State Supreme Court Data Tracker
Use this data to spot trends, anticipate what’s next, and supercharge your advocacy.
| Case Name | State | Year | Topic | ||
|---|---|---|---|---|---|
|
In re N.C., 105 A.3d 1199 (Pa. 2014)
|
Pennsylvania | 2014 | Criminal Justice, Juvenile Justice |
State:
Pennsylvania
Year:
2014
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA juvenile was adjudicated delinquent in the court of common pleas for aggravated indecent assault of a three-year old child. The juvenile appealed, alleging that the juvenile court's admission of an out-of-court, video-taped, forensic interview of the child complainant (who state acknowledged was not responsive during direct examination at trial and objected to continued questioning) under the Tender Years Hearsay Act without cross-examination violated the 6th Amendment's Confrontation Clause. The Supreme Court held that given the Commonwealth's concession that continued questioning was futile and the court's subsequent removal of the child complainant from the stand, the admission of her video testimony violated the juvenile's 6th Amendment rights. The Supreme Court affirmed the superior court's opinion vacating the dispositional order and remanded the case for a new hearing.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
A juvenile was adjudicated delinquent in the court of common pleas for aggravated indecent assault of a three-year old child. The juvenile appealed, alleging that the juvenile court's admission of an out-of-court, video-taped, forensic interview of the child complainant (who state acknowledged was not responsive during direct examination at trial and objected to continued questioning) under the Tender Years Hearsay Act without cross-examination violated the 6th Amendment's Confrontation Clause. The Supreme Court held that given the Commonwealth's concession that continued questioning was futile and the court's subsequent removal of the child complainant from the stand, the admission of her video testimony violated the juvenile's 6th Amendment rights. The Supreme Court affirmed the superior court's opinion vacating the dispositional order and remanded the case for a new hearing.
Link to Opinion
|
||||
|
In re Nat'l Energy Marketers Ass'n v. N.Y. State Pub. Serv. Comm'n, 126 N.E.3d 1041 (N.Y. 2019)
|
New York | 2019 | Environment, Climate Change/Global Warming/Emissions, Actions Against Government |
State:
New York
Year:
2019
Topics:
Environment, Climate Change/Global Warming/Emissions, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2014, following an investigative process, the Public Service Commission (PSC) issued an order finding energy service companies (ESCOs) were charging their residential or small-scale customers higher prices than those charged by utilities. Two years later, the PSC issued a Reset Order to address these pricing concerns. Specifically, the Reset Order conditioned access to public utility infrastructure by energy service companies upon them caping their prices such that, on an annual basis, they charge no more for electricity than is charged by public utilities, unless 30% of energy is derived from renewable resources. The ESCOs and their respective trade associations challenged the Order, alleging it should be annulled as arbitrary and capricious and in excess of the PSC's authority. The Court of Appeals ruled that ESCOs do not fall within the definition of "gas corporation" and "electric corporation" and thus are not subject to the PSC's direct rate-making authority under Public Service Law article 4. However, the Court of Appeals concluded that under the PSC's authority to regulate utilities' transportation of ESCOs' gas and electricity, the PSC may condition access to utility infrastructure upon ESCO's compliance with a price cap on gas or electricity. The Court of Appeals held that the lower court should have issued a declaration to the effect that the PSC did not exceed its authority under the state's Public Service Law or violate the Petitioners' constitutional rights in issuing the Order.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
In 2014, following an investigative process, the Public Service Commission (PSC) issued an order finding energy service companies (ESCOs) were charging their residential or small-scale customers higher prices than those charged by utilities. Two years later, the PSC issued a Reset Order to address these pricing concerns. Specifically, the Reset Order conditioned access to public utility infrastructure by energy service companies upon them caping their prices such that, on an annual basis, they charge no more for electricity than is charged by public utilities, unless 30% of energy is derived from renewable resources. The ESCOs and their respective trade associations challenged the Order, alleging it should be annulled as arbitrary and capricious and in excess of the PSC's authority. The Court of Appeals ruled that ESCOs do not fall within the definition of "gas corporation" and "electric corporation" and thus are not subject to the PSC's direct rate-making authority under Public Service Law article 4. However, the Court of Appeals concluded that under the PSC's authority to regulate utilities' transportation of ESCOs' gas and electricity, the PSC may condition access to utility infrastructure upon ESCO's compliance with a price cap on gas or electricity. The Court of Appeals held that the lower court should have issued a declaration to the effect that the PSC did not exceed its authority under the state's Public Service Law or violate the Petitioners' constitutional rights in issuing the Order.
