State Supreme Court Data Tracker

Summary of Case Context & HoldingThe Attorney General of Florida requested an advisory opinion from the Supreme Court of Florida on a proposed amendment to the state constitution, named "Adult Use of Marijuana." This proposed amendment aimed to permit "the use (and distribution) of recreational marijuana." The Florida Supreme Court evaluated the proposed amendment by relying on the proposed amendment's compliance with the single-subject requirement of the Florida Constitution and whether the ballot title and summary adhered to Florida Statutes. The Court struck the proposed amendment holding that the initiative was clearly and conclusively defective on the ground that the ballot summary was not an "accurate, objective, and neutral summary of the proposed amendment," and would mislead voters regarding the federal legality of recreational marijuana. The dissent argued that the majority's opinion takes an unnecessarily narrow view of the requirements of a ballot initiative title and summary, asserting that the bedrock principle that citizens are presumed to know what constitutes a federal crime does not require such initiatives to provide the legality in multiple jurisdictions.

Summary of Case Context & HoldingA group of borough inhabitants sought to establish a school district independent from the Steelton-Highspire School District (SHSD) to subsequently be absorbed by the Middletown Area School District (MASD). The Pennsylvania Secretary of Education evaluated the petition considering the "merits of the petition . . . from an educational standpoint" consistent with 24 § P.S. §§ 1-101–27-2702. The Secretary denied the petition, determining that the transfer would "undermine the financial stability of SHSD and put a strain on class size and facilities at MASD." The commonwealth court reversed, holding that the Secretary could not consider a school's projected financial status as part of the "educational merits" review. The Supreme Court reversed the decision of the commonwealth court, holding that the Secretary could consider how the financial impact of the transfer could affect educational quality.

Summary of Case Context & HoldingThe Ohio Power Siting Board approved construction of a wind-powered electric-generation facility on submerged land in Lake Erie. Residents of the area challenged the board's approval of the facility, arguing that the board could not determine the facility's impact on migrating birds and bats. The Supreme Court held that the board did not error when they granted the permit; the Board had evidence regarding the facility's impact on migrating birds and bats and steps for reducing such impact. Moreover, the Board granted the certificate with conditions that were sufficient to protect birds and bats and ensure that the facility caused minimum adverse environmental impact.

Summary of Case Context & HoldingPetitioners Town of Riverhead and Town of Riverhead Community Development Agency (Riverhead) sought to challenge 2010 amendments to the regulations of respondent Department of Environmental Conservation (DEC). The Division of Fish, Wildlife, and Marine Resources of the DEC adopted amendments to a state law pertaining to the protection of endangered or threatened species. Although DEC had the preexisting authority to prohibit the intentional taking of endangered or threatened species, these amendments established a formal process through which individuals could obtain a permit to allow for the incidental taking of such species. Riverhead brought the action after promulgation of these amendments, alleging procedural violations concerning the DEC's failure to comply with certain provisions of the Environmental Conservation Law and State Administrative Procedure Act (SAPA). Specifically this included the failure to refer the proposed amendments to the Environmental Board, failure to hold public hearings, failure to properly evaluate and analyze the potential regulatory impact, and failure to take a necessary look under the State Environmental Quality Review Act (SEQRA). The Court of Appeals held that Petitioners could proceed with the first three of their procedural claims, but lacked standing with respect to the substantive causes of action. The Court of Appeals held that until Petitioner submits a permit application and DEC imposes requirements of the amended regulations to their detriment, allegations that Petitioners are affected by such regulations is too speculative as there is no actual injury caused by the substantive provisions of the amended regulations.

Summary of Case Context & HoldingThe Supreme Court of Arizona issued an administrative order authorizing Fair Housing Initiatives Program (FHIP) employees to represent alleged victims of discrimination during fair housing investigations, mediations, and conciliations by the Civil Rights Division of the Arizona Attorney General's Office, provided: (a) the aggrieved person agrees to such representation; (b) the FHIP organization is a Private Enforcement Initiative (PEI) grantee and is in good standing and funded by the US Department of Housing and Urban Development at the time of representation; and (c) the representative is employed by the FHIP at the time of the representation. This milestone order was requested by the Civil Rights Division of the Arizona Attorney General’s office, which aims to improve access to justice for individuals facing housing discrimination and instability. It is expected that the order will significantly bolster efforts to combat housing discrimination in Arizona, ensuring that those affected have the necessary support and representation to navigate legal processes and achieve justice.

Summary of Case Context & HoldingOver the course of approximately seven years, B.J. allegedly committed multiple sex offenses against his half-sisters when they were children. The incidents allegedly occurred both before and possibly after B.J. turned 18. The State filed a delinquency petition in juvenile court and then filed a certification petition that requested B.J. be transferred to criminal court. The juvenile court transferred the case to criminal court based on the "heinous and egregious" alleged conduct, the lack of time for the juvenile court to rehabilitate B.J. before it lost jurisdiction due to his age, and because B.J. was 18 when he allegedly committed one or more of the offenses. B.J. appealed, arguing that under Nev. Rev. Stat. § 201.230(5) "lewdness with a child under the age of 14 committed by a person under the age of 18 is an act of delinquency and, therefore, a juvenile alleged to have committed such an act cannot be certified for adult proceedings." On appeal, the Court affirmed the juvenile court's decision to transfer B.J.'s case, holding that Nev. Rev. Stat. § 201.230(5) defined a minor's sex offense against a child under age 14 as delinquent but that the statute did not deprive the juvenile court of discretion to certify B.J. to stand trial as an adult in criminal court under Nev. Rev. Stat. § 62B.390. In dissent, Justice Pickering argued that Nev. Rev. Stat. § 201.230(5) was vague and should not be interpreted to deem "B.J. beyond help at this point in his young life," considering his own sexual abuse from his brother.

Summary of Case Context & HoldingPlaintiff, a transgender minor, was convicted of a crime of sexual violence against another minor. Plaintiff asked the Supreme Court to stay sex offender registration on two grounds: (1) the sex offender registry (SOR) is cruel and unusual punishment as applied to transgender individual changing their name; and (2) a violation of free speech. The Supreme Court held that the placement of Plaintiff on the SOR did not violate the U.S. Constitution as (1) SOR was not a punishment; (2) it was not cruel and unusual as applied to transgender Plaintiff; (3) the Defendant could simply use an alias instead of legally changing name (which was prevented by law for sex offenders); and (4) free speech does not allow an individual to compel the government to facilitate their speech (changing name.)

Summary of Case Context & HoldingThe Division of Family and Children Services (DFCS) had temporary custody of John and Brittani Chandler’s children. The Chandlers objected to their children receiving vaccinations while in DFCS custody on religious grounds and because John stated he did not believe COVID-19 was real. DFCS indicated that it sought immunization to facilitate health care, schooling, and foster placement and that vaccinations fell within their authority to provide ordinary medical care to the children. The juvenile court denied the Chandlers’ motion finding that their asserted religious objections were not sincere because they were no longer active in the church and are only against vaccination by personal philosophical choice based on a perception from the eldest’s child’s vaccination experience and John’s self-proclaimed conspiracy theories. The Supreme Court remanded the case, finding that the lower court did not properly conduct the sincerity analysis of the parents’ religious beliefs for their First Amendment claims. The Supreme Court held that even if the parents did not observe a particular religion, attend church consistently, or their objection is partly secular, they may be able to identify a sincerely held religious belief that would be violated by vaccinating their children.

