to all juvenile offenders who may be subject to a LWOP sentence, including those previously sentenced, and granted all similarly situated individuals the ability to file a motion for resentencing within one year of the decision. In reaching its holding, the Court considered two arguments: (i) whether Miller applies retroactively; and (ii) whether Miller’s retroactive application would apply to cases where LWOP sentences were not mandatory. For (i) the Court found that the prohibition against LWOP imposed by Miller was a “substantive” change in the rules of criminal procedure, and thus retroactively applicable under existing U.S. Supreme Court precedent. See Teague v. Lane, 489 U.S. 288 (1989) (holding that the general prohibition against retroactive application of new constitutional rules does not apply to rules that are substantive). For (ii) the Court acknowledged that Miller only explicitly barred States from maintaining sentencing schemes that mandate LWOP for juveniles whereas South Carolina’s sentencing scheme merely permits LWOP as a punishment for juvenile offenders. Nonetheless, the Court recognized that Miller’s analysis of the constitutional relevance of youth to criminal sentencing, particularly that LWOP sentences are analogous to capital punishment for youth, and how the social and developmental differences of children, as defendants, “counsel against irrevocably sentencing them to a lifetime in prison.” Accordingly the Court was compelled to extend Miller’s bar on LWOP sentences for juvenile offenders to even non-mandatory sentencing schemes.

Summary of Case Context & HoldingCommercial fisherman brought declaratory judgment action against the Alabama Department of Conservation and Natural Resources to challenge the constitutionality of a statute banning gill and trammel net fishing (Ala. Code § 9-11-88(b)). The trial court declared the statute void because it is a local law and was not properly advertised as such. The Department appealed. The Alabama Supreme Court found that the Department was immune from suit under Ala. Const. art. I § 14. Because the trial court consequently lacked jurisdiction, the trial court's judgment was void.

Summary of Case Context & HoldingCatherine Clark worked in the girls athletic department at Alamo Heights Junior School. Clark and Ann Monterrubio began to have issues between them. Clark alleged that Monterrubio made comments about female body parts, and used vulgar language, often with sexual connotations, that was sometimes directed at her. The issues between the two teachers persisted and both Monterrubio and Clark were placed on an employee growth plan. Clark filed a charge of discrimination with the EEOC, alleging Monterrubio and Michelle Boyer (the girls athletic department coordinator) sexually harassed her and, after she complained, the school district and her supervisors retaliated against her. Clark submitted three letters to Stephanie Kershner (the middle school principal) detailing more than forty additional complaints against Monterrubio, Boyer, other coaches, and Kershner herself. Kershner investigated Clark's complaints and issued a written response concluding (1) no evidence of retaliation; and (2) Clark was responsible for any difficulties. The Alamo Heights School Board issued a Notice of Proposed termination that included nineteen specific instances of conduct supporting good cause for termination. Clark never contested the grounds for termination or requested a hearing and was fired. Clark sued Alamo Heights, asserting sexual-harassment and retaliation claims under the Texas Commission on Human Rights Act (TCHRA). Notably, school districts are immune from suit unless the state consents. The TCHRA waives immunity, but only when the plaintiff states a claim for conduct that actually violates the statute. Alamo Heights filed a plea to the jurisdiction, arguing the TCHRA's governmental-immunity waiver does not apply because Clark has no evidence of a statutory violation. The trial court denied the plea, and the court of appeals affirmed. Upon review, the Court found that (1) the record did not support a finding that Monterrubio’s behavior evinced hostility to her own gender in the workplace; (2) that the evidence revealed that Monterrubio had similar inappropriate conduct toward both male and female co-workers; and (3) that comments about gender-specific anatomy and characteristics do not alone raise an inference that harassment is because of gender. Accordingly, the Court held that no reasonable juror could find that Clark's gender motivated the conduct toward her, and thus immunity had not been waived with respect to her sexual-harassment claim. Regarding the retaliation claim, the Court found that none of the internal complaints constituted protected activity under the TCHRA. The only protected activity supported by the record was Clark's October 2008 EEOC charge. The Court noted that the TCHRA protected employees only from actions that are "materially adverse." The Court found that Clark’s complaints did not rise to the level of the material adversity needed under the TCHRA and involved only Monterrubio, a co-worker, rather than a decisionmaker. Accordingly, the Court found that immunity was not waived as to this claim. The Court reversed.