Link to Opinion
|
||||
|
In re Nat'l Fuel Gas Supply Corp. v. Schueckler, 150 N.E.3d 1192 (N.Y. 2020)
|
New York | 2020 | Environment, Pollution/Contamination |
State:
New York
Year:
2020
Topics:
Environment, Pollution/Contamination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingNational Fuel Gas Supply brought an Eminent Domain Procedure Law (EDPL) vesting proceeding to acquire temporary construction easements and a fifty-foot-wide permanent easement over respondent landowners' property to build a 99-mile gas pipeline from Pennsylvania to Western New York. The New York Supreme Court granted the EDPL petition, concluding that National Fuel made a prima facie showing of entitlement to the easements based on the Federal Energy Regulatory Commission (FERC) certificate of public convenience and necessity. The New York Appellate Division reversed this lower court decision, holding that the New York State Department of Environmental Conservation's intervening denial of National Fuel's application for a water quality certification meant that National Fuel no longer held a qualifying federal certificate for purposes of the EDPL exemption. The Court of Appeals reversed, holding that the federal certificate was still valid because the FERC-issued certificate of public convenience and necessity did not condition National Fuel's eminent domain authority on receipt of a water qualify certification. The Court of Appeals further held that while a FERC certificate of public convenience and necessity contains numerous "conditions," including receiving a water quality certificate, these conditions cannot be reasonably understood as rendering the certificate provisional for purposes of eminent domain, since they are not conditions addressing the validity of the certificate itself.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
National Fuel Gas Supply brought an Eminent Domain Procedure Law (EDPL) vesting proceeding to acquire temporary construction easements and a fifty-foot-wide permanent easement over respondent landowners' property to build a 99-mile gas pipeline from Pennsylvania to Western New York. The New York Supreme Court granted the EDPL petition, concluding that National Fuel made a prima facie showing of entitlement to the easements based on the Federal Energy Regulatory Commission (FERC) certificate of public convenience and necessity. The New York Appellate Division reversed this lower court decision, holding that the New York State Department of Environmental Conservation's intervening denial of National Fuel's application for a water quality certification meant that National Fuel no longer held a qualifying federal certificate for purposes of the EDPL exemption. The Court of Appeals reversed, holding that the federal certificate was still valid because the FERC-issued certificate of public convenience and necessity did not condition National Fuel's eminent domain authority on receipt of a water qualify certification. The Court of Appeals further held that while a FERC certificate of public convenience and necessity contains numerous "conditions," including receiving a water quality certificate, these conditions cannot be reasonably understood as rendering the certificate provisional for purposes of eminent domain, since they are not conditions addressing the validity of the certificate itself.
Link to Opinion
|
||||
|
In re Northmet Project Permit to Mine Application Dated Dec. 2017, 959 N.W.2d 731 (Minn. 2021)
|
Minnesota | 2021 | Environment, Pollution/Contamination, Actions Against Government |
State:
Minnesota
Year:
2021
Topics:
Environment, Pollution/Contamination, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingMinnesota Department of Natural Resources (DNR) issued a permit to mine and two dam-safety permits to PolyMet to build and operate Minnesota’s first copper-nickel mine, which posed water contamination risks. In issuing the permits, the DNR denied petitions by several parties requesting contested case hearings to address various concerns regarding the safety and environmental impact of the mine, holding that the petitioning parties had not alleged they owned property in sufficient proximity to the mine to be affected by its operation. The appeals court reversed and remanded to the DNR, overruling the DNR's determination that the petitioners did not have standing and ordering the DNR to hold a contested case hearing on each of the issues petitioners raised. The Court affirmed the court of appeals' holding that respondents were not required to own property adjacent to the mine to have standing to request a contested case hearing. Next, the Court found that the court of appeals applied the wrong standard of review in failing to defer to the DNR's judgment regarding whether a contested case hearing was required, holding that a contested case hearing was required on only one of the issues raised by respondents. The Court reversed the court of appeals' order requiring a contested case hearing on the remaining issues raised by petitioners, finding the DNR did not abuse its discretion in denying those petitions because the denials were supported by substantial evidence. The Court affirmed the court of appeals' reversal of DNR's grant of the permit to mine, finding that the DNR erred by issuing the permit without an appropriate fixed term. Finally, the Court held that the court of appeals erred in reversing the two dam-safety permits, finding that the dam-safety permits are governed by different legal standards than the mining permit and the court of appeals' decision to reverse those permits without considering the separate record on which the DNR relied for those permits was an error of law.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Minnesota Department of Natural Resources (DNR) issued a permit to mine and two dam-safety permits to PolyMet to build and operate Minnesota’s first copper-nickel mine, which posed water contamination risks. In issuing the permits, the DNR denied petitions by several parties requesting contested case hearings to address various concerns regarding the safety and environmental impact of the mine, holding that the petitioning parties had not alleged they owned property in sufficient proximity to the mine to be affected by its operation. The appeals court reversed and remanded to the DNR, overruling the DNR's determination that the petitioners did not have standing and ordering the DNR to hold a contested case hearing on each of the issues petitioners raised. The Court affirmed the court of appeals' holding that respondents were not required to own property adjacent to the mine to have standing to request a contested case hearing. Next, the Court found that the court of appeals applied the wrong standard of review in failing to defer to the DNR's judgment regarding whether a contested case hearing was required, holding that a contested case hearing was required on only one of the issues raised by respondents. The Court reversed the court of appeals' order requiring a contested case hearing on the remaining issues raised by petitioners, finding the DNR did not abuse its discretion in denying those petitions because the denials were supported by substantial evidence. The Court affirmed the court of appeals' reversal of DNR's grant of the permit to mine, finding that the DNR erred by issuing the permit without an appropriate fixed term. Finally, the Court held that the court of appeals erred in reversing the two dam-safety permits, finding that the dam-safety permits are governed by different legal standards than the mining permit and the court of appeals' decision to reverse those permits without considering the separate record on which the DNR relied for those permits was an error of law.
