State Supreme Court Data Tracker

Summary of Case Context & HoldingDefendant police officers asserted qualified immunity as a defense to several civil rights claims, including false arrest, in a motion for summary judgment. The trial court rejected Defendants' claim that they were entitled to summary judgment based on qualified immunity because they did not have probable cause to arrest and because their beliefs were objectively unreasonable. Defendants claimed that the trial court's order denying summary judgment was a legal determination and therefore appealable under Rule 2:2-3(a)(3), which provides that final judgments can be appealed as of right. The Appellate Division ruled that the appeal was interlocutory and dismissed the appeal. The Supreme Court considered whether a trial court's order denying summary judgment is a legal determination and therefore appealable as of right. The Supreme Court held that a trial court's order rejecting as a matter of law a claim of qualified immunity should not be designated a final order appealable as of right under Rule 2:2-3(a), and federal law does not require the contrary result. In a New Jersey Civil Rights Act (NJCRA) action, a defendant seeking to challenge a trial court's order denying qualified immunity prior to final judgment must proceed by motion for leave to file an interlocutory appeal. The Court reasoned that the legislature's purpose in enacting the NJCRA (to provide a remedy for deprivation of or interference with civil rights) would not be advanced by appeal as of right.

Summary of Case Context & HoldingA state prisoner, Harris, brought a federal 42 U.S.C. § 1983 civil action against the prison's warden, Williams, and other state officials and employees alleging lack of adequate medical care for the prisoner's extreme chest pains in violation of the Eighth Amendment. The prison's warden brought a motion to dismiss for failure to state a claim, asserting that the complaint contained no facts that identified Williams by name, let alone alleged any personal involvement in Harris's care. In the alternative, Williams argued that he was entitled to qualified immunity as no alleged facts contended that he violated Harris's constitutional rights. Harris opposed, alleging additional facts to support Williams's notice of Harris's serious medical needs. The district court granted the motion, refused to allow Harris to amend the complaint, and dismissed his claims with prejudice. The remaining parties then filed motions to dismiss due to failure to properly serve state officials, which the district court granted without prejudice. The Supreme Court reversed and held that Harris properly pleaded a § 1983 action against Williams and that Harris's allegations sufficiently indicated that Williams was indifferent to Harris's complaints of debilitating chest pains over a six-month period and of his prison's staff's failure to respond to those complaints. Williams was required to review and answer Harris's filed grievances, which detailed Harris's debilitating chest pains, so when he denied said grievances, he did so with knowledge of and disregard for an "excessive risk to Harris's health." As such, the facts as initially pled supported a 1983 claim and put Williams on notice. Dismissal of the complaint was improper. Regarding Harris's failure to properly serve state officials, the Supreme Court held that Harris was entitled to a "reasonable" period of time to cure his failure to complete service on a state official. The district court's orders dismissing the complaint were reversed.

Summary of Case Context & HoldingA local radio host made allegedly defamatory remarks on the air about a local Republican political hopeful, Daniel McCarthy, after they both attended a "Stop the Steal" rally. McCarthy sued for defamation. Because McCarthy was a public figure, the "actual malice" standard applied. The Arizona Supreme Court readily concluded that seven of the nine statements at issue were nonactionable because they could not be construed as factual assertions as opposed to rhetorical political hyperbole. As to one of the remaining statements, that McCarthy had created a new political party, the Court concluded that was not defamatory even though it was provable as false. As to the other, that McCarthy told people he would put a million dollars into his campaign, the Court also concluded it was not defamatory—in context, the host was suggesting McCarthy did not have faith in his own campaign, which would be best understood as political commentary rather than objective fact. Citing the U.S. Supreme Court's jurisprudence on the importance of political speech under the First Amendment, the Court concluded that evolving standards of political discourse in talk radio made the challenged statements non-actionable.

Summary of Case Context & HoldingPlaintiff suffered a compensable accident and sustained injuries while he was walking at his job site. During the years after his work-related accident, Plaintiff continued to have neck pain. Plaintiff later sought permanent partial disability benefits. After a remand from the Supreme Court, the Industrial Commission (an agency of the state of North Carolina that administers among other things the state's Workers’ Compensation Act) entered an amended opinion and award denying benefits. The court of appeals affirmed, concluding that the Industrial Commission did not err in concluding that Plaintiff was not entitled to any compensation for permanent partial disability. The Supreme Court reversed and remanded, holding that the Industrial Commission failed to carry out the court of appeals’ mandate that it make additional findings of fact and conclusions of law on the issue of Plaintiff’s entitlement to benefits under N.C. Gen. Stat.§ 97-31. Because the amended opinion and award did not take into account all pertinent evidence, the Court could not determine whether the Plaintiff was entitled to benefits for a permanent partial impairment under the statute.

Summary of Case Context & HoldingPlaintiff, an employee of Health Network Laboratories Limited Partnerships and Leigh Valley Health Network, Inc., was fired as retaliation for whistleblowing/reporting to Health Network's Chief Operating Officer/Chief Compliance Office and "her chain of command" discriminatory and abusive conduct by one co-employee against another and brought suit against Health Network Laboratories and Leigh Valley Health Network under Pennsylvania's Whistleblower Law, 43 Pa. Const Stat. § 1423-24. Defendants, Health Network Laboratories and Leigh Valley Health Network, argued that the Pennsylvania Human Relations Act (PHRA) is the exclusive remedy for unlawful workplace discrimination, such that plaintiff could not bring suit under the Pennsylvania Whistleblower Law where the underlying basis for a Whistleblower Law retaliation claim is discrimination deemed unlawful under the PHRA. Defendants argued that Plaintiff was therefore required to exhaust administrative remedies as required by the PHRA. The Supreme Court held that "[whistleblower] plaintiffs who are not themselves the victims of discrimination based on their own race, color, familial status, religious creed, ancestry, handicap or disability, age, sex, or national origin, but who report discriminatory conduct made unlawful by the PHRA, may pursue a claim under the Whistleblower Law notwithstanding the viability of a claim under the PHRA for the same harm."

Summary of Case Context & Holding25 taxpayers challenged the Opportunity Scholarship Program, which allocated revenue from taxpayers to fund scholarships for low-income students to attend nonpublic schools. The trial court declared the program unconstitutional on its face and enjoined implementation of the Opportunity Scholarship Program, including the disbursement of public funds. The Supreme Court found that the trial court incorrectly declared the program unconstitutional because the Opportunity Scholarship Program does not preclude the state from continuing to support the public school system while also supporting outside initiatives to benefit society. To be specific, the Supreme Court held that (1) the program did not violate constitutional requirements for school funding; (2) the program did not violate the uniformity clause of the North Carolina Constitution; and (3) the appropriations made for the program were for a "public purpose." A key fact was that the program was funded out of the general fund, not by taking funds already earmarked for public schools.

Summary of Case Context & HoldingAn employee claims that he was terminated by his employer without cause, and subsequently amended his complaint to include an age discrimination claim, whereas the employer argued that it was due to the employee's lack of adherence to standards of professional conduct. The lower court granted summary judgment for the employer, denying the employee leave to amend. The Supreme Court clarified that age discrimination claims can be mixed-motive under Montana's Human Rights Act such that even if there were non-discriminatory justifications for firing an employee, the employee can prevail if they can show direct evidence of age discrimination or establish that the non-discriminatory justifications were pretextual. Mont. Code Ann. § 49-2-303(1)(a). Here, the Plaintiff's claim failed nonetheless because the employer had met its burden at summary judgment for showing good cause for the termination, and thus the lower court did not err in granting the employer's motion for summary judgment and denying the employee's leave to amend.

Summary of Case Context & HoldingPursuant to Section 2105–165 of the Department of Professional Regulation Law (the Act), the Illinois Department of Financial and Professional Regulation permanently revoked Plaintiffs' health care licenses to practice medicine due to their prior misdemeanor convictions of battery and criminal sexual abuse of their patients. Plaintiffs challenged their license revocations for several reasons: (1) they were convicted before the Act's effective date; (2) the Act was impermissibly retroactive; (3) it violated due process; (4) it was unenforceable based on res judicata related to previous discipline from the Department of Financial and Professional Regulation; and (5) violations of various federal and state constitutional protections, such as double jeopardy. First, the Supreme Court found that the Act applied to Plaintiffs because its language, "has been convicted," referred to health care workers with the status of having been convicted of a particular offense, regardless of whether the conviction occurred before the Act's effective date. Second, the Court rejected the retroactivity argument, reasoning that the Act did not reach back in time to change the criminal penalties imposed on Plaintiffs as a result of their convictions. Third, the Court analyzed Plaintiffs' due process arguments from both a substantive and procedural standpoint. Analyzing Plaintiffs' substantive due process argument, the Court held that a medical license is a property right subject to rational basis review, such that legislation must be upheld if a rational connection exists between its means and goals. The Court found the Act's licensing requirements rationally related to the protection of public safety, health, and welfare. Analyzing Plaintiffs' procedural due process argument, the Court found that Plaintiffs failed to allege a procedural due process violation because they received due process in the underlying criminal proceedings that led to their convictions. Fourth, the Court rejected the res judicata argument because the doctrine does not apply to the revocation of licenses, but would apply to preclude the Department of Financial and Professional Regulation from disciplining Plaintiffs again for their convictions. Fifth, the Court declined to address what it considered the Plaintiffs' underdeveloped arguments based on double jeopardy, bill of attainder, and other constitutional grounds. The Court affirmed the judgment of the appellate court and held that plaintiffs' complaints were properly dismissed.