Summary of Case Context & HoldingC.S was an adult with disabilities who lived with his foster father S.M. and received special education services from the Butte School District between September 2009 and June 2013 (C.S. turned 18 in March 2012). In November 2012, S.M. instituted an action on behalf of C.S. with the Montana Office of Public Instruction (OPI) against the Butte School District for violations of the Individuals with Disabilities Education Act (IDEA) and Montana's special education laws. A subsequent investigation revealed numerous violations of the IDEA and also raised concerns about C.S.'s ability to make his own educational decisions and the need to appoint a surrogate parent. OPI noted that Montana did not have a process for appointing a surrogate parent for students who have reached the age of majority, directed the school district to the process for minor children, and ordered that the district promptly appoint a surrogate parent. The district court appointed Mary Jo Mahoney after a petition from the school district to do so. C.S. did not learn about Mahoney's appointment until Mahoney attended his individualized education plan (IEP) meeting. After Mahoney approved an IEP plan with the school district that S.M. had long disputed, C.S. filed a motion to vacate the appointment of Mahoney and substitute S.M. as his surrogate parent. The district court denied the motion noting that a foster parent "has no statutory preference or priority for appointment as a surrogate parent . . . ." The Montana Supreme Court ruled that C.S.'s claims were not moot as he was actively seeking compensation to compensate for the Butte School District's failure to provide him with a free applicable public education (FAPE) as required by the IDEA and Mahoney's appointment impacted his future educational possibilities. The Court went on to note that IDEA's definition of a parent includes "a natural, adoptive, or foster parent of a child" (20 U.S.C. § 1401(23)(A)) and that OPI and federal administrative rules allow for the appointment of a foster parent. Admin R.M. 10.16.3504(1); 34 C.F.R. 300.30; Admin R.M. 10.16.3504(2). The Court held that the district court erred in not taking those statutes and administrative rules into account, reversed the district court's order denying C.S.'s motion to remove Mahoney and appoint S.M., and remanded for the court to determine whether an award for attorney's fees was appropriate to C.S. as the prevailing party.

Summary of Case Context & HoldingDefendant suffers from schizophrenia. While incarcerated, he was committed to an institution and determined to be incompetent to refuse medication. Defendant argued that forced medication under the Wisconsin's "patients rights" statute (Wis. Stat. § 51.61(1)(g))) was unconstitutional because he was never determined to be dangerous. The Supreme Court agreed and held that forced medication without a determination of dangerousness is facially unconstitutional.

Summary of Case Context & HoldingC.S. suffers from schizophrenia and was an inmate in the Wisconsin prison system. While he was incarcerated, C.S. was committed and determined incompetent to refuse medication pursuant to Wis. Stat. § 51.61(1)(g) and, therefore, was the subject of multiple involuntary medication court orders. C.S. argued that Wis. Stat. § 51.61(1)(g)(3) was unconstitutional when it permitted the involuntary medication of any inmate who was committed under Wis. Stat. § 51.20(1)(are) without a determination that the inmate was "dangerous" at any stage in the proceedings. Winnebago County argued that the statute was facially constitutional and that it had a legitimate interest in the care and assistance of a mentally ill and incompetent inmate. The Supreme Court found that the order for petitioner's involuntary medication and treatment was improper because it was facially unconstitutional for any inmate who was involuntarily committed under Wis. Stat. § 51.20(1)(are). Incompetence to refuse medication alone was not an essential or overriding State interest and could not justify involuntary medication.

Summary of Case Context & HoldingTrump campaign challenged the Philadelphia County Board of Elections' decision to count mail-in ballots that were complete and submitted in a timely fashion but lacked the voter's handwritten name, address, and/or date on the ballot-return outer envelope. While the Trump Campaign argued the failure to include that information should invalidate the ballots, the Supreme Court held the ballots were qualified ballots because the provisions of the state Election Code merely directed, and did not mandate, inclusion of this information. The Supreme Court reasoned that missing handwritten names, addresses, and/or dates were merely technical violations of the Election Code that should not disenfranchise voters, particularly when the mailed ballots already contained the printed name and address of the voter on the back of the outer envelope.

Summary of Case Context & HoldingThe Trump campaign sued the Philadelphia Board of Elections claiming campaign poll observers were prevented from having “meaningful access” to observe the canvassing ballots because the observers were not allowed close enough to the ballots to read the declarations on the ballot envelopes and determine whether the secrecy envelopes contained improper markings. The Supreme Court ruled the that the city's Board of Elections provided adequate access because state election law merely authorized presence in the room, and did not set a minimum distance from the ballots. Trump campaign's subsequent appeal to the U.S. Supreme Court was denied.

Summary of Case Context & HoldingIn response to the outbreak of COVID-19, Michigan Governor Gretchen Whitmer issued a succession of executive orders (EOs). As a result, medical services providers brought action in federal court against the Governor, Michigan Attorney General, and Michigan Department of Health and Human Services Director, challenging the Governor's EO that prohibited healthcare providers from performing nonessential procedures. The Supreme Court held that (1) the Supreme Court could not address, much less second-guess, federal district court's decision to certify certain questions to the Court and to not certify others; (2) the Governor did not possess authority, much less obligation, to redeclare same state of emergency or state of disaster and thereby avoid Legislature's limitation on her authority under Emergency Management Act (EMA); (3) the actual terms of Emergency Powers of the Governor Act (EPGA) did not preclude Governor from proclaiming state of emergency in response to statewide emergency; (4) delegation under EPGA was in violation of provision prohibiting exercise of legislative power by executive branch; and (5) the EPGA was unconstitutional in its entirety.

Summary of Case Context & HoldingA patient underwent surgery to have a portion of her thyroid removed to analyze it using a cryostat machine. However, when the machine was unavailable, the goal of the surgery shifted to instead fully remove the left lobe of the patient's thyroid. The surgeon accidentally removed tissue from the patient's thymus gland instead. As a result, the patient needed to undergo a second surgery to remove the left lobe of her thyroid. Following this incident, the hospital where the surgery took place, Christus Santa Rosa Health System (Christus), convened a medical peer review committee to review the surgeon's performance. Following review, the committee did not recommend any action to be taken against the surgeon. The patient filed suit against the surgeon and his medical group for medical malpractice. The surgeon filed a motion to designate Christus as a responsible third party, arguing that Christus had not informed him of the unavailability of the necessary cryostat machine. After the patient named Christus as a defendant, the surgeon requested that Christus produce certain documents, including documents from the surgeon's medical peer review file. Christus refused to produce the peer review documents, claiming that they were protected under the medical peer review privilege. After Christus sent the documents to the trial court for an in camera inspection, and following an evidentiary hearing, the trial court ordered Christus to produce the documents to the surgeon under a protective order. Christus appealed to the Supreme Court. The Supreme Court found that the requested files were protected under the medical peer review privilege, and Christus was not required to produce them. Notably, there is an exception to this statutory privilege if a peer review committee takes or recommends disciplinary action. The surgeon argued that because the committee had the opportunity to execute disciplinary action and chose not to, it had effectively taken an action and the materials should not be covered under the exception. The Court disagreed, holding that this interpretation of the privilege would essentially strip all protections under the privilege, as essentially every time a peer committee meets it has the ability to recommend some disciplinary action. As a result, the proceedings of the peer review committee were protected from production.