Link to Opinion
|
||||
|
In re November 3, 2020 Gen. Election, 240 A.3d 591 (Pa. 2020)
|
Pennsylvania | 2020 | Democracy & Voting, Voting Rights |
State:
Pennsylvania
Year:
2020
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingBecause of the increase in mail-in ballots due to the COVID-19 pandemic, in advance of the November 2020 presidential election, the Secretary of the Commonwealth issued guidance documents for the Pennsylvania Boards of Election when processing mail-in ballots, which included guidance prohibiting the rejection of ballots based on signature matching. Ruling on an application for relief by the Pennsylvania Secretary of the Commonwealth, the Supreme Court sided with the Secretary and held that county Boards of Elections were prohibited from rejecting absentee ballots based on signature matching. The Supreme Court reasoned that the Commonwealth's Election Code was plain and unambiguous, and that the process for verifying a voter's identity and the sufficiency of a voter's ballot did not extend to signature comparison. Further, the Supreme Court stated it would not read signature matching into the Election Code where the state's general assembly intentionally omitted it.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Because of the increase in mail-in ballots due to the COVID-19 pandemic, in advance of the November 2020 presidential election, the Secretary of the Commonwealth issued guidance documents for the Pennsylvania Boards of Election when processing mail-in ballots, which included guidance prohibiting the rejection of ballots based on signature matching. Ruling on an application for relief by the Pennsylvania Secretary of the Commonwealth, the Supreme Court sided with the Secretary and held that county Boards of Elections were prohibited from rejecting absentee ballots based on signature matching. The Supreme Court reasoned that the Commonwealth's Election Code was plain and unambiguous, and that the process for verifying a voter's identity and the sufficiency of a voter's ballot did not extend to signature comparison. Further, the Supreme Court stated it would not read signature matching into the Election Code where the state's general assembly intentionally omitted it.
Link to Opinion
|
||||
|
In re Petition for Expungement of the Crim. Rec. Belonging to T.O., 242 A.3d 842 (N.J. 2021)
|
New Jersey | 2021 | Criminal Justice, Access to Justice |
State:
New Jersey
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA former offender who received a full pardon from the governor for his two unrelated convictions filed a petition to expunge the records of those convictions. Both the trial court and the Appellate Division denied the petition pursuant to a statute which made offenders with multiple convictions ineligible for expungement. The issue presented to the New Jersey Supreme Court was whether a pardon, which removes legal disabilities linked to a conviction, should dissolve the statutory bar to eligibility for expungement. The Supreme Court held that the former offender was entitled to expungement of the convictions, reasoning that the statutory bar was a legal disability coming into play solely because of the prior convictions, so the pardon should dissolve the statutory bar. Pardons do not retroactively "blot out" past guilt, but they eliminate prospective legal consequences of that guilt. Therefore, no further legal consequences should flow from a crime that has been pardoned. Further, a pardon does not automatically lead to expungement, but entitles one to seek expungement.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
A former offender who received a full pardon from the governor for his two unrelated convictions filed a petition to expunge the records of those convictions. Both the trial court and the Appellate Division denied the petition pursuant to a statute which made offenders with multiple convictions ineligible for expungement. The issue presented to the New Jersey Supreme Court was whether a pardon, which removes legal disabilities linked to a conviction, should dissolve the statutory bar to eligibility for expungement. The Supreme Court held that the former offender was entitled to expungement of the convictions, reasoning that the statutory bar was a legal disability coming into play solely because of the prior convictions, so the pardon should dissolve the statutory bar. Pardons do not retroactively "blot out" past guilt, but they eliminate prospective legal consequences of that guilt. Therefore, no further legal consequences should flow from a crime that has been pardoned. Further, a pardon does not automatically lead to expungement, but entitles one to seek expungement.
Link to Opinion
|
||||
|
In re Petition of Pa. Prison Soc'y, 228 A.3d 885 (Pa. 2020)
|
Pennsylvania | 2020 | Health Care, Public Health, Criminal Justice |
State:
Pennsylvania
Year:
2020
Topics:
Health Care, Public Health, Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPetitioner, a non-profit organization, asked the Supreme Court to invoke King's Bench jurisdiction (the extraordinary jurisdiction of the Supreme Court over inferior courts) to immediately release specified categories of incarcerated persons to prevent the spread of COVID-19. The Supreme Court denied the petition, holding that it would not order the immediate presumptive release of specified categories of incarcerated persons. The Supreme Court considered the potential danger of inmates to victims and the general population, as well as the diversity of situations present within individual institutions and communities.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Petitioner, a non-profit organization, asked the Supreme Court to invoke King's Bench jurisdiction (the extraordinary jurisdiction of the Supreme Court over inferior courts) to immediately release specified categories of incarcerated persons to prevent the spread of COVID-19. The Supreme Court denied the petition, holding that it would not order the immediate presumptive release of specified categories of incarcerated persons. The Supreme Court considered the potential danger of inmates to victims and the general population, as well as the diversity of situations present within individual institutions and communities.