Summary of Case Context & HoldingEmployee-Plaintiff was injured while on the job, and after trying and failing to find accommodations that could allow the employee to remain in his current, physically-demanding role, the employer terminated his employment. The employee filed suit alleging that he was discriminated against and terminated due to his disability, whereas the employer alleged that they provided reasonable accommodations that the employee failed to follow up on. The lower court found for the employer, holding that the employee did not engage in good faith with the employer in the accommodation process. The Supreme Court held for the employer, finding that the employer had reasonably accommodated an employee under the Montana Human Rights Act by offering alternative positions and considering various possible accommodations, and through the fault of the employee for failing to follow up on offered accommodations, the interactive process broke down. Mont. Code Ann. § 49-2-303(1)(a).

Summary of Case Context & HoldingThe Plaintiff filed a sexual harassment complaint against her employer with the Montana Human Rights Bureau (HRB) under the Montana Human Rights Act (MHRA), alleging that she was subject to unwelcome sexual comments while at work. Mont. Code Ann. § 49-2-303(1). The HRB's hearings examiner considered disputed corroborative testimony and found that the Plaintiff's testimony was credible, and awarded damages. The employer appealed on the basis that there was lack of direct evidence supporting the Plaintiff's claim, only indirect evidence by the way of third-party testimony regarding the Plaintiff's statements regarding details of the alleged sexual harassment. The Supreme Court found that although the HRB examiner incorrectly referenced inapplicable hearsay exclusions, the examiner did not erroneously admit or consider the disputed testimony because the third-party testimony was not offered for the purpose of proving the sexual harassment, but to help the examiner evaluate the Plaintiff's credibility. Therefore, it was not hearsay by definition, and the Supreme Court will affirm the decision of a lower court that ultimately reaches a correct result, even if based on a wrong reason.

Summary of Case Context & HoldingJeffrey D. Allen, on behalf of his minor daughter, appealed a decision denying insurance coverage for a diabetes educational training session prescribed after her diagnosis with Type 1 diabetes. Allen was covered under the State Health Plan, administered by the South Carolina Public Employee Benefit Authority (PEBA). PEBA denied the claim, citing an exclusion in the State Health Plan specifically for diabetes education services. Allen challenged this denial, arguing it violated S.C. Code Ann. § 38-71-46, a statute mandating that health insurance policies issued in South Carolina must provide coverage for outpatient diabetes self-management training and education. The Administrative Law Court (ALC) upheld PEBA’s denial, concluding that the State Health Plan did not fall under the definition of "health insurance coverage" as set forth in South Carolina statutes, and therefore was exempt from this mandate. On review, the South Carolina Supreme Court reversed the ALC's decision. The Supreme Court held that the State Health Plan indeed qualified as "health insurance coverage" under state law, thus making it subject to the diabetes education coverage requirement. In reaching this conclusion, the Court closely examined both the language and legislative intent behind the statute. The Court found the statutory language clear and broad, expressly mandating diabetes education coverage for "every health maintenance organization, individual, and group health insurance policy" issued in the state. Moreover, the Court underscored that the legislature’s clear purpose in enacting § 38-71-46 was to address South Carolina’s high incidence of diabetes, noting the state's significant public health concern surrounding diabetes management and education. Given this context, the Court determined that excluding the State Health Plan from the statutory mandate would undermine the legislature’s explicit intent and produce an illogical result—covering essential diabetes treatment equipment but not the necessary training to use it.