Summary of Case Context & HoldingTwo unions (FOP Lodge 34 representing full-time "correction officers" and PBA Local 77, representing "sergeants, detective I and detectives") filed charges against Atlantic County, appealing the decisions of the Public Employment Relations Commission (PERC) dismissing unfair practice charges in connection with the counties' failure to continue scheduled salary increases set forth in expired collective negotiation agreements (CNAs) during the negotiation of successor CNAs. The Supreme Court held that counties violated the Employer–Employee Relations Act (EERA) by unilaterally ceasing payment of salary increases. Of note, the Supreme Court did not determine whether, as a general rule, an employer must maintain the status quo while negotiating a successor agreement. In these cases, the governing contract language required that the terms and conditions of the respective agreements, including the salary step increases, remain in place until a new CNA is reached. Therefore, the Supreme Court affirmed the appellate court's decision on other grounds.

Summary of Case Context & HoldingDefendant committed first degree murder when he was nine years old, and the victim was 14 months old. Defendant was found “not not guilty” of murder at a discharge hearing, and was subsequently remanded to the Department of Human Services to be restored to fitness for trial. Defendant argued on appeal that statements made during his interviews with Detective Adams should be suppressed as involuntary, given that he did not receive an attorney, did not voluntarily waive his Miranda rights, and that Adams further admitted on cross-examination that he deliberately lied to and tricked the Defendant–for example, by telling the Defendant he believed the victim’s injuries to be accidental. The Supreme Court considered whether the test for determining whether a defendant is in custody for purposes of Section 5-170(a) of the Juvenile Court Act, which sets forth a statutory right to an attorney for the custodial interrogation of a minor for an act that would be first-degree murder if committed by an adult, is any different than the test for determining whether a defendant was in custody for purposes of Miranda. The Supreme Court decided to assume, without deciding, that the definition of “custodial interrogation” in Section 5-401.5(a) of the Juvenile Court Act also applies to Section 5-170(a), and thus it was appropriate to use the Miranda custody test to determine whether Defendant was in custody when questioned by Detective Adams. In determining whether there had been a custodial interrogation, the Supreme Court looked to factors set forth in People v. Slater, 886 N.E.2d 986 (Ill. 2008): "(1) the location, time, length, mood, and mode of the questioning; (2) the number of police officers present during the interrogation; (3) the presence or absence of family and friends of the individual; (4) any indicia of a formal arrest procedure, such as the show of weapons or force, physical restraint, booking or fingerprinting; (5) the manner by which the individual arrived at the place of questioning; and (6) the age, intelligence, and mental makeup of the accused." After reviewing video recordings of Adams’ interviews with Defendant, the Supreme Court held that Defendant was not in custody while questioned because the Defendant was questioned at home, Adams was the only officer, Adams was not in uniform, Defendant's father was present, each interview lasted only 30 to 40 minutes, and Adams asked Defendant and his father for permission before asking questions. The Supreme Court noted that while the Defendant's age of nine was a factor, it was only one of many factors to be considered and that there was no bright-line rule regarding age. Thus, on balance, the Court determined that Defendant’s statements were voluntary, so it was not necessary to further consider whether Defendant waived his Miranda rights or would have been entitled to counsel under Section 5-170(a).

Summary of Case Context & HoldingUnder Ohio laws, for a juvenile offender who is 16 or 17 years old at the time of committing a sexually oriented offense and is classified as a Tier 1 sex offender, the juvenile court must continue that classification at the completion-of-disposition hearing, no matter how effective the treatment was or whether any risk of reoffending is present, which classification follows the juvenile into adulthood. In this case, the juvenile had successfully completed probation, intended to attend college, and was working–the prosecutor even jointly submitted a report prepared by a psychologist on behalf of the juvenile. The courts, however, were unwilling to declassify the juvenile under law, and the juvenile's attorney appealed arguing that the statutes preventing the court from exercising discretion to terminate Defendant’s classification as a juvenile-sex-offender registrant violated Defendant’s due-process rights under the Fourteenth Amendment to the U.S. Constitution. The Supreme Court held that a statute requiring continuation of Tier 1 sex offender classification at completion-of-disposition hearing, when applied to a juvenile, was fundamentally unfair in violation of due process.

Summary of Case Context & HoldingMinor D.T. sexually assaulted his minor ex-girlfriend after coming to her apartment to retrieve his missing cell phone. The State filed a petition to certify D.T. for trial as an adult for "sexual assault, battery with intent to commit a crime, burglary, kidnapping, and battery constituting domestic violence." D.T.'s counsel argued that D.T. was cognitively impaired, but two court-ordered competency evaluations found D.T. competent. Accordingly, the juvenile court certified D.T. for trial as an adult. D.T. appealed, arguing that (1) the juvenile court's certification order was vague and unsupported such that it violated D.T.'s procedural due process rights; (2) the juvenile court abused its discretion in certifying D.T. for trial as an adult; and (3) D.T.'s certification violated the Eighth Amendment's prohibition against cruel and unusual punishment. The Court rejected each argument. First, the Court held that while the juvenile court's oral ruling lacked detail, it met the minimum requirements for procedural due process as the court conducted a full background investigation that it considered in rendering its decision. Moreover, the juvenile court's written order sufficiently considered and stated the reasons for certification. Second, the Court held that the juvenile court did not abuse its discretion in balancing subjective factors, including D.T.'s cognitive impairments, in concluding that public safety warranted certification. Finally, the Court held that because certification as an adult is not a punishment, the Eight Amendment's prohibition against cruel and unusual punishment could not apply.

Summary of Case Context & HoldingDefendant was charged with first degree murder and attempted murder when she was 14. Defendant moved for a jury trial, acknowledging that first-time offenders charged with first degree murder are not entitled to a jury trial under the Juvenile Court Act but arguing that a denial would violate the due process and equal protection clauses of the United States and Illinois Constitutions. The Supreme Court explained that in In re Jonathon C.B., 958 N.E.2d 227 (Ill. 2011), the Supreme Court had previously determined that due process does not mandate jury trials for juveniles. Regarding the equal protection claim, the Supreme Court found that the legislature had determined that it was necessary to address a class of offenders who are qualitatively different from other juvenile offenders, and that first-time offenders charged with first degree murder are not in the same class as habitual juvenile offenders or violent juvenile offenders (who are entitled to jury trials) solely because of the common consequence of mandatory incarceration. The Supreme Court accordingly rejected Defendant’s due process challenge and reversed the trial court’s determination that Sections 5-101(3) and 5-605(1) of the Juvenile Court Act, which do not provide for jury trials for first-time juvenile offenders charged with first degree murder, violated the equal protection clauses of the United States and Illinois Constitutions.