Summary of Case Context & HoldingThe Miami Lodge No. 20, Fraternal Order of Police, a police union that represents the City of Miami's officers, made a claim for unfair labor practice against the City of Miami based on the city's unilateral approval of changes to its collective bargaining agreement (CBA) with the union after declaring a "financial urgency." In doing so, the city unilaterally altered the collective bargaining agreement without following the mandated resolution process laid out in the statute. The union sought review of the determination by the Public Employees Relations Commission, arguing that an employer must demonstrate that funds are available from no other possible source before unilaterally modifying a CBA, and said modification can only be made after completing the impasse resolution process. The Florida Supreme Court determined that (1) based on the plain language of the Florida Statute, which must be strictly construed because its application has the potential to impair two fundamental rights afforded to public employees, an employer must demonstrate that funds are completely unavailable from a reasonable source before unilaterally modifying a CBA; and (2) an employer must follow the resolution process mandated by Florida state law prior to unilaterally making changes to the CBA.

Summary of Case Context & HoldingPlaintiff was employed as a maintenance worker for First Amherst, a property management and maintenance company. The Plaintiff responded to a work order alleging that a bird had burrowed into the gutter through a hole, about six inches by six inches, and there was an excess of bird excrement soiling the entryway to the tenant's shop. Plaintiff had an eight-foot stepladder and a work truck and responded to the area of affected gutter. He intended to remove the bird's nest from the gutter, and then repair the hole in the gutter with sheet metal. The Plaintiff set up his ladder on the concrete dock flooring outside of the affected tenant's shop below the affected gutter. Plaintiff testified he used this particular ladder, because it was the proper elevation for the job. After tapping the gutter several times in an effort to dislodge the bird, the Plaintiff reached his hand into the gutter and the bird flew out causing the Plaintiff to fall from the ladder. To recover under Labor Law § 240(1) for an injury caused by a failure to provide such safety devices, plaintiffs must first show that they were engaged in one of that section's enumerated activities including, among others, "cleaning." To determine whether an activity is "cleaning" within the meaning of the statute, courts apply a four-factor analysis (see Soto v. J. Crew Inc., 998 N.E.2d 1045,1048-49 (N.Y. 2013)). The first factor considers whether the work is "routine, in the sense that it is the type of job that occurs on a daily, weekly or other relatively-frequent and recurring basis as part of the ordinary maintenance and care of commercial premises." The Court of Appeals held that a determination of whether the work was "routine" does not involve a fact-specific assessment of a plaintiff's regular tasks—it instead asks whether the type of work would be expected to recur with relative frequency as part of the ordinary maintenance and care of a commercial property. Consistent with this interpretation, the Court of Appeals held that Plaintiff's work was "routine" within the meaning of the first factor, which weighs against concluding that he was "cleaning." Therefore, Defendant's motion for summary judgment dismissing Plaintiff's Labor Law § 240(1) claim was granted.

Summary of Case Context & HoldingFollowing his termination, a white teacher in a public, independently operated school with a predominantly black student body brought a race discrimination claim against the company which owned and operated the school. The Plaintiff was fired for telling a racially charged joke and contended that black employees engaged in similar "racial banter" but were not disciplined. After the Plaintiff's termination, the school made mandatory disclosures of the plaintiff's unprofessional conduct which resulted in the Plaintiff having difficulty finding another teaching job. A lower court awarded damages to Plaintiff for both past and future economic losses. The Supreme Court reversed the decision in part by concluding: (1) the Plaintiff presented sufficient circumstantial evidence of racial discrimination and sustained the jury's verdict and award of past damages (because the past economic damages stemmed from the firing itself), but (2) vacated the jury's award of future damages because the future damages were predicated on the harm caused by the school's mandatory disclosures and the statute under which the school reported the conduct provides complete immunity to disclosing schools.

Summary of Case Context & HoldingHomeowners defaulted on a mortgage and the lender brought an action in court to judicially foreclose. The lender obtained a judgment for the amount due on the loan plus attorneys’ fees and a foreclosure judgment on the property. After sale of the property, the trial court entered a deficiency judgment against the homeowners. One of the homeowners appealed, arguing that the loan was entitled to the anti-deficiency protections contained in Ariz. Rev. Stat. Ann. § 33-729(A)—which provides that in choosing judicial foreclosure, the creditor can obtain a deficiency judgment in all cases except those dealing with purchase money collateral on the residential property. Given that the loan at issue was a construction loan and the court had, in a prior case, held that a “construction loan used to build a home that secures the debt qualifies as a purchase money loan" the homeowner sought anti-deficiency protection. Ultimately, the Supreme Court granted review to clarify the circumstances of when a loan is a “construction loan” and, thus, subject to the protection of Ariz. Rev. Stat. Ann. § 33-729(A)’s anti-deficiency provision (versus a “home improvement loan” which would not be). The Court explained that in making the determination courts should consider the “totality of the circumstances surrounding the loan,” but also identified the following five non-exclusive factors that may indicate whether a loan is a construction loan for purpose of the anti-deficiency provision: “(1) whether there was a complete or substantially complete demolition of an existing structure and a new building constructed in its place; (2) the intent of the parties when executing the loan documents; (3) whether the structure was inhabitable or inhabited during construction; (4) whether the structure was largely preserved and improved or substantially expanded; and (5) whether the project is characterized as 'home improvement' or 'construction' in the loan documents and in the permits or other official documents.” Applying those factors, the Supreme Court found that several facts suggest that the homeowners’ loan was a construction loan to which the anti-deficiency protection would apply. As a result, the Supreme Court vacated the opinion of the court of appeals and remanded to the trial court, directing that on remand, the trial court should consider the totality of circumstances surrounding the homeowners’ project and the loan, including factors set forth by the Supreme Court, and enter judgment in accordance with the trial court’s findings.

Summary of Case Context & HoldingIn 2015, Hennepin Healthcare used staffing agency workers and offered three-year service contracts to those workers. In 2018, Hennepin Healthcare renewed its service contracts with the staffing agency for another three year term. Before the renewal of the service contracts, AFSCME filed a grievance, arguing that Hennepin Healthcare's use of non-union subcontracted workers for more than six months violated their collective bargaining agreement. In 2020, the parties arbitrated the dispute. Hennepin Healthcare filed an action to vacate an arbitration award in favor of the healthcare workers' union (AFSCME) based on the arbitrator's finding that Hennepin violated the parties' collective bargaining agreement by using contracted workers for more than six months. The Supreme Court found that the arbitrator did not exceed its power when its decision "drew its essence" from the underlying collective bargaining agreement. In other words, the Supreme Court found that the arbitrator interpreted the collective bargaining agreement and parties’ mutual intent, so the award was rationally derived from the agreement and thus satisfied the essence test for upholding the award.

Summary of Case Context & HoldingBarbara Henry worked for Defendant school district as a network technician for nineteen years when she suddenly received two substandard reviews, and was placed on a performance improvement plan (PIP). After receiving a third negative review and written notice that the school district was considering terminating her employment, Henry resigned. Henry filed suit, alleging age-based harassment arising from a hostile work environment, and age discrimination. The district court granted the school district’s motion for summary judgment on both claims, ruling in part that Henry had voluntarily resigned from her position without taking advantage of the School District's anti-discrimination policies, and the court of appeals affirmed the dismissal of the hostile work environment claim, but reversed as to the discrimination claim because it concluded that Henry had presented sufficient evidence of disparate-treatment age discrimination to withstand summary judgment. The Supreme Court held: (i) the conduct did not rise to a level of pervasiveness or severity required to demonstrate that the alleged harassment affected term, condition, or privilege of employment, as required to establish a hostile work environment claim; (ii) there is no requirement that the employee alleging disparate-treatment-based constructive discharge under the Minnesota Human Rights Act (MHRA) attempt to mitigate the alleged mistreatment before resigning; (iii) whether the employee suffered adverse employment action in the form of a constructive discharge precluded the grant of summary judgment; and (iv) (reversing the court of appeal's determination in this respect) the employee did not establish an adverse employment action element for age-based disparate treatment under MHRA by relying on the cumulative effect of the employer's actions. In short, with respect to prong (iv), the Supreme Court rejected the court of appeal's expansion of “the concept of an adverse employment action” under the MHRA.

Summary of Case Context & HoldingFormer union employees brought suit against a labor union representing construction workers. Plaintiffs argued that the union violated the Michigan Whistleblowers' Protection Act (WPA) by terminating Plaintiffs in retaliation for reporting suspicions to the United States Department of Labor of (1) criminal activity including fraud and embezzlement; and (2) improper wages and unsafe working conditions. The union argued that the federal National Labor Relations Act (NLRA) and federal Labor-Management Reporting and Disclosure Act (LMRDA) both preempted the WPA and therefore the employees' claims should be dismissed. The Supreme Court partially affirmed the lower court's decision by ruling that the NLRA and LMRDA do not preempt WPA claims premised on reporting suspected criminal misconduct.