Summary of Case Context & HoldingDefendant and codefendant were indicted for first-degree murder of their child and for child abuse offenses. The trial court ruled that convictions on the child abuse charges would constitute convictions for “serious offenses,” within the meaning of the statutory aggravating circumstances for the death penalty, and that, because the grand jury had found probable cause to support the child abuse charges, there was probable cause to support the “serious offenses” aggravator. Defendant and codefendant filed a petition for special action. The court of appeals granted relief based on the determination that the trial court was required to independently determine whether there was probable cause to support the “serious offense” aggravator. The State granted review, and the Supreme Court held that the trial court was required to independently consider whether the child abuse charges qualified as “serious offenses,” but was not required to review the sufficiency of the evidence to support the return of indictment on those charges.

Summary of Case Context & HoldingReggie Eugene Allen was charged with three counts of sexual battery and one count of lewd or lascivious exhibition, all relating to incidents that took place between 2010 and 2016. Allen's victim, T.W., is the daughter of his ex-girlfriend. T.W. was between nine and fifteen years old during the alleged incidents. The jury found Allen guilty as charged on all four counts. Allen appealed, arguing that the trial court erred in denying his motion to instruct the jury on sexual battery as a necessarily lesser included offense of capital sexual battery. The Supreme Court addressed the question of whether the schedule of lesser included offenses promulgated by the Supreme Court in 2018 incorrectly classifies sexual battery under § 794.011(5) as a necessarily lesser included offense of capital battery under § 794.011(2)(a). Section 794.011(5) provides that someone eighteen years of age or older who commits sexual battery upon a person less than twelve years of age commits a capital felony. Section 794.011(2)(a) provides that someone eighteen years of age or older who commits sexual battery upon a victim eighteen years of age or older commits a felony of the second degree. The Supreme Court held that the schedule incorrectly classifies sexual battery as a necessarily lesser included offense of capital sexual battery and concluded that statute at issue does not present a gradient of culpability, but a binary choice (i.e., whether a victim is under the age of twelve or not). Here the law offers special protection to the young and elsewhere to the old, and the Supreme Court has upheld the permissibility of that legislative choice over the years. The Supreme Court further reasoned that its conclusion squares with the plain meaning of Florida's sexual battery statute (Section 794.011), and that the structure and language of the statute mean that those who commit sexual battery upon a person under the age of twelve are treated more harshly than those who commit the same crime upon persons not in that statutorily prescribed age group.

Summary of Case Context & HoldingA silica sand mining company sought certiorari review of the County Environment and Land-Use Committee's denial of its conditional-use permit application for non-metallic mineral mining on the grounds that: (1) the Committee exceeded its jurisdiction in denying the permit based on broad legislative concerns over public health, safety and welfare; and (2) the Committee acted in an arbitrary, oppressive, and unreasonable manner. The Supreme Court found that substantial evidence supported the Committee's denial of the permit, including that the plan seemed rushed; there were environmental concerns related to significant wetlands in the area; the mining would cause significant changes to the surrounding landscape; and the mine raised health concerns and would result in changes to local culture and conditions. The Supreme Court also found that the ordinance on non-metallic mineral mining was not unconstitutionally vague: it required the Committee to consider various factors such as effect on area property, noise, odor, dust, surface water drainage, and natural beauty in deciding whether to grant a permit. Finally, the Supreme Court concluded that any fulfillment of all of the specific conditions in the ordinance did not entitle the mining company to the permit.