Summary of Case Context & HoldingA nonprofit charter school in New York City responded to a request for proposals from the local school district to receive funding for providing a pre-k program under the state's Universal Pre-K Law. The funding was granted, contingent on the charter school executing a contract with the school district that included provisions regulating curriculum and operations of the charter school and giving the school district authority to monitor the charter school. The charter school formally objected to the contract and was denied payment. The charter school initiated an action against the district seeking the funds and a declaration that the contract was unlawful. The Commissioner of Education ruled in favor of the school district. On appeal, the appellate court reversed the Commissioner's decision and ruled that the Universal Pre-K Law did not give the school district control over curriculum and operations of the charter school. The Court of Appeals agreed with the lower court, finding that it did not need to defer to the decision of the Commissioner and holding that the statutory scheme governing charter school pre-k programs does not allow for shared oversight between charters and local school districts. The Court of Appeals reasoned that the plain language of the Universal Pre-K Law provides that charter school pre-k programs are the exclusive responsibility of the charter entity.

Summary of Case Context & HoldingIn 2003, an ordained deacon in the Diocese of Lubbock was indefinitely suspended from his diaconal position after the Diocese became aware of reports of sexual misconduct between the deacon and a woman who suffered from mental and emotional disorders. Three years later, the deacon was reinstated. Subsequently, in 2008, the deacon had his diaconal rights permanently withdrawn (such that he could no longer perform sacramental functions) following further allegations of sexual misconduct involving the same woman. In September 2018, the Catholic Bishops of Texas released the names of all clergy members in Texas against whom the bishops were aware that credible allegations of sexual abuse of a minor had been made. Under Canon Law, a “minor” includes any “person deemed vulnerable due to a health or mental condition.” The deacon was named on the list, as the woman he had been accused of sexually abusing multiple times was considered a minor under Canon Law, and because the Diocese of Lubbock had determined that the accusations were credible. The deacon demanded a retraction of his name from the list, to which the Diocese of Lubbock responded by explaining how it had derived its definitions of sexual abuse of a minor as applied in the list, and how it viewed the various allegations against the deacon as credible. In turn, the deacon sued the Diocese of Lubbock, alleging claims of defamation and intentional infliction of emotional distress. The Diocese filed a motion to dismiss asserting that the preparation and posting of the list were protected under its right to free speech. The Diocese also filed a plea to the jurisdiction arguing that the ecclesiastical abstention doctrine precluded the trial court from exercising jurisdiction. Under the ecclesiastical abstention doctrine, courts must abstain from resolving legal issues pertaining to internal theological matters under the First Amendment. The district court denied both of the Diocese’s motions, and the Diocese appealed to the court of appeals. The court of appeals affirmed the trial court’s ruling, holding that the matter ceased to be ecclesiastical when the church released the list to the public. The court emphasized the facts that the Diocese’s decision to post the list online, engage with media, and later release public statements regarding the list. The court of appeals further rejected the Diocese’s argument that a court would need to interpret Canon Law to determine the definition of “minor,” instead holding that in determining the defamatory meaning of the word, a court would look to how a person of ordinary intelligence would construe “minor,” rather than the definition under Canon Law. On further appeal, the Supreme Court held that the ecclesiastical abstention doctrine required the trial court to abstain from ruling on the case. Specifically, the Court held that because the deacon’s allegations called into question the investigation process and the drafting of the list, they implicated ecclesiastical matters. Any court ruling on the case would need to determine whether the Diocese had accurately applied the canonical definition of “minor.” The Court further noted that a publication extending beyond the walls of the church did not render the publication no longer a church matter. Instead, a court must look to whether the “substance and nature” of the allegations implicate ecclesiastical issues, such as a church’s “internal affairs, governance, or administration.” Here, the Supreme Court held that the ecclesiastical issue was too “inextricably intertwined” with the deacon’s tort claims for the case to properly proceed through the courts.

Summary of Case Context & HoldingThe Bankruptcy court certified to the Arizona Supreme Court the question of whether a "motor" home in which a person over 18 years of age resides qualifies as a “mobile home” for purpose of claiming an Arizona homestead exemption, as outlined in Arizona Statute § 33-1101(A). The Supreme Court explained that, as used in Arizona Statute § 33-1101(A), the term "mobile home" was meant to describe a permanent dwelling attached to land and, thus, is distinct from a "motor home" which is readily movable and not physically connected to the land in any meaningful way. The Supreme Court explained that Arizona Statute § 33-1101(A)(3) was meant to provide an exemption to owners of mobile homes situated on leased land, but still connected to that land in a significant way, who would not be eligible for an exemption under Arizona Statute § 33-1101(A)(4) which covers mobile homes situated on land owned by the person who owns the mobile home. It was not, the Supreme Court explained, meant to apply to "motor homes."

Summary of Case Context & HoldingIn this family law case involving parental rights, Francisco, a citizen and resident of Mexico, was convicted in Wisconsin of an offense involving an underage girl and placed on probation. In 1996, Francisco moved from Wisconsin to Texas without completing the terms of his probation. In Texas, Francisco met Edna, married her, had two children in 1998 and 1999, and later separated. In 2004 or 2005, after the separation, Francisco approached the immigration authorities in Dallas to procure a green card. Because Francisco left Wisconsin in violation of his probation terms, the immigration authorities arrested, jailed, and ultimately deported Francisco to Mexico, with a 10-year bar to re-entry. The children remained in Texas with Edna from Francisco's deportation until about 2009, when the Department of Family and Protective Services (the Department) placed them in foster care due to Edna's neglectful supervision and endangerment. Until their removal to foster care, Francisco provided child support through an informal agreement and maintained some contact with the children from Mexico, and Edna testified that Francisco was a good father who provided support for the children. However, the Department petitioned to terminate both Edna’s and Francisco’s parental rights, and the trial court terminated both parents’ rights in 2010, finding by clear and convincing evidence that termination was in the best interest of the children, and that Francisco (1) knowingly placed or knowingly allowed the children to remain in conditions or surroundings which endangered their physical or emotional well-being; (2) engaged in conduct or knowingly placed the children with persons who engaged in conduct which endangered their physical or emotional well-being; (3) failed to support the children in accordance with his ability; and (4) constructively abandoned the children. Francisco filed a timely combined motion for new trial, which the trial court denied. However, the trial court found that Francisco's appeal was not frivolous and appointed counsel to represent Francisco on appeal. A divided court of appeals affirmed the trial court's judgment as to Francisco, and Francisco appealed to the Texas Supreme Court. The Texas Supreme Court stated that termination of parental rights requires “proof by clear and convincing evidence” and that involuntary termination statutes are to be strictly construed in favor of the parent, so that for a trial court to terminate a parent's right to his children, the State must prove by clear and convincing evidence both that: (1) the parent committed an act prohibited under Texas Family Code Section 161.001(1); and (2) termination is in the children's best interest. The Court found the evidence legally insufficient on both prongs. The government argued that the first prong was met because Francisco engaged in conduct endangering the physical or emotional well-being of his children, but the Court held that that although Francisco’s conviction (before he had children) for an offense involving a minor, probation violation, and deportation were all “factors to be considered,” "no reasonable factfinder could have formed a firm belief or conviction that Francisco engaged in a course of endangering conduct." With respect to deportation, the Court held that (1) it is insufficient in and of itself to establish endangerment; and (2) its relevance to endangerment depends on the circumstances and that just as not every minor offense committed by a citizen that could lead to incarceration establishes endangerment, nor can every offense that could lead to deportation (including “a minor one committed long before the parent’s children were born”) be considered to establish endangerment. The Court reasoned that there was no evidence that Francisco’s actions "created such uncertainty and instability for his children sufficient to establish endangerment" nor was there "evidence that Francisco abandoned his parental responsibilities once he was forced to leave the country." On the “best interest” prong, the Court found that the government had not established that termination was in the children’s best interest, but did not go so far as to "conclude that the children's best interest is unquestioningly for them to join their father in Mexico; [because] it is possible that the children's best interest is to remain in the United States, whether in foster care or with . . . another family member." Accordingly, the Court reversed the court of appeals' judgement in part and remanded to the trial court.