Summary of Case Context & HoldingDianne Hensley, a justice of the peace in McLennan County, Texas, charged $100 to officiate marriage ceremonies to opposite-sex couples. However, she did not perform same-sex marriages due to her religious beliefs but referred same-sex couples to others willing to officiate. The State Commission on Judicial Conduct (Commission) learned about her practice and opened an investigation and issued a warning. After Hensley challenged the Commission's warning in a hearing, asserting her speech was protected by the Free Speech Clause and that the Commission's sanction infringed on her beliefs in violation of the Texas Religious Freedom Restoration Act (TRFRA), the Commission issued its final Public Warning in November 2019, finding a violation of Canon 4A(1) of the Texas Code of Judicial Conduct. Hensley sued the Commission and its members and officers in district court under TRFRA. TRFRA provides that a government agency may not substantially burden the free exercise of religion unless it demonstrates that the burden is in furtherance of a compelling governmental interest and is the least restrictive means of furthering that interest. Hensley asserted that the Commission violated TRFRA through its investigation, Public Warning, and threat of future discipline if she resumes her referral system, and sought damages for lost income from performing opposite-sex weddings, declaratory relief, and injunctive relief prohibiting future Commission sanctions of her speech and conduct. She also asserted that because the commissioners acted ultra vires, they lost the protection of sovereign immunity. The Commission filed a plea to the jurisdiction, asserting that Hensley should have first exhausted her administrative remedies by appealing to the Special Court of Review (SCR), the exclusive forum the Legislature provides for appeals from Commission warnings. Second, the Commission contended that Hensley's claims were barred by sovereign immunity. The trial court dismissed Hensley's claims for lack of jurisdiction, and the court of appeals affirmed. The Supreme Court granted Hensley's petition for review. The Supreme Court held that Hensley was not required to exhaust the SCR appeal as an administrative remedy because that could not have mooted her claims. The Court also addressed the Commission's arguments that Hensley's action was barred by sovereign immunity. First, the Court determined that Hensley gave sufficient notice under TRFRA of the burden to her religious freedom because she had contended her protected religious freedom was burdened once the Commission opened an investigation, regardless of whether the Commission would agree she was burdened. Second, the Court held the trial court erred in relying on Section 33.006 of the Texas Government Code in concluding that it lacked jurisdiction over the Commission, because that section only provided immunity from liability, not immunity from suit, and thus could not be raised in a plea to the jurisdiction. Third, the Court held that the lower courts correctly concluded that the Commission's sovereign immunity was not waived for Hensley's request for a declaration regarding Canon 4A because Canon 4A, a rule promulgated by the Supreme Court, did not fall under the Uniform Declaratory Judgments Act, which applied to statutes and municipal ordinances. Finally, the Court held that sovereign immunity would not bar suits complaining of legal errors from the exercise of an officer's limited discretion, as here, because the commissioners' issuance of a warning over a TRFRA defense was necessarily limited due to the Commission's lack of absolute discretion to interpret and apply TRFRA. The Supreme Court affirmed the court of appeals' judgment dismissing Hensley's request for declaratory relief, but reversed the remainder of the judgment and remanded to the court of appeals for unaddressed issues remaining on appeal. Justice Blacklock wrote a concurrence, joined by Justice Devine, to resolve merits questions the majority remanded to the lower courts and stated that the Commission's actions did violate Hensley's legal rights. Justice Young, in a separate concurrence, opined that the lower courts should be allowed to address the merits first, if at all, because the parties themselves were not required to "keep pressing the merits." Last, in her dissent, Justice Lehrmann reasoned that a faithful application of the Court's precedent would have required the exhaustion of administrative remedies as a jurisdictional prerequisite to filing suit in the district courts. Judge Lehrmann took an opposite view from the majority in concluding that vacating the Public Warning would have extinguished any credible threat of future sanctions against Hensley, and emphasized that the exhaustion requirement would result in an orderly procedure to enforce a party's legal rights and could have resulted in a more streamlined and efficient TRFRA lawsuit against the Commission, had Hensley prevailed before the SCR.

Summary of Case Context & HoldingIn connection with a declaratory judgment action brought by Plaintiff, Herkimer County Industrial Development Agency, the Village of Herkimer sought a judgment through a counterclaim declaring the Plaintiff personally liable to the Village for certain unpaid water rents. These bills were incurred by the Plaintiff through a bond financing sale-and-leaseback transaction. The Court of Appeals held the law applicable to the subject property provided for a lien upon the real property, and not personal liability of the owner and accordingly concluded that the Plaintiff is not liable for unpaid water rents.

Summary of Case Context & HoldingOn August 25, 2020, Rainbow City, Alabama, held a municipal election for City Council, Place 1, in which Anita Bedwell was declared the winner by a single vote over Debbie Hiltz (880 to 879). Pursuant to Ala. Code § 11-46-69(b), Hiltz filed an election contest in the Etowah Circuit Court, alleging that several provisional ballots had been improperly excluded and could potentially alter the outcome. Bedwell responded by identifying two additional uncounted provisional ballots cast in her favor. After trial, the court ruled that five of the eleven challenged provisional ballots should be counted - three for Bedwell and two for Hiltz - bringing the final certified tally to 883 votes for Bedwell and 881 for Hiltz. The trial court declared Bedwell the winner under Ala. Code §§ 11-46-55(a) and 11-46-70, which govern certification and contest procedures for municipal elections. Hiltz appealed the judgment, arguing that Bedwell's "counterclaim" seeking to count additional ballots should have been procedurally barred because Bedwell had not formally filed her own election contest. The Alabama Supreme Court rejected that argument, interpreting Ala. Code §§ 11-46-69(a) and 17-16-56 to permit contestees to present evidence and responsive claims within the original contest without independently initiating a new contest. The Court referenced precedent, including Eubanks v. Hale, 752 So. 2d 1113 (Ala. 1999), which clarified that only challenges to those "declared elected" may be initiated (here, Bedwell) but a contestee (here, Bedwell) may still defend the outcome. The Court also upheld the circuit court's decision to count the two contested ballots favoring Bedwell, concluding that Bedwell made a prima facie showing under Ala. Code § 11-46-38 (voter eligibility) that the voters resided in Rainbow City and that Hiltz failed to rebut the evidence. Additionally, the Court ruled that the circuit court did not err in declining to open an additional ballot after determining it would not affect the outcome, pursuant to Ala. Code §§ 11-46-55(b) and 11-46-70, which outline how a majority is calculated and when reopening a ballot is necessary. Bedwell cross-appealed to challenge certain ballots counted for Hiltz, including those involving boundary-line residents governed by Ala. Code § 17-3-33, but acknowledged the issues were moot if the two ballots in her favor remained valid. Because the Alabama Supreme Court affirmed those ballots, it dismissed Bedwell's cross-appeal. The decision affirmed Bedwell's victory and clarified the legal standard for election contests in Alabama, confirming that contestees may defend results by raising additional ballot challenges in response to a properly initiated contest.

Summary of Case Context & HoldingHitchcock was sentenced to death in 2000 and later filed a motion for postconviction relief seeking Hurst v. Florida, 577 U.S. 92 (2016) relief (requiring that a jury find each fact necessary to impose a sentence of death). The circuit court summarily denied Hitchcock’s motion, concluding that the Supreme Court’s decision in Asay v. State, 210 So. 3d 1 (Fla. 2016) (denying the retroactive application of the U.S. Supreme Court's decision in Hurst as interpreted in the Florida Supreme Court's decision on remand (Hurst v. State, 202 So. 3d 40 (Fla. 2016)) to defendants whose death sentences were final when the U.S. Supreme Court decided Ring v. Arizona, 536 U.S. 584 (2002)) precludes relief. Because Hitchcock's death sentence was final before Ring, the Florida Supreme Court denied retroactive application of Hurst. However, Justices Lewis and Pariente wrote separately to question the nonretroactivity of Hurst. Justice Lewis wrote that the Court should analyze Hurst relief for defendants that had asserted the unconstitutionality of Florida's sentencing scheme during their trial and direct appeal rather than adopting a blanket rule against retroactivity. Justice Pariente took a stronger line, claiming that Hurst should be entirely retroactive because "a death sentence imposed without a unanimous jury verdict for death is inherently unreliable." Additionally, Justice Pariente took the position that it is an unconstitutional denial of due process for some defendants to receive the benefit of the Hurst decision and for others to not, based solely on whether their trial was before or after Hurst.