Summary of Case Context & HoldingPlaintiff, Revival Chiropractic, LLC, a medical provider, submitted charges for services rendered to two of Defendant Allstate Insurance Company's policyholders under a personal injury protection (PIP) policy. Defendant reimbursed 80% of the submitted charges, which was less than the maximum allowable under the statutory schedule. Plaintiff contended that Defendant should pay either 80% of the maximum charge or the full amount of the submitted charge. The U.S. District Court ruled in favor of Plaintiff, stating that Defendant violated Florida law by paying only 80% of the submitted charges when these charges were below the amounts allowed under the statutory schedule. Defendant appealed to the Eleventh Circuit, which then presented the issue to the Florida Supreme Court as a certified question. The Florida Supreme Court granted review and determined that under the terms of the PIP policy, it was proper to pay only 80% of the billed charges. The PIP policy explicitly permitted this payment method and there was no statutory provision that contradicted the contractual language of the policy. The Court clarified that an insurer using the schedule of maximum charges could still pay 80% of reasonable charges as determined under the statute. Additionally, the Court rejected the argument that the statutory requirement for insurers to pay the full amount of charges below the maximum schedule was mandatory, deeming that it was permissive instead. Thus, the Court held that the policy language was controlling and there was no statutory provision which would prevent Defendant's reimbursement method.

Summary of Case Context & HoldingIn 2003, the Montana legislature passed a bill which allowed establishments with "video gambling machines" (VGMs) to be exempt from local government ordinances that were more restrictive than the Montana Clean Indoor Air Act (MCIAA). This included smoking in public spaces prohibitions. Prior to the bill, four charter government cities with self-governing powers adopted the ordinances limiting or prohibiting smoking tobacco products in buildings open to the public. Helena was the only city to adopt an ordinance without limitation to premises with state licenses for the operation of VGMs. Following those ordinances, the Legislature enacted a bill that imposed a surcharge fee on VGMs and exempted the establishments with VGMs on the premise from local government smoking ordinances more stringent than the MCIAA. The Supreme Court of Montana was asked to determine if the state law was unconstitutional under provisions of the state Constitution. The Montana Constitution states all persons have an inalienable right to "a clean and healthy environment" and that the state is charged with maintaining and improving the environment. The state of Montana inquired as to whether the exemption expressly prohibited the ordinances passed by local government and argued that the Bill preempted city ordinances covering state licensed video gambling machines. The Montana Supreme Court in a split decision held that the state law did not violate the local government sovereignty provision of the Montana Constitution because the statute did not preempt self-governing entities' no smoking ordinances. The Court held that the meaning of exempt is not the same as prohibit and "an exemption is an exception to, not a denial of the power to act."

Summary of Case Context & HoldingThe County employees' union petitioned the commonwealth court for review of an order of the Labor Relations Board, which ruled that the County did not engage in unfair labor practice when a multi-county Workforce Investment Board contracted out employment development services and youth programs to private entities, which services had been previously provided by County employees, without first bargaining with the union. The commonwealth court affirmed the order, and the union appealed. Because the Workforce Investment Board, and not the County, made the decision to award contracts to non-union private entities, the Supreme Court affirmed the order and held that the County did not engage in unfair labor practice.

Summary of Case Context & HoldingFollowing the November 6, 2012 general election, with a 63,141 to 63,104 vote margin for the election for the office of State Senator for the 46th Senate District, candidates for political office sued the New York State Board of Elections challenging 216 affidavit ballots and 53 special ballots cast by Ulster County election inspectors more than two weeks before the election. The Supreme Court upheld objections to 209 affidavit ballots on the grounds that they contained inaccurate or incomplete information and allowed the other 7 to be canvassed, i.e., counted in the election. The Supreme Court held that the 53 special ballots would not count. On appeal, the Appellate Division upheld the Supreme Court's decision regarding the 216 affidavit ballots but determined that the 53 special ballots cast by election inspectors would be canvassed since Election Law § 11-30 required only that the Election Board provide the ballots not more than two weeks before the election but did not explicitly say the earliest time voters had to return ballots. The Court of Appeals subsequently denied a motion for leave to appeal of the decision. Judge Graffeo dissented arguing that the Court should review whether such an exception to statutory compliance should be made in the special ballot context.