Summary of Case Context & HoldingIn 2007, Entergy applied to the Nuclear Regulatory Commission (NRC) for a 20-year renewal of its operating licenses for nuclear reactors at Indian Point, taking the position with the NRC that its application was subject to the New York Department of State's (Department) consistency review under the state's Coastal Management Program (CMP). This CMP sets forth 44 enforceable statewide policies relating to coastal activities against which federal license renewals and other actions affecting coastal areas must be assessed, including the objectives of protecting fishing and wildlife, meeting public energy needs, and controlling air and water pollution. Certain projects are exempt from consistency with these coastal policies set forth in the CMP. In 2012, Entergy changed its position and sought a ruling that its re-licensing was not subject to the Department's review for consistency with the CMP. Entergy sought a declaratory ruling from the Department, arguing its license renewals fell within two exemptions to CMP's consistency requirement. Entergy argued that one exemption was grandfathered in under the State Environmental Quality Review Act (SEQRA) and that the second exemption was because the facilities' final environmental impact statements were adopted before the effective date of the Department's relevant regulations. The Court of Appeals noted that Entergy's new application for a license to operate the Indian Point nuclear reactions for an additional 20 years is a new federal action, with different impacts and concerns than what appeared in the initial environmental impact statements issued 40 years earlier. The Court of Appeals held that the Department's interpretation of the exemptions in the CMP and its conclusion that Entergy's application to re-license the nuclear reactors at Indian Point was subject to a consistency review was rational, reversed the lower court's orders, and judgment was granted in favor of the Department of State.

Summary of Case Context & HoldingIn this case the Supreme Court considered whether the Michigan Department of Health and Human Services (DHHS) could recover Medicaid benefits paid to or on behalf of deceased recipients during their lifetimes. Pursuant to the Michigan Medicaid estate-recovery program (MMERP), DHHS asserted creditor claims in the amount of those benefits against the estates of four deceased beneficiaries. The probate courts denied DHHS's collection attempts in the underlying actions, and DHHS appealed. The appeals were consolidated and the court of appeals affirmed in part, reversed in part, and remanded. On appeal, the Supreme Court concluded that DHHS did not violate the statutory or constitutional rights of the deceased beneficiaries, thus DHHS was not barred from pursuing some of the estate recovery amounts paid. The Supreme Court therefore affirmed in part, reversed in part, and remanded the cases to the probate courts.

Summary of Case Context & HoldingPlaintiff Michigan Governor Gretchen Whitmer claimed that MCL 750.14, a statute that criminalizes the administration of abortions, violated the state constitution’s (1) right to privacy as guaranteed by the due process clause, which protects liberty and bodily integrity (Art. 1, § 17) and the unenumerated rights clause (Art. 1 § 23), and the state constitution's (2) guarantee of equal protection (Art. 1, § 2). Upon filing her complaint in a trial court, Governor Whitmer asked the Michigan Supreme Court to assume jurisdiction over the case and decide whether the Michigan Constitution protects the right to abortion. In light of an amendment to the Michigan Constitution protecting the right to reproductive autonomy that voters approved in November 2022, the Supreme Court has dismissed the case.

Summary of Case Context & HoldingFMC Corp owns and operates a 103-acre pesticide production facility in Niagara County, and has released significant quantities of hazardous waste including arsenic, lead, cyanide and more onto adjacent properties including school, recreational watercourses, croplands, and residences. Under the state Environmental Conservation Law (ECL), applicants are required to undertake corrective actions for all releases of hazardous waste as part of the permitting approval process. To adhere to these requirements, FMC entered into a consent order with the New York Department of Environmental Conservation (DEC) and the Environmental Protection Agency (EPA) and in 2013, the DEC adopted a final corrective measure for FMC. FMC then proposed eight different options for remediation, but DEC found none of them sufficiently alleviated the threat posed by FMC's release of hazardous waste and announced it would seek to undertake the corrective measures itself. FMC alleged the DEC's decision to implement such measures unilaterally was arbitrary and capricious. The Court of Appeals held the lower court erred in foreclosing the possibility that the DEC's unilateral remediation action was authorized, and that the interpretation of the ECL adopted by both parties authorized DEC's action.

Summary of Case Context & HoldingHospitals sought a writ of certiorari to appeal the conclusion by the Minnesota Department of Human Services (DHS) that Minn. Stat. § 256.9657 requiring hospitals to pay a surcharge on net patient revenues to DHS was not preempted by the Federal Employees Health Benefits Act (FEHBA) and federal statute creating TRICARE program. Both FEHBA and TRICARE are programs through which the federal government provides its employees and uniformed members of the armed services with health insurance benefits. The hospitals claim that federal law preempts the surcharge to the extent that it requires them to pay a surcharge on revenues obtained from insurance carriers that participate in the FEHBA or the TRICARE programs. The case was assigned to an Administrative Law Judge (ALJ), which concluded that the surcharge was not preempted because, although it is a “tax, fee, or other monetary payment,” the surcharge is not “imposed, directly or indirectly, on a carrier.” As a result, the ALJ granted DHS's motion for summary disposition. The hospitals filed exceptions to the ALJ's recommendations and submitted those exceptions to the Commissioner of DHS. After reviewing the hospitals' exceptions and the responses from DHS, the Commissioner issued an order resolving the contested case. The Commissioner followed the recommendations of the ALJ, denied the hospitals' motion for summary disposition, and granted DHS's motion for summary disposition. On appeal, the court of appeals affirmed the Commissioner's decision. The Supreme Court affirmed the court of appeals, holding that: (1) hospitals had standing to challenge a surcharge under Minn. Stat. § 256.9657 (2014); and (2) the FEHBA and TRICARE programs do not expressly preempt state law requiring hospitals to pay the surcharge because the plain language of FEHBA's preemption provision, 5 U.S.C. § 8909(f)(1), only preempts taxes, fees, and other monetary payments that are imposed, either directly or indirectly, on carriers. To impose a tax, fee, or monetary payment means to make it compulsory. In this instance, the state has not imposed the surcharge on FEHBA or TRICARE carriers because those carriers are never compelled by the state to pay the surcharge. Instead, to the extent that the economic burden of the surcharge is borne by the carriers, it is because the hospitals have voluntarily chosen to pass on the cost of the surcharge to the carriers, and the carriers have voluntarily chosen to pay the cost of the surcharge as part of their agreements with the hospitals. As a result, the surcharge found Minn. Stat. § 256.9657, subd. 2, is not preempted by 5 U.S.C. § 8909(f)(1).