Summary of Case Context & HoldingPlaintiffs challenged the legal sufficiency of Initiative No. 171 (I-171) as unconstitutional and void and sought to enjoin the Secretary of State from submitting the measure for approval by the voters. I-171 would prohibit Montana and its political subdivisions from using funds, resources or personnel to administer or enforce the federal Patient Protection and Affordable Care Act (Affordable Care Act). The measure also would prohibit expansion of the Montana Medicaid Program as provided for by the Affordable Care Act and would prohibit the state and its political subdivisions from planning, creating, or participating in a health insurance exchange. Specifically, Plaintiffs argued that (1) the ballot statement are legally insufficient; (2) the measure addresses a matter concerning an appropriation of money and therefore is outside the initiative power of the State of Montana; (3) the measure contains more than one subject; and (4) the measure is unconstitutional and preempted under Supremacy Clause of the U.S. Constitution. Citing to MEA-MFT v. State, 318 P.3d 702 (Mont. 2014), the Supreme Court reiterated that "the Attorney General does not have the authority to make a declaration regarding the constitutionality of I-171." The Supreme Court also noted that it has not jurisdiction to consider alleged constitutional defects in the substance of a proposed ballot during an original proceeding under Mont. Code Ann. § 13-27-316(2) (as is the case here), but can consider such challenges in the ordinary course of appeal. Accordingly, the Supreme Court concluded that claims (2) through (4) raised by Plaintiffs did not meet the definition of a legal deficiency claim within the scope of the Attorney General's authority on review of a proposed ballot measure, and instead consisted of constitutional claims, such that the Supreme Court could not express an opinion. As to Plaintiffs' first claim, they argued that I-171's fiscal statement must not contain any explanation of the initiative, however, the Supreme Court observed that Plaintiffs cited to no authority for this claim, and denied it as well.

Summary of Case Context & HoldingA proceeding was brought to review the state's compliance with the comprehensive remedial plan (CRP) that was developed pursuant to a consent order to achieve its obligation under the North Carolina Constitution to provide all children the opportunity to obtain a sound basic education in public school. The trial court entered an order requiring transfer of state funds to fund the CRP. The Supreme Court held that not only do all children have the right to the opportunity to a sound basic education, the state must guard and maintain that right. The Supreme Court held the trial court acted within its inherent power in directing these funds to the CRP. Additionally, the trial court was correct in finding that the Budget Act (the North Carolina appropriations bill) did not satisfy the state's constitutional obligation to provide all children the opportunity to obtain a sound basic education in public school. Citing its authority to address constitutional violations through equitable remedies in the face of inaction by other branches of government, the Supreme Court also held that the order for transfer of funds did not raise a non-justiciable political question. Finally, the Supreme Court directed the trial court to recalculate the distribution of available state funds for an education program over two years.

Summary of Case Context & HoldingPlaintiffs were a family who owned land bordering a river. The Plaintiffs regularly kayaked down the river. Their neighbors issued trespass notices against them for using the river. The Plaintiffs filed an action seeking a declaratory judgment that they had a right to use the river. The river was considered non-navigable because it did not connect to state waters nor was it used for commercial shipping. The Court examined what riparian rights the Plaintiffs had over the non-navigable river. Non-navigable lakes create a right of use. However, the Court did not find any precedent that created a right of use for non-navigable rivers, which allow for easier designation of property lines than a lake. The Court held that Plaintiffs did not have a right to use the river for kayaking and urged the legislature to weigh in on this subject because there were several different policy arguments involved. The legislature has not yet taken any action.

Summary of Case Context & Holding[Overruled] Prospective voters brought a case against the North Carolina speaker of the House, Timothy Moore, and other legislative defendants, alleging that legislation requiring voter ID (i.e., government(local/state/federal)-issued IDs or qualifying college-issued IDs) violated the Equal Protection Clause of the North Carolina Constitution because the requirement would disproportionately weigh on black, impoverished voters. The bill was passed quickly by the Republican supermajority before they lost their majority in the General Assembly and it was passed without sufficient information to inform voters about the impact the bill would have. The Supreme Court noted that the North Carolina Constitution requires voters to present photographic identification, but also noted that the North Carolina Constitution finds violations of equal protection when laws are motivated by racially discriminatory purposes. The Supreme Court found (1) the law would disparately impact on black voters in North Carolina who may not have ID or have easy access to ID and it would disproportionately discourage blacks from voting; (2) the current law evolved from the racially polarizing historical background of strong Jim Crow laws in North Carolina and striking down of racial gerrymandering in Cooper and Rucho; and (3) the bill was passed in a rush without giving voters proper information, the legislators struck down amendments that specifically would have favored black people, and the legislators did not request information about the impact this specific bill would have on the state's black population. Based on these findings, the Supreme Court found that the bill was passed with a discriminatory intent to target black voters. The Supreme Court also found that the law would not have been enacted but for the racial animus because the legislature did not sufficiently consider the impact on the black voters and there was little evidence voter ID would prevent voter fraud or that there was high voter fraud in the state.

Summary of Case Context & HoldingProspective voters brought a case against the North Carolina speaker of the House, Timothy Moore, and other legislative Defendants, alleging that legislation requiring voter ID violated the Equal Protection Clause of the North Carolina Constitution because the requirement would disproportionately weigh on black, impoverished voters. After the Supreme Court ruled that the law violated the North Carolina constitution, the legislative Defendants appealed to the Supreme Court's decision claiming that the Court reversed the burden of proof by disregarding the presumption of legislative good faith and so erred in finding the law was enacted with discriminatory intent. The Defendants also asked the Supreme Court to reconsider the decision in light of the federal circuit finding in another case that the same North Carolina voting law was not enacted with discriminatory intent. In rehearing, the Supreme Court first said that the Court would presume laws enacted by the General Assembly are constitutional and the Court would not hold it invalid unless unconstitutional beyond a reasonable doubt. Using that standard, the Supreme Court said that a law will be found to violate the state constitution if (1) enacted with discriminatory intent; and (2) the law produces a meaningfully disparate impact along racial lines. Ultimately, this Supreme Court found that the prior Supreme Court over-relied on historical evidence which does not bear on a current law's constitutionality and over relied on the brevity of the legislative process which does not create so strong of an inference of bad faith to overcome the presumption of legislative good faith. In all, the Supreme Court indicated the prior Supreme Court presumed legislative bad faith rather than good and so flipped the standard. The Supreme Court found that the evidence used by the prior Supreme Court was misleading because (1) the prior court referenced hypothetical voting inconveniences not based on hard facts; and (2) the prior court emphasized the lack of racial data/impact considered in this specific bill when this data had been considered for the prior version of the bill. The evidence brought by the Plaintiffs did not prove beyond a reasonable doubt that the voter ID law was enacted with discriminatory intent or would have a meaningfully disparate racial impact.

Summary of Case Context & HoldingDeyundrea “Khali” Holmes was convicted of first-degree murder and robbery. On direct appeal, Holmes argued that the district court erred (among other evidentiary arguments) by admitting inflammatory rap lyrics from his song "Drug Deala," which Holmes wrote while in California jail. The lyrics read, in part, "I catching slipping at the club and jack you for your necklace. . . . Man I'm parking lot jacking, running through your pockets with uh ski mask on straight laughing." In fact, Holmes wore a ski mask the night he murdered and robbed the victim. The Court held that the district court did not err in admitting the rap lyrics to prove the State's case-in-chief. While the Court acknowledged that the potential for prejudice existed, the probative value of the rap lyrics, which relayed very similar facts to the crime charged, was not substantially outweighed by the danger of unfair prejudice, namely, that the jurors, unversed in rap, would misinterpret Holmes's exaggerated, artistic lyrics as fact. In dissent, Justice Saitta would have found that the district court abused its discretion in admitting the rap lyrics, finding that the lyrics were artistic expression, not an admission, and that the lyrics were not sufficiently specific to be relevant to the charged crime.

Summary of Case Context & HoldingYork County in South Carolina imposed an impact fee passed pursuant to the South Carolina Impact Fee Act (the Impact Fee Act), codified under S.C. Code Ann. §§ 6-1-910, on new home construction in School District No. 4. The imposed impact fee is a charge on new development projects in order to fund the costs of providing public services like infrastructure, including the building of public roads, school and utilities. Local developers grouped together under the Home Builders Association of South Carolina (HBASC) and challenged the fee, claiming that the Impact Fee Act was (1) unconstitutionally vague; and (2) violated their right to substantive due process. HBASC further argued that the Impact Fee Act required York County to consider the impact on affordable housing caused by the proposed impact fee, and the Impact Fee Act did not provide sufficient guidance on how to accomplish its directive. Due to the fact that the case rests on a constitutional issue, the South Carolina Supreme Court had jurisdiction to hear and decide the case. The Court held that Impact Fee Act is valid on its face. In particular, it was not unconstitutionally vague and did not violate the right to substantive due process. First, the Court reasoned that the Impact Fee Act's definition of affordable housing as "housing affordable to families whose incomes do not exceed 80% of the median income for the service area or areas within the jurisdiction of the government entity" was sufficient to avoid being facially void for vagueness. This conclusion is further supported by the fact that the United States Department of Housing and Urban Development established that a household is cost-burdened if it spends more than 30% of its income on housing and severely cost burdened if it spends more than 50% of its income on housing. The statutory language here conveys sufficient definite warnings as to the proscribed conduct when measured by common understandings and practices. The standard measure for determining the degree of burden a household faces due to housing expenses further clarifies the Impact Fee Act's scope and does not make it void for vagueness. Second, the Court also found that the Impact Fee Act does not violate an individuals' right to substantive due process. The Court reasoned that the party asserting a violation of their right to substantive due process must show that they were arbitrarily and capriciously deprived of a cognizable property interest. Here the localities have a choice of whether to fund (but are not required) via an impact fee on any new school construction. This choice was backed by a legitimate interest in providing education for the youth and was not facially arbitrary and capricious, and accordingly did not violate substantive due process.