Link to Opinion
|
||||
|
In re Petition to Transfer Territory from Vaughn Elementary Sch. Dist. No. 74, 360 P.3d 1119 (Mont. 2015)
|
Montana | 2015 | Education |
State:
Montana
Year:
2015
Topics:
Education
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPower Elementary School District No. 30 (Power Elementary) appealed a district court order affirming an administrative panel's dismissal of a petition for the transfer of territory from Vaughn Elementary School District No. 74 (Vaughn Elementary) to Power Elementary on the grounds that the transfer territory was not located within three miles of an operating school because the transfer territory (i.e., the Attendance Center ran by Vaughn Elementary) was not an "operating school" under Section 20-6-105(1)(a)(iii), MCA. The Court affirmed the district court's decision to uphold the panel's dismissal of the petition, ruling that the attendance center operated by Vaughn Elementary was a school even though it was not opened consistent with the procedures set forth in Section 20-6-502, MCA, which required a vote by the county commissioners and formal approval by the state superintendent. The Court reasoned that because the attendance center "was approved by local school authorities and approved for funding by state school authorities, staffed with school employees, funded with public resources, regulated under state and federal law, and opened to all qualifying students" it was a school established under Montana law. The Court noted that an alternative outcome would put form over substance, especially as county commissioners do not exercise direct supervision over public schools and the state superintendent's office "approved the Attendance Center de facto by funding and regulating it."
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Power Elementary School District No. 30 (Power Elementary) appealed a district court order affirming an administrative panel's dismissal of a petition for the transfer of territory from Vaughn Elementary School District No. 74 (Vaughn Elementary) to Power Elementary on the grounds that the transfer territory was not located within three miles of an operating school because the transfer territory (i.e., the Attendance Center ran by Vaughn Elementary) was not an "operating school" under Section 20-6-105(1)(a)(iii), MCA. The Court affirmed the district court's decision to uphold the panel's dismissal of the petition, ruling that the attendance center operated by Vaughn Elementary was a school even though it was not opened consistent with the procedures set forth in Section 20-6-502, MCA, which required a vote by the county commissioners and formal approval by the state superintendent. The Court reasoned that because the attendance center "was approved by local school authorities and approved for funding by state school authorities, staffed with school employees, funded with public resources, regulated under state and federal law, and opened to all qualifying students" it was a school established under Montana law. The Court noted that an alternative outcome would put form over substance, especially as county commissioners do not exercise direct supervision over public schools and the state superintendent's office "approved the Attendance Center de facto by funding and regulating it."
Link to Opinion
|
||||
|
In re Q.P., 40 N.E.3d 9 (Ill. 2015)
|
Illinois | 2015 | Criminal Justice, Juvenile Justice |
State:
Illinois
Year:
2015
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant, a minor, was found guilty of knowingly furnishing false information to a police officer with the intent to prevent his own apprehension. Defendant admitted that while at the scene of a vehicle burglary in progress, he gave a police detective a misspelled name because he knew there was a prior warrant for his arrest. Defendant argued on appeal that he was already apprehended when he gave the false information, since he was already handcuffed and in the back of the police car. The appellate court construed "apprehension" to mean a seizure, and held that "a person already apprehended cannot act with the intent to prevent his own apprehension on other charges." On appeal by the State, the Supreme Court reversed the appellate court's judgment in favor of Defendant. The Supreme Court cited statutory language as the most reliable indicator of legislative intent, and noted that Defendant had clearly not been apprehended for the outstanding juvenile warrant, but rather apprehended solely for the vehicle burglary. The Supreme Court thus held that a rational trier of fact could have found that Defendant’s actions satisfied all of the elements of the offense of furnishing false information (a misspelled name) with the intent to prevent apprehension (for the outstanding juvenile warrant), and, accordingly reversed the appellate court’s judgment overturning the Defendant’s delinquency adjudication.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Defendant, a minor, was found guilty of knowingly furnishing false information to a police officer with the intent to prevent his own apprehension. Defendant admitted that while at the scene of a vehicle burglary in progress, he gave a police detective a misspelled name because he knew there was a prior warrant for his arrest. Defendant argued on appeal that he was already apprehended when he gave the false information, since he was already handcuffed and in the back of the police car. The appellate court construed "apprehension" to mean a seizure, and held that "a person already apprehended cannot act with the intent to prevent his own apprehension on other charges." On appeal by the State, the Supreme Court reversed the appellate court's judgment in favor of Defendant. The Supreme Court cited statutory language as the most reliable indicator of legislative intent, and noted that Defendant had clearly not been apprehended for the outstanding juvenile warrant, but rather apprehended solely for the vehicle burglary. The Supreme Court thus held that a rational trier of fact could have found that Defendant’s actions satisfied all of the elements of the offense of furnishing false information (a misspelled name) with the intent to prevent apprehension (for the outstanding juvenile warrant), and, accordingly reversed the appellate court’s judgment overturning the Defendant’s delinquency adjudication.