Summary of Case Context & HoldingA hospital appointed a guardian to a ward who, in alignment with the ward's attorney and the hospital and with authorization by the district court, removed the ward's life support systems. The district court held that the medical power granted to a guardian does not grant the guardian the unrestricted authority to direct the removal of life support without prior court approval under Minn. Stat. § 524.5-313(c)(4)(i). According to the district court, the power to direct removal of life support "is not inherent in any of the enumerated powers normally granted a guardian," and therefore guardians seeking that power needed specific authorization from the district court. The guardian appealed and the court of appeals reversed, holding that absent a limitation in the guardianship order, "the medical-consent power granted to a guardian" under the statute includes the power to authorize disconnection of a permanently unconscious ward's life-support systems "without further authorization from the [D]istrict [C]ourt." The Supreme Court affirmed, holding that: (1) otherwise-moot issue of guardian's power would be considered as an important public issue of statewide importance; and (2) guardian's statutory medical consent power included power to consent to removal of ward from life support systems when all interested parties agreed that removal was in ward's best interests.

Summary of Case Context & HoldingAppellant was charged in juvenile court with aiding and abetting second-degree murder and first-degree aggravated robbery, when he was 15 years old. The State filed a motion to try Appellant as an adult, which was denied because only two of the six public safety factors weighed in favor of adult certification. The State appealed and the appeals court reversed, determining that three additional factors to the two the trial court found favor adult certification: (2) culpability; (4) programming history; and (5) adequacy of the punishment or programming available in the juvenile justice system. On appeal, the Court held that the court of appeals correctly determined that the district court committed clear error (i) in determining culpability was not met because Appellant's mental health diagnoses did not reduce his culpability or satisfy any other mitigating factor of the sentencing guidelines; and (ii) in determining that programming history was not met because despite Appellant's recent progress in a 45-day treatment, he had a long history of unwillingness to meaningfully participate in programming. The Court also found that the appeals court incorrectly determined the district court clearly erred in finding that the adequacy of punishment/programming available in the juvenile justice system was not met, because the district court was presented with expert testimony that the availability of trauma informed treatment in the juvenile facility would be beneficial to Appellant for public safety purposes, and weighed that information against other expert testimony on the amount of time Appellant would need to be under the juvenile court's jurisdiction for the best effect on public safety. Nonetheless, the Court concluded that the district court abused its discretion in determining that two of the factors were not met and, therefore, remanded for adult certification.

Summary of Case Context & HoldingAppellant was adjudicated as a sexually violent delinquent child (SVDC) for committing sex offenses as a juvenile and was ordered to undergo inpatient treatment at a sex offender residential treatment facility. Appellant challenged the constitutionality of the Court-Ordered Involuntary Treatment of Certain Sexually Violent Persons statute (Act 21), which he said constituted criminal punishment, so its retroactive application would be an ex post facto violation. The Supreme Court held that because Act 21 is intended as treatment, is reasonable in relation to the public safety concerns, and only requires a juvenile adjudication (rather than a criminal conviction) to apply, Act 21, is not criminal punishment and is therefore constitutional.

Summary of Case Context & HoldingThe Washoe County District Attorney charged juvenile I.S. with possessing a schedule I controlled substance and defacing property. I.S. admitted to the allegations and at a later plea hearing, the Washow County Department of Juvenile Services recommended the case be dismissed and that I.S. be placed on probation, required to complete 100 hours of community service and a youth development program, and be required to pay restitution. However, the DA argued I.S. should proceed to formal adjudication. I.S. argued that Nev. Rev. Stat. § 62C.200(1)(b), which required a prosecutor to consent before a juvenile court dismissed a petition in favor of informal supervision, was an unconstitutional "prosecutorial veto" that violated the separation of powers between the executive and judicial branches. The juvenile court declined to find that statute unconstitutional. I.S. appealed. On appeal, the Court concluded that "a juvenile court's decision to dismiss a petition without prejudice and refer a juvenile to informal supervision is not a sentencing decision, as it does not involve imposition of a period of detention or imposition of requirements under the supervision of the court with consequences to be imposed by the court if they are not satisfied." The Court reasoned that allowing the juvenile court to permit dismissal of the complaint without consent of the DA would be akin to allowing a defendant to accept a plea bargain without the prosecutor's involvement. Accordingly, the Court affirmed the juvenile court's order affirming the constitutionality of Nev. Rev. Stat. § 62C.200(1)(b).

Summary of Case Context & HoldingThe Michigan Secretary of State and Michigan Independent Citizens Redistricting Commission filed a petition seeking an extension of the deadline for Michigan to redraw its state legislative and congressional maps due to the delay of the release of census data needed to redraw the maps due to COVID-19. The Supreme Court declined to grant the extension, finding that it would be premature to grant relief ahead of the map deadline.

Summary of Case Context & HoldingThe Minnesota Pollution Control Agency (MPCA) granted air-emissions permit to mining company for proposed mine operation. Environmental advocacy groups and an indigenous tribe opposed the permit on the basis that the mining company applied for a sham permit to engage in a lower volume of mining than was actually intended in order to circumvent a stringent review process and pollution control requirements applicable to “major source” pollution producers under the Clean Air Act. The Court held that the MPCA was not obligated to investigate Appellants’ allegations, finding that the Clean Air Act did not require it. Additionally, the Court held that the MPCA’s failure to investigate the allegations was not improper because the mining company would be subject to a full major sources review if it changed its business plans and could face sanctions and increased costs to retrofit the facility with best available technology, providing deterrence and a complete remedy if the allegations were true.

Summary of Case Context & HoldingA juvenile was adjudicated delinquent for committing criminal homicide against a pregnant woman and criminal homicide of an unborn child appealed challenging the weight of the evidence. After a dispositional hearing, the juvenile court committed Defendant to a secured residential treatment facility. The commitment order allowed Defendant the right to file a post-dispositional motion within 10 days. Defendant did not submit a post-dispositional motion but instead filed a notice of appeal from the dispositional order in a Pa.R.A.P. 1925(b) statement and argued that the adjudication of his delinquency was against the weight of the evidence for specific reasons. A Pa.R.A.P. 1925(b) statement is a document required in Pennsylvania appellate courts under Rule 1925(b) of the Pennsylvania Rules of Appellate Procedure (Pa.R.A.P.). When a party files an appeal and the trial court issues a written opinion addresses the issues raised in the appeal, the appellant may file a Pa.R.A.P. 1925(b) statement. The Supreme Court held that the Pennsylvania Juvenile Rules of Court Procedure do not specify the manner in which a juvenile must present a "weight of the evidence" claim in order to preserve that claim for appellate review, and vacated the superior court's order, and remanded the case to juvenile court for further proceedings. The majority opinion, as well as the concurrence and dissent, however did not address the weight of evidence itself. Instead, the Supreme Court focused on the procedural rule and whether this case should be treated differently from a previous case.

Summary of Case Context & HoldingSeven juveniles adjudicated delinquent for sex offenses, who were required to register with Pennsylvania's Sex Offender Registration and Notification Act (SORNA), challenged the constitutionality of the statute's registration requirement. The Supreme Court held that SORNA violated the juvenile offenders' due process rights because of its "irrebuttable presumption that all juvenile offenders 'pose a high risk of committing additional sexual offenses'" despite juveniles' lower rates of recidivism.