Summary of Case Context & HoldingPlaintiffs, guardians of patient's estate, brought a negligence action against an emergency room physician and his employer. The patient, a disabled person, suffered a severe and permanent brain injury after Dr. Murphy, a physician working in the emergency room, responded to patient's Code Blue and attempted intubation. Defendants moved for summary judgment under Section 25 of the Good Samaritan Act (the Act) because it provides that any licensed person who provides medical care without a fee cannot be held liable for civil damages except in circumstances involving willful misconduct. The doctor argued that Section 25 did not apply because the patient was not billed for the doctor's services during the Code Blue, only for supplies. However, Plaintiffs argued that the doctor was not providing services "without fee" because his employer paid him by the hour, and he was not even allowed to bill patients directly. The trial court granted summary judgment to Defendants, but the appellate court reversed, reasoning that the statute's ambiguous reference to "fee" could broadly encompass the patient being billed or the physician being paid. The Supreme Court affirmed the judgment of the appellate court, holding that Section 25 did not apply to a physician responding to an emergency when paid to do so. The Court reasoned that the Act was designed to encourage physicians to voluntarily render aid to an injured person despite not having a duty to do so. In contrast, physicians paid to respond to emergencies do not need the incentives at the heart of a Good Samaritan statute. The Court also presumed the legislature did not intend "absurd, unjust, or inconvenient results" such as a disparity of legal remedies between affluent and indigent patients, whereby doctors could be immunized from liability for rendering substandard services to patients who could not pay. Finally, the Court was also persuaded by the fact that under modern billing practices, most doctors are not directly compensated by their patients. Therefore, construing "fee" to include a doctor's compensation, whether it came from the patient or another source, would effectuate the legislature's intent.

Summary of Case Context & HoldingIn May 2016, Support Independent Maps (Independent Maps), a registered ballot initiative committee, filed with the Secretary of State a petition proposing an amendment to the Illinois State Constitution, to replace the current system for redrawing Illinois's legislative and representative districts. In response, taxpayers (specifically, a political committee called People's Map, along with its chairperson, John Hooker, and individual members and leaders of other groups) brought a declaratory judgment action to restrain expenditure of public funds related to the proposed constitutional amendment regarding legislative districts. The Plaintiffs argued that Independent Maps should not be allowed to place a constitutional amendment to introduce an independent redistricting commission on the ballot in November 2016 because the amendment fell outside the scope of permissible ballot initiatives according to the Illinois State Constitution, which limits permissible initiatives to "structural and procedural subjects." Although Independent Maps was not originally included as a party, it was later granted leave to intervene. Following appeal, the Supreme Court held that the proposed ballot initiative concerning the constitutional amendment regarding redistricting violated constitutional limits on amendment through initiative because, in assigning new duties to the Auditor General, it was not "limited to structural and procedural subjects." The framers of the constitution chose to limit the scope of ballot initiatives in Article XIV, Section 3. Specifically: "Amendments shall be limited to structural and procedural subjects contained in Article IV." In this case, Article IV does not mention the "subject" of the Auditor General's office or its duties even in passing. And the duties of the Auditor General have never been and are not a subject contained in Article IV as currently constituted. Thus, that provision is not a proper "subject" of the legislative article.

Summary of Case Context & HoldingThe Arizona Snowbowl Resort Limited Partnership (Snowbowl) operates a ski resort in the San Francisco Peaks in the Coconino National Forest north of Flagstaff, Arizona. The Hopi Tribe (the Tribe) challenged Snowbowl’s activities in the San Francisco Peaks for many years. The Hopi Tribe filed this action in 2011 against the City alleging claims under various state laws, including, among other things, that the City’s “sale of reclaimed wastewater to make artificial snow” is a public nuisance that “will result in unreasonable harm to the environment and the Hopi Tribe.” More broadly, the Tribe alleged that “the Snowbowl expansion project, H3 “additional traffic,” and the very “presence of the Snowbowl Resort” itself will adversely impact the “natural environment” and unduly interfere with the Tribe’s cultural use of the public wilderness for religious and ceremonial purposes. Snowbowl moved to dismiss the public nuisance claim, arguing that the Tribe failed to sufficiently allege the type of damages necessary to maintain a public nuisance. However, the court of appeals concluded that the Tribe had successfully shown that the use of reclaimed wastewater caused it “a special injury, different in kind than that suffered by the general public, by interfering with places of special cultural and religious significance to the Tribe.” Hopi Tribe v. Ariz. Snowbowl Resort Ltd., 418 P.3d 1032, 1034 (Ariz. Ct. App. 2018), vacated and remanded, 430 P.3d 362 (Ariz. 2018). The Supreme Court disagreed holding that the Tribe's alleged injury from environmental damage from reclaimed wastewater for artificial snowmaking on public land that had religious and cultural significance to the Tribe, was different in degree but not in kind or quality than that suffered by the public, and accordingly the Tribe did not sufficiently allege the special injury necessary to maintain a public nuisance claim in connection with the City's sale of reclaimed wastewater to the ski resort. The Supreme Court reasoned that although the Tribe alleged harm to its special interest in the environment, including its right to use and enjoy the land in its unimpaired, natural condition, the Tribe shared that right with the public. The Tribe did not specifically allege any property interest, or that sale or authorized use of reclaimed wastewater impaired federal statutory rights of access or privacy for traditional or cultural activities, and the Tribe did not specifically allege how frequently it used the land for religious or cultural purposes.

Summary of Case Context & HoldingThe Plaintiff fell and injured herself while walking on the premise of her employer during a required break. The employer denied the employee's claim related to the injury, arguing that the injuries did not arise out of and in the course of her employment. The Supreme Court held that the employee's injuries occurred in the course of her employment under the premises-related or parking-lot exception since she was injured within a reasonable time of leaving work, as she was injured at the start of her 15-minute break.

Summary of Case Context & HoldingHorsley was a juvenile when he committed first-degree felony murder for which he would later be convicted and sentenced to mandatory life without parole. A year after his sentencing, the U.S. Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012) which found mandatory life sentences without parole for juveniles to be unconstitutional, and the State of Florida sought to revive an older statute that would have maintained Horsley's sentence but afforded him the opportunity for a parole hearing after 25 years of incarceration. Horsley appealed his sentence under the Miller ruling. The Florida Supreme Court held that the appropriate remedy is to retroactively apply a Florida statute that requires individualized sentencing that weighs factors such as age, background, and potential for rehabilitation, to all juvenile offenders whose sentences became unconstitutional under Miller. Horsley's case was subsequently remanded to be assessed under the new standard.

Summary of Case Context & HoldingIn a two-week period, Defendant Gregory Hover kidnapped, sexually assaulted, robbed, and murdered multiple victims, specifically targeting Latinos. Among numerous convictions, Hover was convicted of two counts of murder with the use of a deadly weapon, for which the jury sentenced him to death. On appeal, Hover assigned various errors including the following that were rejected: (1) Though certain members of the jury pool were inclined towards harsher punishment, that alone did not prohibit them from serving on the jury where each potential juror stated they would fairly consider all available penalties and, in any event, the challenged jurors were not empaneled; (2) Where a juror stated that she would not impose the death penalty unless the defendant was proven guilty beyond any doubt, not any reasonable doubt, the Court found no error in the dismissal, as the juror was required to apply the reasonable doubt standard; (3) Under Batson v. Kentucky, 476 U.S. 79 (1986), where the State struck one African-American juror from the panel while another African-American juror remained, and where the State proffered several race-neutral reasons for striking the juror, the district court did not err in denying Hover's challenge; (4) Hover's request for a PET scan was appropriately denied where Hover actually requested an MRI scan and because, absent some basis for the request, the Court was not required to order a PET scan merely because Hover was facing the death penalty; (5) Hover objected to allowing a gruesome photograph tending to show that Hover sexually assaulted one of the victims via anal intercourse as unduly prejudicial; the Court found no abuse of discretion in allowing the photograph because the photo corroborated testimonial evidence and was relevant to establishing an aggravating circumstance; and (6) Hover argued that the death penalty violated the Eighth Amendment of the U.S. Constitution's prohibition against cruel and unusual punishment (and the corresponding Nevada provision) affirming the constitutionality of the death penalty, the Court rejected this challenge. On review of Hover's death sentence, the Court first found there was sufficient evidence of the aggravating circumstances given the multiple convictions for other serious crimes. Second, the verdict was rendered impartially. Finally, the death sentence was not excessive given the "plethora" of other violent crimes committed in Hover's two-week spree. Justice Cherry dissented, arguing for reversal as the district court should have ordered the PET scan despite any deficiency in Defendant's request as that evidence could have undermined Hover's mens rea and mitigated his conduct.