Link to Opinion
|
||||
|
In re Ranco Sand & Stone Corp. v. Vecchio, 49 N.E.3d 1165 (N.Y. 2016)
|
New York | 2016 | Environment, Pollution/Contamination, Actions Against Government |
State:
New York
Year:
2016
Topics:
Environment, Pollution/Contamination, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPetitioner Ranco Sand and Stone Corp owns two parcels of contiguous property in an area zoned for residential use in Suffolk County and leased a parcel to a private school bus company which was used as a bus yard and trucking station. Although this use was unapproved and nonconforming, the Town had not enforced the residential zoning requirement against Ranco. Ranco applied to rezone the parcel from residential to heavy industrial use. Following a public hearing, the Town's Planning Board adopted a resolution issuing a positive declaration that rezoning the parcel may have a significant effect on the environment and required Ranco to prepare a draft environmental impact statement (DEIS). Ranco challenged the Board's decision pursuant to the State Environmental Quality Review Act (SEQRA) and sought to annul it on the grounds that the declaration was "arbitrary, capricious, and unauthorized." The Court of Appeals held that Ranco does not claim the declaration is unauthorized, or that the property is not subject to SEQRA, nor does it present any other basis to conclude the Town acted outside the scope of its authority. Therefore the Court of Appeals affirmed the lower court's order and ruled the matter was not ripe for judicial review.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Petitioner Ranco Sand and Stone Corp owns two parcels of contiguous property in an area zoned for residential use in Suffolk County and leased a parcel to a private school bus company which was used as a bus yard and trucking station. Although this use was unapproved and nonconforming, the Town had not enforced the residential zoning requirement against Ranco. Ranco applied to rezone the parcel from residential to heavy industrial use. Following a public hearing, the Town's Planning Board adopted a resolution issuing a positive declaration that rezoning the parcel may have a significant effect on the environment and required Ranco to prepare a draft environmental impact statement (DEIS). Ranco challenged the Board's decision pursuant to the State Environmental Quality Review Act (SEQRA) and sought to annul it on the grounds that the declaration was "arbitrary, capricious, and unauthorized." The Court of Appeals held that Ranco does not claim the declaration is unauthorized, or that the property is not subject to SEQRA, nor does it present any other basis to conclude the Town acted outside the scope of its authority. Therefore the Court of Appeals affirmed the lower court's order and ruled the matter was not ripe for judicial review.
Link to Opinion
|
||||
|
In re Renewal TEAM Acad. Charter Sch., 252 A.3d 1008 (N.J. 2021)
|
New Jersey | 2021 | Education, Access to Education/Funding |
State:
New Jersey
Year:
2021
Topics:
Education, Access to Education/Funding
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingSeven Newark charter schools applied to amend or renew their charters, seeking to increase enrollment beginning in the 2016-17 school year. The Newark Public Schools (the District) submitted comments to the New Jersey Commissioner of Education (the Commissioner) in response to six applications, but did not raise a challenge or make a showing that the proposed expansions would prevent it from providing its students the "thorough and efficient" education required under the New Jersey Constitution. Citing In re Grant of Charter School Application of Englewood on the Palisades Charter School, 753 A.3d 687, 697-98 (N.J. 2000), the Supreme Court held that if a charter school's district of residence demonstrates with specificity that the constitutional requirement of a thorough and efficient education would be jeopardized by diverting district funding to a charter school, the Commissioner must evaluate carefully the question of fiscal harm. However, in the instant case, the District made no such preliminary showing. The Supreme Court did not disturb the Commissioner’s grant of the charter school expansion applications challenged in this appeal, but the Supreme Court did note that for future applications to open or expand charter schools, the Commissioner must thoroughly address both (i) the racial impact that a charter school applicant will have on the district of residence in which the charter school will operate; and (ii) the potential effect of the charter expansions on the percentage of charter school students and students in District-operated schools who are English language learners or students with disabilities.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Seven Newark charter schools applied to amend or renew their charters, seeking to increase enrollment beginning in the 2016-17 school year. The Newark Public Schools (the District) submitted comments to the New Jersey Commissioner of Education (the Commissioner) in response to six applications, but did not raise a challenge or make a showing that the proposed expansions would prevent it from providing its students the "thorough and efficient" education required under the New Jersey Constitution. Citing In re Grant of Charter School Application of Englewood on the Palisades Charter School, 753 A.3d 687, 697-98 (N.J. 2000), the Supreme Court held that if a charter school's district of residence demonstrates with specificity that the constitutional requirement of a thorough and efficient education would be jeopardized by diverting district funding to a charter school, the Commissioner must evaluate carefully the question of fiscal harm. However, in the instant case, the District made no such preliminary showing. The Supreme Court did not disturb the Commissioner’s grant of the charter school expansion applications challenged in this appeal, but the Supreme Court did note that for future applications to open or expand charter schools, the Commissioner must thoroughly address both (i) the racial impact that a charter school applicant will have on the district of residence in which the charter school will operate; and (ii) the potential effect of the charter expansions on the percentage of charter school students and students in District-operated schools who are English language learners or students with disabilities.