Summary of Case Context & HoldingJuvenile was adjudicated delinquent for making terroristic threats based on comments he made in two instances. First, he stated that he “doesn't think people deserve to live and everyone should just die” in the hallway. Six days after 17 high school students at Marjory Stoneman Douglas High School in Parkland were fatally shot, he said that he "wanted to beat the record of 19." Juvenile appealed, arguing that his adjudication violated his 1st Amendment rights. The Supreme Court held that his comments were "protected speech," and that the record did not support the lower courts' characterization of the juvenile's speech as "true threats." First, the Supreme Court concluded that the First Amendment allows for the prosecution of reckless threats, as recklessness is a culpable mental state akin to intentional conduct and imposing criminal liability in such cases does not infringe on the First Amendment. Second, the Supreme Court concluded that there was very little evidence to support the characterization of the Juvenile as someone who relished death or that his first statement was heard by "anyone and everyone" in the hallway. The Supreme Court also noted that the lower court wrongfully placed the burden on the Juvenile to prove that his statement was not a true threat. The Supreme Court also concluded that the second statement lacked sufficient context and specificity to be considered a true threat. There was no evidence to show that the appellant made the statement with conscious disregard for causing terror. Therefore, his adjudication for terroristic threats must be vacated as it violates the First Amendment. The Supreme Court then vacated juvenile's adjudication of delinquency.

Summary of Case Context & HoldingDefendant, a juvenile living in a residential treatment facility, was adjudicated delinquent for misdemeanor indecent assault. The trial court notified defendant that pursuant to Section 6358 of the Juvenile Act, the Sexual Offender Assessment Board (SOAB) would evaluate whether he required further involuntary civil commitment. The trial court denied defendant's motion for additional redactions to his records, including a psychiatric evaluation report made for the purpose of his treatment in which he made incriminating statements, and the documents were delivered to SOAB as-is. The SOAB initiated civil commitment proceedings, and the trial court civilly committed defendant. Defendant appealed, and the superior court held that, while the trial court erred in failing to redact the report, the error was harmless. The Supreme Court held that harmless error doctrine was not relevant to violations of psychologist-patient privilege in Juvenile Act commitment proceedings and reversed and remanded the case for further proceedings. The Supreme Court recognized that some constitutional rights, such as the right to counsel and impartiality of the presiding judge, are so fundamental that their violation can never be treated as harmless error. In Act 21 (an amendment to the Juvenile Act that provides for assessment of juveniles who have been adjudicated delinquent for an act of sexual violence and have been subject to an institutional placement where he or she has remained through his or her 20th birthday) proceedings, which focus on the mental health treatment of juveniles, confidentiality and the assurance of trust in the therapeutic relationship are crucial for effective treatment. In this case, privileged communications between the juvenile and the psychotherapist were improperly disseminated and used by an expert witness. The Supreme Court concluded that the harm caused by the violation of the psychotherapist-patient privilege cannot be undone, and such violations undermine the success of mental health treatment. The Supreme Court determined that strict adherence to the psychotherapist-patient privilege is essential for fair Act 21 proceedings and, thus, the harmless error doctrine is not applicable in cases where the privilege is violated.

Summary of Case Context & HoldingIn the underlying litigation, Plaintiff Planned Parenthood filed suit against the Attorney General on April 7, 2022, seeking a declaratory judgment that MCL 750.14, a statute that criminalizes the administration of abortions, is unconstitutional under the state Constitution's Due Process Clause. The court of claims rejected the Attorney General's argument that no cognizable controversy existed because the Attorney General agreed with Planned Parenthood that the statute was unconstitutional. The Court went on to grant a preliminary injunction against enforcement of the statute on the basis that, among other things, Planned Parenthood had shown a substantial likelihood of success on the merits. The Court purported to bind all prosecutors in the state to this injunction, even though no such prosecutors were parties to that case. On May 17, 2022, Judge Gleicher entered a preliminary injunction in the court of claims case which purported to enjoin Michigan county prosecutors from enforcing MCL 750.14. In August 2022 the court of appeals ordered that the Plaintiffs Jarzynka and Becker were not bound by the injunction because it did not apply to county prosecutors. The court of appeals also determined that Plaintiffs Right to Life of Michigan and Michigan Catholic Conference lacked standing and an application for leave to appeal ensued. As recently as May 2023, the Supreme Court denied the application and the motion to dismiss.

Summary of Case Context & HoldingDefendant was found guilty of 10 counts of aggravated criminal sexual assault and adjudicated a delinquent minor under the Juvenile Court Act. Defendant argued on appeal that the circuit court had failed to conduct an inquiry into his pro se claim of ineffective assistance of counsel pursuant to People v. Krankel, 464 N.E.2d 1045 (Ill. 1984) after Defendant said, regarding his counsel’s performance, “We don’t talk. I’m never prepared for the stand. He does not answer calls.” The Supreme Court held that the Krankel procedure applies in juvenile delinquency proceedings, and equally to retained and appointed counsel. Furthermore, Defendant’s statement was a clear claim of ineffective assistance of counsel, so once it was memorialized in his social investigation report – the juvenile equivalent of a presentence investigation report–and provided to the circuit court, the circuit court erred in not conducting a preliminary Krankel inquiry.

Summary of Case Context & HoldingMinor 12 year old complainant was charged with seven felony and misdemeanor offenses such as theft, shooting of a calf, and criminal trespass. The Ninth Judicial District Youth Court adjudicated K.J.R. to be a "delinquent youth." The youth court committed K.J.R. “to the supervision” of the youth court until age 18, or sooner released, for placement at a specific therapeutic group home in Billings, Montana due to his parents both being incarcerated. K.J.R. was placed in a non-therapeutic group home in Great Falls and then moved throughout multiple facilities and foster care homes and detention centers. After many bouts of movement due to delinquency, K.J.R. was committed by the court to supervision of the Montana Department of Corrections (DOC) for placement in the Pine Hills Youth Correctional Facility until 18 or sooner released. K.J.R. challenged the legality of a youth court order that committed him to the DOC. The Court found that the youth court retained broad discretion under § 41-5-1422(1), MCA, to revoke K.J.R.’s original youth court commitment under § 41-5-1512(1)(c), MCA, and then to recommit him to DOC for placement in a youth correctional facility pursuant to § 41-5-1513(1)(b), MCA. K.J.R. made no particularized showing that any substantive youth court finding of fact or factual consideration was clearly erroneous.

Summary of Case Context & HoldingThe Department removed two children from their mother due to the mother's inability to care for the infants. The mother has developmental delays stemming from Fetal Alcohol Spectrum Disorder (FASD), a disability under the Americans with Disabilities Act of 1990 (ADA). As part of her treatment plan, Mother engaged in Parent Child Interaction Therapy (PCIT) and Theraplay with a therapist experienced in working with parents with FASD. She also attended individual counseling with a separate therapist also experienced in working with individuals with FASD. Both opined that after extensive sessions with Mother she was still unable to safely parent the children. The district court terminated Mother’s parental rights under § 41-3-609(1)(f), MCA. On appeal, Mother argued the Department and district court failed to provide her with reasonable accommodations under the ADA and did not provide her with active efforts before terminating her parental rights under the Indian Child Welfare Act (ICWA). The ADA applies to dependent neglect cases and the Department is obligated to provide parents with reasonable accommodations. However, the requirements of Title 41, Chapter 3, MCA, to provide reasonable efforts and to develop an appropriate individualized treatment plan to provide services that must accommodate the issues facing the parent and child, such as the parent's disability are consistent with the ADA requirements for reasonable accommodations. If the Department fails to take into account a parent’s limitations or disabilities and make reasonable accommodations, then it did not develop an appropriate treatment plan or make reasonable efforts. The district court is not required to make specific findings under the ADA when terminating parental rights. Here, the district court did not abuse its discretion because the Department provided Mother with services that took her disability into account and Mother never requested additional or different services. Mother’s providers opined there are no accommodations that could result in Mother obtaining the requisite parenting skills to meet the children’s daily needs.