Summary of Case Context & HoldingAppellant Samuel Howard was convicted of first degree murder and sentenced to death. His death sentence was based on one aggravating factor: a New York conviction for a felony involving the use of the threat of violence against another person. Many years after his conviction and sentence, a New York court vacated the conviction and dismissed the charge. Howard than filed a habeas petition arguing that he was now actually innocent of the death penalty such that he overcame the procedural bars to post conviction habeas petitions. The Court agreed, reasoning that Nev. Rev. Stat. § 200.033(2), which provides that first-degree murder is aggravated if the individual is convicted of another murder or violence felony, cannot continue to serve as an aggravating factor if the conviction is later dismissed. Further, Howard showed reasonable diligence in pursuing his petition because he filed it shortly after the New York court dismissed his conviction.

Summary of Case Context & HoldingHowell was convicted of first-degree murder and sentenced to death. Howell made three motions for postconviction relief. Upon the denial of the third motion, Howell filed an appeal challenging Florida's lethal injection protocol. Howell argued the drugs and method used in the lethal injection violated the Eighth Amendment. The Supreme Court rejected Howell's arguments as failing to meet the high requirements needed to demonstrate an Eighth Amendment violation. The Supreme Court subsequently upheld the use of lethal injection for administering the death penalty in the State of Florida.

Summary of Case Context & HoldingTiara Young Hudson, an attorney who had been a candidate for appointment and election to a county judgeship before its reallocation to another county brought an action which named the Governor, the Chief Justice, and the judge appointed to reallocated judgeship as Defendants. Following a judge's retirement in Hudson's county, the Governor reallocated the judgeship to another county, depriving Hudson of the chance for appointment and election. Hudson's action sought a judgment: (1) declaring that the act providing for the reallocation of judgeships, § 12-9A-1 et seq. (the Act), Ala. Code 1975, violated the Alabama Constitution; (2) a permanent injunction removing the other county's circuit judge who had been appointed to fill the reallocated judgeship; and (3) directing the Governor to appoint a new person nominated by the original county's judicial commission to fill the judgeship in the original county. The circuit court dismissed the action for the following reasons: (1) the trial court lacked subject-matter jurisdiction because a quo warranto action—not a declaratory-judgment action—provided the exclusive remedy under the circumstances; (2) Hudson lacked standing because she had not suffered an injury in fact and because, the defendants claimed, her purported injury was neither caused by nor capable of being redressed by the named defendants; and (3) Hudson had failed to state a claim upon which relief could be granted because the legislature had lawfully empowered the Alabama Judicial Resources Allocation Commission to reallocate the judgeship. Hudson appealed asserting the Act was an unconstitutional delegation of the legislative authority to establish circuit-court judgeships. The Defendants moved to dismiss for lack of subject matter jurisdiction because writ of quo warranto (not declaratory judgment) was the exclusive remedy for Hudson. Writ of “quo warranto” is a common law writ used to determine whether one is properly qualified and eligible to hold a public office. Ala. Code § 6-6-591. Additionally, the Defendants argued Hudson lacked standing and failed to state a claim which relief can be granted. This Alabama Supreme Court agreed with the Defendants and found that a writ of quo warranto, rather than a declaratory action, was the exclusive remedy available because the claim was not one that merely concerned the interpretation of the statute and was instead directly aimed at challenging the newly appointed judge's exercise of his judicial office. Therefore, the Court affirmed the lower court's judgment dismissing the declaratory-judgment action for lack of subject matter jurisdiction. The Court did not address the constitutionality of the Act or Hudson's standing to seek declaratory relief.

Summary of Case Context & HoldingIn 2003, William Hueble purchased 220 acres of farming and hunting property in Greenwood County. At the time of closing, the seller informed Hueble that Respondent Eric Vaughn, a corporal for the South Carolina Department of Natural Resources (DNR), had hunted deer on the property. The seller indicated it would be a "good idea" to allow Vaughn continued access. Hueble declined the suggestion. In 2004, Hueble received a call from the seller informing him that Vaughn had recently been on the property and left four wheeler tracks. The seller again suggested that it would be in Hueble's "best interest" to allow Vaughn to hunt on the property, and provided Vaughn's phone number to Hueble. Hueble once again declined the suggestion and did not contact Vaughn. Hueble then acquired additional land and invested substantial sums of money to improve and maintain his property for hunting dove. More than one month prior to the opening day of dove season, Hueble believed the field was in compliance with all regulations and guidelines. On opening day, Hueble's friends and family joined him for the first hunt of the season. Shortly into the hunt, Vaughn and other DNR officers entered Hueble's property unannounced. Vaughn and the DNR officers gathered the hunters together and began threatening them with fines and confiscation of property for baiting (using food or attractants to lure animals) the dove field. Vaughn dug into Hueble's property with a knife blade to produce seeds and claimed that one seed constituted baiting a field. During this interaction, Hueble learned Vaughn was the DNR officer the seller had mentioned. Ultimately, Hueble was the only hunter charged by DNR with baiting the field. Hueble ultimately pled no contest to the baiting charge, believing this would resolve Vaughn's animosity. However Hueble was accused again of baiting at the start of turkey season. Based on these encounters with Vaughn, Hueble believed that Vaughn had a "vendetta" against him and that Vaughn's supervisor was fully aware of the alleged threats he was making against Hueble. Because of these concerns, Hueble brought a complaint with Vaughn's supervisor at DNR. However, the supervisor responded with allegations of Hueble's illegal activity based upon Vaughn's version of the events. Hueble then filed a complaint against DNR and Vaughn asserting several state law causes of action, along with a 42 U.S.C. § 1983 claim for the violation of his constitutional rights to due process and equal protection. Following a hearing where the court encouraged the parties to settle, Vaught and DNR made a joint offer of judgment which Hueble accepted. Hueble thereafter filed a motion for attorneys' fees and costs under 42 U.S.C. § 1988 of the Civil Rights Act which provides a statutory right to attorneys' fees to prevailing parties in civil rights cases designed to curtail unconstitutional behavior. The trial court denied Hueble's motion, finding Hueble was not a prevailing party and even if he was, an award of attorneys' fees and costs would be unjust. On appeal, the South Carolina Supreme Court determined that Hueble qualified as a prevailing party because a judgment in his favor, and against DNR, was entered for $5,100 which materially altered the legal relationship between the parties by imposing an enforceable obligation against Vaughn and DNR to pay Hueble $5,100. The Court also agreed with Hueble that the special circumstances exception was to be applied narrowly and in this particular case did not warrant the denial of attorneys' fees. The Court disagreed with the trial court that the fact that Hueble's recovery was nominal, he failed to achieve his desired relief (barring Vaughn from the property), and Vaugh's counterclaim was settled for five times more constituted special circumstances sufficient to deny the fees.

Summary of Case Context & HoldingDefendant is appealing his conviction of murder in a criminal trial on the grounds that, among other things, there was adequate provocation such that a conviction for the lesser crime of voluntary manslaughter was warranted. Defendant argued that he and the victim had previously engaged in homosexual acts, which the victim had videotaped and published to the internet and to the Defendant's girlfriend, in combination with the Defendant's PTSD, difficulties with impulse control, and inebriation, constituted adequate provocation and lack of the required mens rea. The Supreme Court affirmed the conviction, finding that the claimed provocation was insufficient to excite the requisite passion in a reasonable person.

Summary of Case Context & HoldingFollowing a fatal accident, officers insisted that the Defendant (who was the driver of a vehicle involved in the fatal accident) submit to a blood test. The Defendant did, but he later moved to suppress the results of the blood test, asserting that the officers were without probable cause to believe that he had been driving under the influence. The Supreme Court concluded that the court of appeals reached the right result and properly reversed the trial court's grant of Defendant's motion to suppress. The Supreme Court held that taken together, a reasonable officer could conclude that driving under the influence was an equally or more probable explanation following the fatal accident based on the officer believing that Defendant drove through a red light and caused the accident and that a number of unknown pills were found on his person. The job of the trial court was to determine whether a reasonable officer could have concluded that the Defendant probably was under the influence and whether the officer had probable cause to believe as such. The existence of probable cause is a legal question as to which the appellate courts owe no deference to trial judges.

Summary of Case Context & HoldingA jury convicted the Defendant of two counts of malice murder and numerous related crimes. Defendant waived his right to a jury trial as to sentencing for the murders. At a bench trial on sentencing, the trial court found the existence of multiple statutory aggravating circumstances and sentenced the Defendant to death for each of the murders. The Supreme Court held that the trial court improperly determined that certain of the non-murder counts merged with the murder counts. In particular the Supreme Court determined that the felony murder counts should have been vacated as surplusage rather than "merged" into the malice murder counts. As a result, the Defendant was yet to be sentenced for some of the crimes that he was validly convicted of, including possession of a firearm by a convicted felon and armed robbery. The Supreme Court remanded the case for resentencing. The Defendant further argued that the trial court committed reversible error by denying his request to remove his co-counsel. The Supreme Court held that an indigent defendant in Georgia does not have an absolute right to the attorney of his own choosing and the choice of appointed counsel is a matter of the trial court's discretion. Both of his counsels testified that the Defendant was adamant that unless he was not convicted, he did not want to spend his life in prison, and considered a bench trial “his best bet” to secure a death sentence. The Supreme Court found that even if there was trial counsel error and grounds for Defendant's assertion of ineffective assistance of counsel, the new mitigating evidence would not in reasonable probability result in a different sentencing verdict for the brutal murders. Additionally, the Defendant contended that his execution after a delay of approximately nine years between trial and appeal would violate the Eighth Amendment's proscription against cruel and unusual punishment. The Supreme Court noted that the U.S. Supreme Court has denied similar Eighth Amendment challenges to the imposition of the death penalty in cases where the inmates had been on death row for periods significantly longer than a decade, and federal Courts of Appeal have held that prolonged incarceration under a sentence of death does not violate the Eighth Amendment.