Summary of Case Context & HoldingFormer employees of two in-home personal care companies sued their former employers, asserting that they had not been paid the minimum wage to which they are entitled under the Georgia Minimum Wage Law (GMWL). Specifically, the Supreme Court considered two certified questions: (i) whether an employee that falls under a Fair Labor Standards Act (FLSA) exemption is effectively “covered” by the FLSA for purposes of Ga. Code Ann. § 34-4-3(c) analysis, thereby prohibiting said employee from receiving minimum wage compensation under the GMWL; and (ii) whether an individual whose employment consists of providing in-home personal support services is prohibited from receiving minimum wage compensation under the GMWL pursuant to the “domestic employees” exception articulated in Ga. Code Ann. § 34-4-3(b(3). With respect to the first question, the Supreme Court held that the text of Ga. Code Ann. § 34-4-3(c) does not speak in terms of employees’ coverage by the FLSA (or other acts of Congress) in general—rather, it removes from the GMWL’s protection employees who are “covered” by the minimum wage provisions of a federal statute like the FLSA if such act provides for a minimum wage greater than the GMWL’s minimum wage. As to the second question, the Supreme Court held that “domestic employees” as that term is used in Ga. Code Ann. § 34-4-3(b) must work in or about the homes of their employers, and the employers in the instant case are therefore not exempt from the GMWL under that provision.

Summary of Case Context & HoldingIn 2004, Ricky Anderson injured his vertebrae at work. The injury was debilitating, and Anderson received workers' compensation benefits for temporary total disability (TTD). Following surgery, Anderson returned to work as a construction company foreman for over two years until October 2008. However, Anderson's back problems recurred, and he again received TTD benefits, from November 2008 until June 2010. After more surgery, Anderson was medically released to return to work. But Anderson could not find a job, so he filed for unemployment compensation. The Employment Security Division (ESD) denied Anderson's claim. It determined that he did not qualify for unemployment compensation, calculated conventionally, because he had not earned wages in the first four of the last five calendar quarters preceding his application. Deferring to the ESD's finding of fact that the 2004 injury led to both disability leaves, the Court focused on the legal question of whether, by working full time from 2006 to 2008, Anderson restored his eligibility to elect the optional base period under NRS 612.344. NRS 612.344 allows an individual who cannot find work after a period of temporary disability the option of using their work history for the 15 months preceding their disability leave to determine their unemployment compensation instead of the 15 months preceding their application for unemployment compensation. To qualify for this option, the application must be filed "within 3 years after the initial period of disability begins and not later than the fourth calendar week of unemployment after . . . [t]he end of the period of [TTD] or temporary partial disability [or the] date the person ceases to receive money for rehabilitative services, whichever occurs later." NRS 612.344(2). The Supreme Court held that the phrase "within 3 years after the initial period of disability begins" refers to the first in the series of potentially available benefits enumerated in NRS 612.344(2)—temporary total disability, temporary partial disability, and/or vocational rehabilitation—for each episode of compensated disability leave and, therefore, the alternative-calculation option in NRS 612.344 renews when a temporarily disabled worker recovers and returns to work long enough to reestablish himself in the unemployment compensation system. The Court reversed the district court's denial of the petition for judicial review and remanded for further proceedings.

Summary of Case Context & HoldingPlaintiffs sought certification of a class of home health care aides for alleged violations of the Labor Law based on their respective employer’s failure to pay putative class members a required minimum wage for each hour of a 24- hour shift. Under a New York Department of Labor (DOL) wage order, Plaintiffs’ employers were required to pay the minimum wage “for the time an employee is permitted to work, or is required to be available for work at a place prescribed by the employer.” DOL interpreted the wage order to require payment of the minimum wage for at least 13 hours of a 24-hour shift if the employee is allowed a sleep break of at least 8 hours—and actually receives five hours of uninterrupted sleep—and three hours of meal break time. The Court of Appeals held that DOL’s long-standing interpretation of its wage order was rational and therefore entitled to deference. In reaching this decision, the Court of Appeals noted that DOL’s interpretation was grounded in its specialized knowledge and experience of both round-the-clock work assignments and the home health care industry. While determining that Plaintiffs were not entitled to payment of the minimum wage for each hour in a 24-hour shift if they received the requisite sleep and meal breaks, the Court of Appeals remanded for consideration of additional grounds for class certification, including defendants’ alleged failure to adequately compensate home health care aides when they did not receive the minimum sleep and meal breaks.