Link to Opinion
|
||||
|
In re Robbinsville Twp. Bd. of Educ. v. Wash. Twp. Educ. Ass'n, 149 A.3d 1283 (N.J. 2016)
|
New Jersey | 2016 | Labor, Employment & Economic Justice, Collective Bargaining |
State:
New Jersey
Year:
2016
Topics:
Labor, Employment & Economic Justice, Collective Bargaining
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe CNA between the Robbinsville Township Board of Education and the Washington Township Education Association (Association) had stated that teachers’ salaries would be based on 188 days for new teachers and 185 days for all other teachers. In 2010, a series of events caused a significant reduction in the Board’s funding and the Board requested the Association to reopen negotiations. However, the Association declined each time. In May 2010, the Board imposed a three day furlough on the remaining teachers, reducing their work year from 185 to 182 days. The Association filed an unfair practice charge with the Public Employment Relations Commission (PERC), which found in favor of the Board reasoning that the furlough was a non-negotiable managerial prerogative. The Association appealed, and the appellate division upheld the PERC’s decision. The Supreme Court disagreed with the PERC and reversed the Appellate Division and ruled that even during times of economic crisis, boards of education must negotiate employees’ work hours and cannot unilaterally alter those hours.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
The CNA between the Robbinsville Township Board of Education and the Washington Township Education Association (Association) had stated that teachers’ salaries would be based on 188 days for new teachers and 185 days for all other teachers. In 2010, a series of events caused a significant reduction in the Board’s funding and the Board requested the Association to reopen negotiations. However, the Association declined each time. In May 2010, the Board imposed a three day furlough on the remaining teachers, reducing their work year from 185 to 182 days. The Association filed an unfair practice charge with the Public Employment Relations Commission (PERC), which found in favor of the Board reasoning that the furlough was a non-negotiable managerial prerogative. The Association appealed, and the appellate division upheld the PERC’s decision. The Supreme Court disagreed with the PERC and reversed the Appellate Division and ruled that even during times of economic crisis, boards of education must negotiate employees’ work hours and cannot unilaterally alter those hours.
Link to Opinion
|
||||
|
In re S.C. NAACP Hous. Advoc. Program, 897 S.E.2d 691 (S.C. 2024)
|
South Carolina | 2024 | Housing, Tenant Rights |
State:
South Carolina
Year:
2024
Topics:
Housing, Tenant Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPetitioners requested authorization from the South Carolina Supreme Court for certified non-lawyer volunteers (Advocates) to provide free, limited assistance to tenants facing eviction. Specifically, Petitioners sought a declaratory judgment asserting that their proposed activities did not constitute the unauthorized practice of law. The Court approved the Housing Program on a provisional, pilot basis for a term of three years, unless extended or terminated by the Court. In reaching its decision, the Court conducted a thorough review of the program, including the Housing Eviction Training Program Manual, affidavits and declarations from lawyers participating in the program, and the educational prerequisites required for non-lawyer volunteers to achieve certification as Advocates. Additionally, the Court considered the Petitioners’ commitment to gathering and analyzing data to evaluate the program’s efficacy including tracking tenant outcomes through follow-ups, conducting comparative assessments, and sharing the findings with the Court. Based on these considerations, the Court concluded that the Housing Program provides sufficient training, safeguards, and lawyer oversight such that the Advocates certified under the Housing Program and working within the strict limits set forth in the Training Manual do not engage in the unauthorized practice of law.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Petitioners requested authorization from the South Carolina Supreme Court for certified non-lawyer volunteers (Advocates) to provide free, limited assistance to tenants facing eviction. Specifically, Petitioners sought a declaratory judgment asserting that their proposed activities did not constitute the unauthorized practice of law. The Court approved the Housing Program on a provisional, pilot basis for a term of three years, unless extended or terminated by the Court. In reaching its decision, the Court conducted a thorough review of the program, including the Housing Eviction Training Program Manual, affidavits and declarations from lawyers participating in the program, and the educational prerequisites required for non-lawyer volunteers to achieve certification as Advocates. Additionally, the Court considered the Petitioners’ commitment to gathering and analyzing data to evaluate the program’s efficacy including tracking tenant outcomes through follow-ups, conducting comparative assessments, and sharing the findings with the Court. Based on these considerations, the Court concluded that the Housing Program provides sufficient training, safeguards, and lawyer oversight such that the Advocates certified under the Housing Program and working within the strict limits set forth in the Training Manual do not engage in the unauthorized practice of law.
Link to Opinion
|
||||
|
In re Salazar, 518 P.3d 873 (Nev. 2022)
|
Nevada | 2022 | LGBTQ+ Rights, LGBTQ+ Discrimination |
State:
Nevada
Year:
2022
Topics:
LGBTQ+ Rights, LGBTQ+ Discrimination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff, a transgender inmate, filed a petition to legally change her name to conform to her gender identity. Under Nevada law, a name change petition must meet the requirements of Nev. Rev. Stat. Ann. § 41.270, whereby the petition must, among others, be addressed to the district court, include name and reason for change, and whether the petitioner was convicted of a felony. The district court indicated to Plaintiff that it would deny the petition based on an internal department policy requiring approval from the Nevada Department of Corrections for inmate name changes, without providing any legal basis for imposing this additional requirement. Plaintiff appealed. The Supreme Court held that, even though whether to approve or deny name change petitions is within the district court's discretion, the court must articulate "substantial and principled reasons" when it denies the petition. Accordingly, the Supreme Court found that the district court abused its discretion in dismissing Plaintiff's petition and reversed the decision.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Plaintiff, a transgender inmate, filed a petition to legally change her name to conform to her gender identity. Under Nevada law, a name change petition must meet the requirements of Nev. Rev. Stat. Ann. § 41.270, whereby the petition must, among others, be addressed to the district court, include name and reason for change, and whether the petitioner was convicted of a felony. The district court indicated to Plaintiff that it would deny the petition based on an internal department policy requiring approval from the Nevada Department of Corrections for inmate name changes, without providing any legal basis for imposing this additional requirement. Plaintiff appealed. The Supreme Court held that, even though whether to approve or deny name change petitions is within the district court's discretion, the court must articulate "substantial and principled reasons" when it denies the petition. Accordingly, the Supreme Court found that the district court abused its discretion in dismissing Plaintiff's petition and reversed the decision.