Summary of Case Context & HoldingPatricia Hulsmeyer was a registered nurse who reported suspected abuse of an older patient being cared for at the facility where she worked. She took photographs of suspected abuse and spoke to the patient’s family after she filed her report with her employer. The hospice provider terminated Hulsmeyer for three violations of policy: (i) Hulsmeyer permitted photos of the patient to be taken without authorization; (ii) Hulsmeyer notified the residential care facility operator and the patient’s daughter of the suspected abuse or neglect without first notifying the hospice provider; and (iii) Hulsmeyer improperly shared the patient’s photos at a patient-care conference to discuss the patient’s care. Hulsmeyer sued her former employer, alleging retaliatory discharge for terminating her for reporting suspecting abuse or neglect. Previous Ohio rulings had only extended whistleblower protections to those who reported abuse to governmental agencies. The Supreme Court held that while reporting to the Director of Health is a requirement of R.C. 3721.22(A) (the statute which requires reporting of suspected abuse or neglect), it is absent from R.C. 3721.24 (the whistleblower protection statute). The Supreme Court therefore found that the plain language of R.C. 3721.24 protects employees or other persons used to perform work or services from retaliation for reporting or indicating an intention to report suspected abuse or neglect of residents of long-term-care facilities or residential-care facilities and does not require that the report be made to the director of health. The Supreme Court remanded the specifics of Hulsmeyer's claim to a trial court.

Summary of Case Context & HoldingHurst was convicted and sentenced to death for first degree murder. Hurst appealed the constitutionality of Florida's sentencing scheme to the U.S. Supreme Court, arguing that Ring v. Arizona, 536 U.S. 584 (2002) holds that a jury, not a judge, must find the aggravating factors necessary to impose the death penalty. The U.S. Supreme Court heard arguments on this case in Hurst v. Florida, 577 U.S. 92 (2016), and held that Florida's sentencing scheme was unconstitutional because it allowed a judge to make the findings necessary for the death penalty, instead of a jury. The U.S. Supreme Court remanded the case back to the Florida Supreme Court, which further held that in death penalty cases, juries must be unanimous in finding that all aggravating factors are proven beyond a reasonable doubt, that the aggravating factors are sufficient to impose death, that the aggravating factors outweigh the mitigating circumstances, and are unanimous in recommending a sentence of death. Hurst's case was remanded for a new penalty phase. Subsequently in State v. Poole, 297 So. 3d 487 (Fla. 2020), the Florida Supreme Court limited its holding, stating that under Hurst the jury finding need not "[require] anything more than the jury to find an aggravating circumstance."

Summary of Case Context & HoldingTwo property owners brought suit against the owners and operators of nearby poultry farms for fraud, nuisance, trespass, and intentional interference with property rights due to persistent foul odors. The poultry farms appealed a jury verdict awarding damages for a temporary nuisance. The district court reversed the damages award but granted Plaintiff's motion for a permanent injunction that effectively shut down farm operations indefinitely. On appeal to the Texas Supreme Court, the farm owners and operators challenged the injunction, raising three issues: (1) whether the trial court abused its discretion in finding imminent harm; (2) whether equitable relief was unavailable because damages provide an adequate remedy; and (3) whether the scope of the injunction was overly broad. While the Court rejected the first two issues, it held that the trial court abused its discretion in crafting the scope of the injunction, finding it broader than necessary to abate the nuisance. The Court explained that a court "may go no further than necessary to remedy the plaintiff's injury" and that it is up to defendants to determine whether it is "economical or desirable to continue operating under such modifications." Further, the Court found that the injunction incorrectly prohibited conduct that had not been shown to produce similar nuisance injuries. Lastly, the Court found that the district court acted arbitrarily in setting the scope of the injunction and that on remand should "conduct a defendant-specific balancing of the equities" to inform appropriate corrective measures.

Summary of Case Context & HoldingRock Island Clean Line (RICL) intended to build a power line through Illinois. RICL did not manage any other public utilities and had not done any work of this sort before. RICL went to the Illinois Commerce Commission (ICC) for the required certificates needed to construct the power line. The ICC granted the certificates. Various groups sued to challenge the approval because RICL did not qualify as a public utility under the Public Utilities Act, which was a requirement for issuing the certificates. The Court held that the statute clearly required a party to be a public utility to be granted the certificate requested. Because RICL had no pre-existing business as a public utility, the ICC did not have authority to grant the necessary certificates.

Summary of Case Context & HoldingDefendant, an intellectually-low functioning 12 year old by who was a victim of sexual abuse, had a history in the delinquency system. Defendant had been placed in specialized foster care due to allegations of indecent assault against his younger sister. Over time, Defendant committed additional offenses, including sexual harassment by communication, leading to his adjudication as delinquent and the court determined that Defendant was in need of treatment and supervision. However, because of his combination of sexual misconduct, history of fire-starting, and low intellectual function, most residential treatment facilities (RTFs) either refused to treat him or lacked appropriate treatment programs, and he was not receiving adequate treatment at his current RTF. A bed became available in a facility designed to treat offenders like the Defendant and the facility agreed to take him, but later said they could not accept him because they had an agreement with their township not to accept juveniles currently adjudicated for a sexual offense and they could only accept him if his delinquency supervision was terminated. After exploring multiple potential facilities, the juvenile court terminated Defendant's delinquency supervision, and the Commonwealth appealed. The Supreme Court held that the termination of Defendant's delinquency supervision was proper because it was done for a "compelling reason." Specifically, it was necessary for the Defendant to immediately obtain appropriate treatment, as no other facilities could immediately meet his needs.

Summary of Case Context & HoldingJustin B., a minor, was found delinquent by a South Carolina family court for committing criminal sexual conduct with a minor in the first degree. The family court imposed the mandatory statutory requirement that he register as a sex offender and wear an electronic monitor, both for life. Justin B. claimed the mandatory imposition of lifetime registration and electronic monitoring on juveniles is unconstitutional, and on appeal to the Supreme Court, argued this point under four legal theories (i) that based on the U.S. Supreme Court's ruling in Roper v. Simmons, 543 U.S. 551 (2005), which highlighted key differences between juveniles and adults (such as maturity, vulnerability to influence, and less fixed character traits), the sex offender registry requirement should be reconsidered for juveniles; (ii) that mandatory lifetime registration violates the State’s duty to protect children under the doctrine of parens patriae (the legislative doctrine of making and enforcing laws looking to the education, welfare, and protection of its youth or other individuals with limited legal authority or ability to advocate for themselves); (iii) that mandatory lifetime registration violates the South Carolina Children's Code; and (iv) that this matter is distinguishable from previous cases (such as In the interest of Ronnie A., 585 S.E.2d 311 (S.C 2003)) affirming that a nine-year old was required to register as a sex offender, regardless of the lifetime imposition of the registration, but that the registration would not be made public) because his information would be public, unlike other juvenile cases. The Supreme Court disagreed with each of Justin B.'s arguments and affirmed the family court's decision to require Justin B. to register as sex offender and wear an electronic monitor for life, upholding the constitutionality of mandatory lifetime sex offender registration and electronic monitoring for juvenile offenders. Specifically, the Supreme Court found that the bar imposed by Roper on sentencing juvenile defendant's to death is inapplicable here, as the sex offender registry and electronic monitoring are non-punitive and intended to protect the public and assist law enforcement, not to punish. Additionally, the court (i) found that the parens patriae doctrine was similarly inapplicable to Justin B.'s punishment, as it is a legislative policy, not a constitutional principle, and that the registry itself is an exercise of the State’s duty to protect children; and (ii) dismissed Justin B's argument that mandatory registration violates the South Carolina Children's Code, as it determined that the Legislature intentionally applied the registration requirements to juveniles, and this Court's disagreement with Justin B. aligns with the Legislature's goals to treat adults and juveniles equally in the requirement that they register as sex offenders upon violation of certain provisions of the S.C. Children's Code. Finally, the Supreme Court rejected Justin B's argument to distinguish his case from precedent such as In the Interest of Ronnie A. explaining that a juvenile's reputation is not constitutionally protected, and the Legislature, not the courts, should determine any changes.