Summary of Case Context & HoldingDefendant, while a juvenile in Missouri, allegedly took the victim’s car by force or threat of force. The Supreme Court considered de novo whether, under Section 5-120 of the Juvenile Court Act, a minor who is a resident of Illinois may be adjudicated delinquent for unlawful conduct committed outside of Illinois. The Supreme Court held that section 5-120 unambiguously authorizes delinquency proceedings in Illinois for unlawful conduct in any state, noting the legislature’s use of the word “any” and Section 5-120’s authorization of prosecution in juvenile court for federal law violations regardless of the location of the act.

Summary of Case Context & HoldingThe State charged the Appellant, L.W., then a minor, with possession of a controlled substance with the intent to sell after the school's administration conducted a search of all its enrollees and marijuana was found in L.W.'s possession. Due to behavior problems, L.W. was enrolled to the school on a trial basis on the condition that he sign a "Behavior Contract," which included L.W.'s consent to random searches by school administration. L.W. objected to the admission of evidence resulting from the search as unconstitutionally obtained. His request to suppress the evidence was declined and he was found guilty of the State's charge. The district court affirmed and formally adjudicated L.W. delinquent and L.W. appealed. On appeal, the issue before the Court was whether the State can condition a prospective minor student's access to public education on that student's waiver of his right to be free from unreasonable search and seizure under the Fourth Amendment. The Court noted that a "warrant- and suspicion-less search of a student, of the sort that the [school] administration conducted upon L.W., is presumptively unreasonable, absent that student's consent (or other applicable exception)" and such consent must be both intelligently and voluntarily given. The Court concluded that the State failed to demonstrate that L.W.'s consent to search was voluntary because there was no record of evidence of public education options beyond the school he attended that were available to him, and the State could therefore not constitutionally condition L.W.'s access to a public education on his waiver of his right to be free from unreasonable search and seizure. Accordingly, the Court held that the district court should have suppressed the fruits of the administration's search.

Summary of Case Context & HoldingAfter filing a claim for unemployment benefits, Petitioner-Employee left work five days later "to protect his health" due to the diminishing physical health condition of his knees. An adjudicator of the Adjudication Unit of the North Carolina Division of Employment Security then held that Petitioner was disqualified from receiving benefits because he failed to show good cause for leaving work attributable to the employer as required under North Carolina law. That decision was then upheld by the Board of Review for the North Carolina Department of Commerce, by the Superior Court, and by the court of appeals. The Supreme Court affirmed the decision noting that while Petitioner left work for good cause, he failed to satisfy his burden to show that his leaving work was “attributable to the employer” as a matter of law.

Summary of Case Context & HoldingDefendant was convicted as a juvenile of aggravated domestic battery, aggravated battery, battery, and domestic battery. The trial court ordered her to register under the Murder and Violent Offender Against Youth Registration Act, which mandated that she register as an adult violent offender against youth within 10 days of her seventeenth birthday. Defendant alleged that the statue violated her rights to equal protection, substantive due process, and procedural due process. The Supreme Court held that the registration act was constitutional under both the Illinois Constitution and the U.S. Constitution. First, the equal protection clause guarantees that "similarly situated" individuals be treated equally, and Defendant alleged that junior violent offenders were "similarly situated" to junior sex offenders. The Court rejected this notion, highlighting that the two groups were covered by two different statutes and thus the legislature intended for them to be treated differently. Given the lack of a similar situation, the Court found that the equal protection clause did not cover Defendant's claim. Second, relying on the U.S. Supreme Court's decision in Connecticut Department of Public Safety v. Doe, 538 U.S. 1 (2003), the Court held that Defendant could not seek a hearing to establish that she was not "dangerous" because "dangerousness" was immaterial to the registration act. Registration under the act was solely based on conviction status, and thus there was no procedural due process violation in failing to afford a hearing determining "dangerousness." Lastly, the Court upheld the statute under the rational basis test and held that requiring juvenile registration did not violate Defendant's substantive due process rights because it reasonably accomplishes its goal of protecting the public from juvenile violent offenders by requiring those convicted of certain violent crimes to register upon turning 17 years old.

Summary of Case Context & HoldingThe Supreme Court granted certiorari to address whether the court of appeals erred in dismissing as moot the appeal of a juvenile delinquency adjudication. Defendant was found delinquent for criminal attempt to enter an automobile and was placed on probation for 12 months. Defendant appealed, arguing the evidence was insufficient to support the juvenile court's adjudication of delinquency. When Defendant's probationary sentence concluded, the court of appeals dismissed the appeal as moot because the probationary sentence had expired and Defendant had not shown "any adverse collateral consequences arising from the juvenile court’s adjudication of him as delinquent.” The Supreme Court noted that "the consequences of a juvenile’s adjudication of delinquency continue to reverberate even after the expiration of his disposition." The Supreme Court reversed, holding that a juvenile who appeals his adjudication of delinquency is not required to show adverse collateral consequences in the record. Such consequences will be presumed.

Summary of Case Context & HoldingWife, Maria Rendon Quijada (Rendon), filed for divorce from husband, Julian Pimienta Dominguez (Pimienta). Rendon was an Arizona resident and Mexican national with an expired visa. Pimienta was a Virginia resident and Mexican national with a current visa. Pimienta moved to dismiss the divorce action for lack of subject matter jurisdiction, claiming that federal immigration law divests Arizona courts of jurisdiction over a divorce sought by a noncitizen on an expired visa. The Court denied the motion to dismiss and found in favor of Rendon for the following reasons: (i) non-U.S. citizens in the United States on a visa can both comply with their federal nonimmigrant status and establish domiciliary intent under Arizona divorce laws; and (ii) federal immigration statutes do not expressly preempt application of domiciliary state law related to divorces. Ultimately, the Court held that the divorce proceedings under Arizona law did not involve or interfere with adjudication of Rendon's immigration status or benefits or impact her immigration status or removability, but rather would only require Arizona courts to conduct divorce proceedings. Therefore, Rendon, despite her U.S. citizenship status, was permitted to bring a divorce action under Arizona law.

Summary of Case Context & HoldingA group of landowners petitioned the Renville County Board of Commissioners for improvements to Renville County Ditch 77, which would affect the upper reach of Limbo Creek. Environmental organizations requested that the County complete an environmental assessment worksheet, asserting that the upper reach of Limbo Creek is a public water for which environmental review is required. The County denied the request for environmental review, finding that the upper reach of Limbo Creek is not a public water because it does not appear on the public waters inventory list for Renville County. The court of appeals reversed and remanded, concluding that the statutory definition of "public waters" controls, not the inventory. The Court expressly declined to decide whether the public waters inventory is generally conclusive as to the classification of public waters, finding only that it was not conclusive as to the specific body of water then at issue due to discrepancies in the relevant state and county records. Instead, the Court held that the statutory definition of "public waters" controls, and affirmed the decision of the court of appeals to remand for preparation of a mandatory environmental assessment worksheet.