Link to Opinion
|
||||
|
In re Schmalz, 945 N.W.2d 46 (Minn. 2020)
|
Minnesota | 2020 | Health Care, Health Care Access/Funding |
State:
Minnesota
Year:
2020
Topics:
Health Care, Health Care Access/Funding
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAn applicant for medical-assistance benefits appealed a determination of the Commissioner of the Minnesota Department of Human Services that the applicant was ineligible for medical-assistance long-term care (MA-LTC) benefits on the ground that her husband's assets exceeded the statutory amount that he could retain (as a result of including the value of three non-homestead life estate interests in real property held by the applicant and her husband), and thus the excess was considered to be an available asset to applicant, causing applicant's available assets to exceed the amount of assets that she could retain and still be eligible for MA-LTC. The district court reversed the Commissioner's determination, holding that the Commissioner erred by considering the life estate interest attributable to the husband when determining applicant's eligibility and that the Commissioner's denial of applicant's application was arbitrary and capricious. The district court therefore concluded that the applicant was eligible for MA-LTC benefits. The court of appeals affirmed the district court's holding on the issue of statutory interpretation and thus did not reach the arbitrary-and-capricious issue. The Supreme Court reversed, holding that: (1) value of community spouse's non-homestead life estate assets was includable when totaling assets to determine the community spouse asset allowance; and (2) interpretation of statute governing exclusion of such assets as applying only to the applicant was not arbitrary and capricious.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
An applicant for medical-assistance benefits appealed a determination of the Commissioner of the Minnesota Department of Human Services that the applicant was ineligible for medical-assistance long-term care (MA-LTC) benefits on the ground that her husband's assets exceeded the statutory amount that he could retain (as a result of including the value of three non-homestead life estate interests in real property held by the applicant and her husband), and thus the excess was considered to be an available asset to applicant, causing applicant's available assets to exceed the amount of assets that she could retain and still be eligible for MA-LTC. The district court reversed the Commissioner's determination, holding that the Commissioner erred by considering the life estate interest attributable to the husband when determining applicant's eligibility and that the Commissioner's denial of applicant's application was arbitrary and capricious. The district court therefore concluded that the applicant was eligible for MA-LTC benefits. The court of appeals affirmed the district court's holding on the issue of statutory interpretation and thus did not reach the arbitrary-and-capricious issue. The Supreme Court reversed, holding that: (1) value of community spouse's non-homestead life estate assets was includable when totaling assets to determine the community spouse asset allowance; and (2) interpretation of statute governing exclusion of such assets as applying only to the applicant was not arbitrary and capricious.
Link to Opinion
|
||||
|
In re Senate Joint Resol. of Legis. Apportionment 100, 334 So. 3d 1282 (Fla. 2022)
|
Florida | 2022 | Democracy & Voting, Redistricting/Gerrymandering |
State:
Florida
Year:
2022
Topics:
Democracy & Voting, Redistricting/Gerrymandering
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Court reviewed and approved the Legislature’s reapportionment of House and Senate districts after the decennial census. No party opposed the Legislature’s plans, so the Court reviewed under a presumption of validity and reviewed the materials only to ensure that there was evidence to support the validity of the apportionment. The Court determined that (1) deviations in population for both the House and the Senate were “unquestionably [driven by] legitimate consideration[s]”; (2) districts were “at least as compact as the districts that they replace[d]”; (3) the Legislature followed political and geographical boundaries; and (4) the apportionment did not raise concerns of vote dilution on the basis of race, language, or politics.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
The Court reviewed and approved the Legislature’s reapportionment of House and Senate districts after the decennial census. No party opposed the Legislature’s plans, so the Court reviewed under a presumption of validity and reviewed the materials only to ensure that there was evidence to support the validity of the apportionment. The Court determined that (1) deviations in population for both the House and the Senate were “unquestionably [driven by] legitimate consideration[s]”; (2) districts were “at least as compact as the districts that they replace[d]”; (3) the Legislature followed political and geographical boundaries; and (4) the apportionment did not raise concerns of vote dilution on the basis of race, language, or politics.