Summary of Case Context & HoldingA student was expelled from school by the district's school board after a pocketknife was found in a purse, within her locker, during a random controlled substances search at the student's high school. The student appealed the decision to the Commissioner of Education, which affirmed the expulsion, and thereafter sought review of the case by the state's court of appeals. On appeal, the court found that the school board's findings were not sufficient to support the conclusion that the student either willfully violated the district's policy or willfully conducted herself in a manner that endangered herself or others, as required for dismissal under the Minnesota Pupil Fair Dismissal Act (PFDA), and, therefore reversed the decision. The Supreme Court affirmed the reversal finding that the student, who knew the pocketknife was in her purse, but stated that she had forgotten to take it out before school, neither acted willfully to violate the school's policy against weapons nor endangered herself or other persons by doing so and, thus, that there were not facts sufficient to support the student's dismissal under the PFDA.

Summary of Case Context & HoldingA delinquency petition was filed when Defendant was 15 years old, alleging that Defendant committed second-degree reckless homicide while armed with a dangerous weapon. Defense counsel challenged Defendant's competency to proceed. Two psychologists found Defendant not competent and not likely to become competent within the statutory time frame, which resulted in the circuit Court suspending the delinquency proceedings, entering a juvenile's “need of protection or services” (JIPS) order (a legal mechanism that allows juvenile offenders to be directed to alternative rehabilitation programs), and placing Defendant in a residential treatment center. While the JIPS order was pending, the state filed additional charges against Defendant alleging battery, criminal damage to property, and disorderly conduct in adult criminal court. In the adult criminal proceedings, Defendant was found not competent but likely to become competent. As a result, the state filed a motion to recall for reconsideration of Defendant's competency in the juvenile delinquency case. The court of appeals concluded that Wis. Stat. § 938.30(5)(d) allows the circuit court to retain authority over delinquency proceedings where the juvenile remains not competent such that the circuit court may revisit the issue of competency when circumstances warrant reevaluation. The Supreme Court held that: First, the circuit court had authority to resume suspended juvenile delinquency proceedings. Although there is no explicit procedure laid out in the statute to reinstate the suspended delinquency proceedings in Defendant's case, the statutory language and the surrounding subsections are unambiguous. Second, the expiration of a JIPS order had no bearing on the circuit court's competency to proceed with a juvenile's delinquency proceedings. The Supreme Court agreed with the cases cited by the state, where the Supreme Court had determined that a criminal proceeding is jurisdictionally independent from a civil commitment based on lack of competency. The Supreme Court explained that the statute demonstrates that the court presiding over the JIPS proceedings does not truly have “exclusive original jurisdiction.” A juvenile who is found not likely to become competent is subject to a separate JIPS order, yet the circuit court may continue to exercise jurisdiction over the juvenile through reexamination for competency and resumption of delinquency proceedings if the juvenile becomes competent within the statutory time frame. Therefore, the expiration of Defendant's accompanying JIPS order has no bearing on the circuit court's competency to proceed with Defendant's delinquency proceedings.

Summary of Case Context & HoldingA.R.C. visited a hospital emergency room in July 2022 displaying psychotic symptoms and delusional behavior. A.R.C.’s behavior was so erratic that it led the attending physician to file an application for emergency detention, and a magistrate shortly signed a warrant authorizing A.R.C.’s detention in a medical facility. The following morning, A.R.C. was examined by Dr. Paez, a second-year psychiatry resident practicing under a “physician-in-training” permit. The day following, Paez filed a certificate of medical examination as well as an application for temporary court-ordered mental health services, wherein Paez stated that A.R.C. presented a substantial risk of serious harm to himself or others. The county attorney then filed a motion for protective custody, and the court signed the order, in the process scheduling both a probable cause hearing and a final hearing, both to be held within the week. At the probable cause hearing, the probate court found that A.R.C. presented a substantial risk of serious harm to himself or others, following which a second physician, Dr. Kutcher-Diaz, also a second-year psychiatry resident, examined A.R.C. and signed a second certificate of medical examination, which determined that A.R.C. was mentally ill. Under the Texas Health & Safety Code, prior to a final hearing on an application for court-ordered mental health services, two separate physicians must have examined the proposed patient and submitted certificates of medical examination. Further, at least one physician must be a psychiatrist if a psychiatrist is available in the county. Immediately prior to the final hearing, A.R.C. filed a motion to dismiss, claiming that the State had failed to comply with the statutory requirements, as neither of the examining physicians qualified as a “psychiatrist.” The court rejected the argument and proceeded with the hearing. The court ruled that A.R.C. undergo 45 days of in-patient mental health care and receive forced medication. On appeal, the court of appeals agreed that Paez and Kutcher-Diaz did not qualify as psychiatrists under the law and overruled the probate court’s ruling. The State appealed to the Supreme Court. On appeal, the Court first reviewed the text of the Texas Health and Safety Code, noting that it explicitly defines physicians to include those who “perform medical acts under a physician-in-training permit.” Viewing psychiatrists as a subset of physicians, the Court then turned to the meaning of a psychiatrist and held, after looking to a variety of dictionary and medical definitions on the subject, that a psychiatrist is a physician who specializes their practice in psychiatry. The Court looked to Paez and Kutcher-Diaz’s residency program practices and noted that each had engaged in enough formal training and practice in treating the mentally ill that they had “clearly passed any dividing line between psychiatrists and non-psychiatrists.” As a result, the Court held that the certificates of medical examination submitted by each of the doctors met the psychiatry requirement under the statute and that A.R.C.’s forced treatment, which had already since completed by the time that both the court of appeals and Supreme Court issued their rulings, was valid.

Summary of Case Context & HoldingOn February 18, 2022, the Texas Attorney General issued an Opinion stating that certain "sex change" procedures and treatments performed on children could legally constitute child abuse under Chapter 261 of the Texas Family Code. The Texas Governor then issued a letter and a directive to the Texas Department of Family and Protective Services (DFPS) Commissioner to follow the Texas Law and DFPS issued a statement regarding the directive. Plaintiffs, a married couple of a child diagnosed with gender dysphoria and a doctor who treats such children, sued the Texas Governor, the DFPS Commissioner, and DFPS (Defendants) challenging the Governor's directive and the statements made by DFPS. Plaintiffs argued that DFPS's statement announces a new agency rule without the notice-and-comment procedure required by law. Further, Plaintiffs challenged DFPS's authority to investigate the use of medical treatments that are deemed unlawful by the Governor's letter. The district court issued a temporary injunction that restrained the Defendants from certain actions including: (1) actions against Plaintiffs based on the Governor's directive and DFPS rule; (2) investigating reports against people based on alleged child abuse by providers facilitating gender-affirming care; (3) prosecuting or referring for prosecution such reports; and (4) imposing reporting requirements on persons in the State of Texas who are aware of others who facilitate or provide gender-affirming care to transgender minors. The court of appeals ordered a reinstatement of the district court's temporary injunction in its entirety. The State then petitioned the Texas Supreme Court for a writ of mandamus to direct the court of appeals to vacate its order. In the majority opinion, the Texas Supreme Court first held that there was no legal authority for DFPS to be obligated to base its investigatory decisions on the Governor's letter or Attorney General's opinion. Accordingly, DFPS did not need to follow any directive by the Governor or the Attorney General and could make its own assessment of a report of child abuse or neglect. Second, the Court held that the court of appeals abused its discretion in reinstating the district court's temporary injunction. The Court found that the court of appeals only had authority to offer statewide relief to parties (and not nonparties). Lastly, the Court denied mandamus relief to reinstate the temporary injunction while the appeal was pending. The Court reasoned that ordering the Governor not to investigate reports of abuse, prosecute the reports, or impose reporting requirements was improper because the Governor lacks the authority to investigate or prosecute the Plaintiffs. Accordingly, an order prohibiting him from engaging in such conduct has no support. Justice Blacklock wrote a concurring opinion in part and a dissenting opinion in part, joined by Justices Boyd and Devine. The Justices concurred with the majority that Texas law does not authorize the court of appeals to afford statewide relief to non-parties, agreeing that enforcing the temporary injunction in its entirety was an abuse of discretion. However, the Justices disagree with the majority's decision to deny the State mandamus relief from the court of appeals' order reinstating the temporary injunction with respect to the Plaintiffs. They reasoned that in order to reinstate the temporary injunction, the court of appeals should have reviewed the injunction de novo, to consider the same factors considered by the district court.

Summary of Case Context & HoldingEnvironmental group Petitioners brought suit against the state Department of Environmental Conservation (DEC) for permitting seasonal snowmobile use on an existing roadway on property recently acquired by the state and added to the Adirondack Forest Preserve. Petitioners argued the DEC exceeded its authority and contravened the controlling motor use restrictions in the Adirondack Park State Land Master Plan and Wild, Scenic and Recreational Rivers System Act. The lower courts held the DEC did not exceed its authority, and the court of appeals affirmed these lower court decisions, ruling that the challenged portion of the DEC's decision was not irrational, arbitrary and capricious or contrary to law. The Court of Appeals held it was rational for DEC to conclude the contemplated use of the disputed one-mile portion of the road during the winter and hunting season to public snowmobile use would not necessarily alter or expand the prior use within meaning of New York State law.