Summary of Case Context & HoldingPlaintiff, a senior paralegal in the legal department of a large corporation, complained to her department supervisor after being passed over for a promotion and after newly implemented corporate policies reduced the flexibility of her schedule and her ability to work overtime. After further requests that Plaintiff adopt a more standard work schedule, and after Plaintiff continued to work unauthorized overtime, she was reprimanded by her supervisor. Plaintiff then submitted a formal email to upper management in her department, alleging that she was being discriminated against on the basis of both her gender and her age (Plaintiff was 59 at the time). The only discrimination-specific allegation submitted by Plaintiff was that she had “observed and experienced the Company’s pervasive negative attitude toward advancing or recognizing the contributions or accomplishments of its female employees.” Following an internal investigation of her claims, the company found no wrongdoing. Reflecting numerous discussions among management regarding Plaintiff’s insubordination and disagreements with her supervisor, Plaintiff was ultimately terminated. Plaintiff submitted a complaint to the Equal Employment Opportunity Commission through the Texas Workforce Commission, asserting age discrimination. Following receipt of a “right-to-sue” letter, Plaintiff sued the corporation, alleging claims of age discrimination as well as retaliation for complaining about age and gender discrimination. Following trial, a jury found that while age was not a motivating factor in Plaintiff’s termination, her email constituted a complaint of discrimination that resulted in her termination. On appeal, the appellate court affirmed the ruling. The Supreme Court then granted the corporation’s petition for review, restricting its review to the preliminary question of whether the jury had sufficient evidence to find that, but for Plaintiff’s email, the corporation would not have terminated her. The Court emphasized that this “but-for” standard prevents employees who suspect they may be terminated from making unfounded discrimination claims in order to remain employed. After reviewing the totality of the evidence presented to support Plaintiff’s retaliation claim, the Court held that no evidence suggested Plaintiff would not have been terminated but for her email alleging discrimination. The Court especially considered Plaintiff’s refusal to conform her schedule to the corporation’s standard working hours, her repeated unauthorized overtime, and her statement that she no longer wanted to work for her supervisor. As a result, the Court concluded that this evidence, taken together with various statements indicating the corporation had already intended to terminate Plaintiff prior to the discrimination-alleging email, demonstrated that the but-for standard was not met.

Summary of Case Context & HoldingProperty owner Applegate-Bader Farm operated an 11,000 acre farm in southern Wisconsin; approximately 2,000 of those acres were enrolled in a federal Wetland Reserve Easement through the Agricultural Conservation Easement Program. The easement is permanent, so Applegate is unable to use the land for agricultural purposes. This case is over a 2015 revision to the Wisconsin Administrative Tax Code and the effect that that revision had on landowners with conservation easements. Applegate alleged that the Wisconsin Department of Revenue failed to consider environmental effects of the rule, and failed to prepare an Environmental Impact Statement of the rule. The rule changed the tax treatment of wetland easements on agricultural parcels of land, effectively removing the lowered tax assessment value for wetland easements on agricultural land. Applegate alleged that these changes would cause farmers to attempt to farm previously protected land. The Supreme Court conducted a two-step inquiry into the Department of Revenue's decision: (1) whether the Department developed a reviewable record that sufficiently considered the potential environmental concerns; and (2) whether the Department's determination that the action does not significantly impact the quality of the environment logically flow from the Department's investigation. Upon review of the Department's record, the Supreme Court found that the Department failed to take a "hard look" at the potential environmental effects of the rule noting that there was no "discussion, memoranda, e-mail, transcript or other documentation" on the Department's rationale to not prepare an Environmental Impact Statement of the rule. Therefore, it fails the first step of the inquiry. To remedy Applegate's case, the Supreme Court stayed the enforcement of the revision to the tax code and remanded the claim to the circuit court with instructions to remand the matter to the Department of Revenue for further investigation on its environmental effects.

Summary of Case Context & HoldingDevelopers purchased land from the operator of a neighboring golf course for development as a residential community and hired a contractor to construct erosion control structures and devices. A dam that the contractors built ruptured, causing mud, water and other debris to repeatedly flood the neighboring golf course. The local county natural resources department issued several notices of non-compliance to the developers for having taken insufficient measures to control erosion and sedimentation in violation of North Carolina law. The golf course operator subsequently brought suit against the developers and contractors, alleging, among other claims, violations of the Sedimentation Pollution Control Act of 1973 (SPCA). The Supreme Court held that the Plaintiff did not have standing to bring the SPCA claim because the Defendants had only received notices of non-compliance but had not been cited for violation of a relevant law, rule, order or erosion and sedimentation control plan. The Supreme Court held that a violation of, rather than mere noncompliance with, an erosion and sedimentation control plan must have occurred to give rise to a private cause of action under the statute.

Summary of Case Context & HoldingAppellant Applied Building Sciences, Inc. (ABS) was a tenant in a building condemned for public use by the South Carolina Department of Commerce, Division of Public Railways (Public Railways). Besides the just compensation for its leasehold interest, ABS was entitled to two types of reimbursements from Public Railways. First, under South Carolina Code Section 28-11-10, a relocating business can apply for reimbursement of reasonable expenses for moving tangible personal property, which Public Railways paid. Second, under South Carolina Code Section 28-11-30(4), a relocating business can seek reimbursement for other reestablishment expenses up to $50,000. ABS renovated the replacement site and sought reimbursement from Public Railways for reestablishment expenses exceeding $560,000. ABS argued that the $50,000 cap was unconstitutional under the Takings Clause of the Fifth Amendment of the U.S. Constitution and Article I, Section 13 of the South Carolina Constitution. The South Caroline Supreme Court held that (1) reestablishment expenses are separate from constitutional just compensation in an eminent domain action; and (2) the statutory cap of $50,000 on reestablishment expenses is constitutional. Specifically, the court explained that the party challenging the constitutionality of a statute bears the burden of establishing its unconstitutionality. The Court considered three precedents: (1) United States v. Petty Motor Co., 327 U.S. 372 (1946); (2) United States v. Westinghouse Electric & Manufacturing Co., 339 U.S. 261 (1950); and (3) Joslin Manufacturing Co. v. City of Providence, 262 U.S. 668 (1923). Petty Motor Co. established that the cost of removal or relocation should not be included in valuing the property taken because these costs “are apart from the value of the thing taken” and are “personal to the lessee.” Westinghouse Electric clarified that when the government takes a tenant's entire leasehold interest, the expenses of removal or relocation are not to be included in valuing what is taken. Joslin Manufacturing held that the cost of removing personal property from land taken is recoverable only if provided for by statute. Applying these precedents, the Court concluded that reestablishment expenses are separate from damages awardable as just compensation under the United States and South Carolina Constitutions. The Court further held that the General Assembly acts within constitutional confines and has plenary power to make policy decisions, including setting the $50,000 cap. Accordingly, the Court concluded that ABS had not met its burden of establishing that the $50,000 cap on reestablishment expenses in Section 28-11-30(4) is unconstitutional.

Summary of Case Context & HoldingSeveral large anti-gay activist organizations sought to challenge Wisconsin's domestic partnership law/civil unions under the state anti-gay marriage amendment, also known as Wisconsin Question 1, passed by popular referendum in 2006. The referendum (later nullified by Obergefell v. Hodges, 574 U.S. 1118 (2015)) created a state constitutional amendment that validated only marriage between one man and one woman. Further, the amendment stated that "[a] legal status identical or substantially similar to that of marriage for unmarried individuals shall not be valid or recognized in this state." The Supreme Court held that domestic partnership law did not create a legal status identical to or substantially similar to that of marriage, and thus, the law did not violate marriage amendment.