Link to Opinion
|
||||
|
In re Sheila W., 835 N.W.2d 148 (Wis. 2013)
|
Wisconsin | 2013 | Health Care |
State:
Wisconsin
Year:
2013
Topics:
Health Care
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingSheila W., a Jehovah's Witness, was diagnosed with anemia. Her doctors recommended she receive blood transfusions, which Jehovah's Witnesses shun. The circuit court appointed a guardian for Sheila who decided—against the wishes of Sheila—that she should receive the transfusions. Sheila appealed the circuit court's decision, but the order had expired while the case was pending. The court of appeals then dismissed the appeal as moot. Sheila appealed to the Supreme Court arguing that Wisconsin should recognize the mature minor doctrine, which allows a minor to give or refuse consent to medical treatment after a finding they are sufficiently mature and competent to make a treatment decision, and that it should be an exception to the general rule requiring parents to give consent to medical treatments. The Supreme Court did not address the merits of the case because, had it rendered a decision, it would not have any practical legal effect on the controversy: the order that Sheila was appealing had expired. The Supreme Court thus left in place the court of appeals' decision.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Sheila W., a Jehovah's Witness, was diagnosed with anemia. Her doctors recommended she receive blood transfusions, which Jehovah's Witnesses shun. The circuit court appointed a guardian for Sheila who decided—against the wishes of Sheila—that she should receive the transfusions. Sheila appealed the circuit court's decision, but the order had expired while the case was pending. The court of appeals then dismissed the appeal as moot. Sheila appealed to the Supreme Court arguing that Wisconsin should recognize the mature minor doctrine, which allows a minor to give or refuse consent to medical treatment after a finding they are sufficiently mature and competent to make a treatment decision, and that it should be an exception to the general rule requiring parents to give consent to medical treatments. The Supreme Court did not address the merits of the case because, had it rendered a decision, it would not have any practical legal effect on the controversy: the order that Sheila was appealing had expired. The Supreme Court thus left in place the court of appeals' decision.
Link to Opinion
|
||||
|
In re Sierra Club v. Village of Painted Post, 43 N.E.3d 745 (N.Y. 2015)
|
New York | 2015 | Environment, Pollution/Contamination, Actions Against Government |
State:
New York
Year:
2015
Topics:
Environment, Pollution/Contamination, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Village of Painted Post (Village) is located at the confluence of three different rivers, and underlying this confluence is the Corning aquifer, which is the principal drinking water supply of several New York State municipalities. The Village adopted a resolution to enter into a surplus water sale agreement with respondent SWEPI LP, a subsidiary of Shell Oil Company, which operates gas wells in Pennsylvania. The Village determined that under New York law, its water sales were exempt from review under the State Environmental Quality Review Act (SEQRA). Petitioners, which included environmental groups as well as individual residents of the Village, brought an action against the Village challenging this water sale agreement. The Petitioners argued the Village failed to comply with the procedural mandates of SEQRA on grounds that it failed to consider significant adverse environmental impacts of the water withdrawals, including noise and air contamination associated with the proposed rail loading facility site. The Court of Appeals ruled, contrary to the decision of the lower court, that petitioner John Marvin had standing. Specifically, the Court of Appeals found that the lower court's standing analysis—which reasoned that because other Village residents lived along the train line, the Petitioner did not suffer noise impacts that were different from his neighbors even though train noise fell under the purview of the SEQRA—applied an overly restrictive analysis of the requirement to show harm different from that of the public at large.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
The Village of Painted Post (Village) is located at the confluence of three different rivers, and underlying this confluence is the Corning aquifer, which is the principal drinking water supply of several New York State municipalities. The Village adopted a resolution to enter into a surplus water sale agreement with respondent SWEPI LP, a subsidiary of Shell Oil Company, which operates gas wells in Pennsylvania. The Village determined that under New York law, its water sales were exempt from review under the State Environmental Quality Review Act (SEQRA). Petitioners, which included environmental groups as well as individual residents of the Village, brought an action against the Village challenging this water sale agreement. The Petitioners argued the Village failed to comply with the procedural mandates of SEQRA on grounds that it failed to consider significant adverse environmental impacts of the water withdrawals, including noise and air contamination associated with the proposed rail loading facility site. The Court of Appeals ruled, contrary to the decision of the lower court, that petitioner John Marvin had standing. Specifically, the Court of Appeals found that the lower court's standing analysis—which reasoned that because other Village residents lived along the train line, the Petitioner did not suffer noise impacts that were different from his neighbors even though train noise fell under the purview of the SEQRA—applied an overly restrictive analysis of the requirement to show harm different from that of the public at large.
Link to Opinion
|
||||
|
In re Standard Jury Instructions in Civ. Cases, 214 So.3d 552 (Fla. 2017)
|
Florida | 2017 | Civil Rights |
State:
Florida
Year:
2017
Topics:
Civil Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court authorized various changes to a number of standard jury instructions following a proposal by the Supreme Court Committee on Standard Jury Instructions in Civil Cases under Section 417, Unlawful Discrimination, based on the Florida Civil Rights Act (FCRA) and several other discrimination-related statutes. The FCRA makes it unlawful for an employer to discriminate based upon race, color, religion, sex, pregnancy, national origin, age, handicap, or marital status. The Committe submitting the jury instructions proposed the instructions using the FCRA and other statutes as a basis for the changes. The instructions were in a format and style consistent to that approved by the Court in 2010 when the Court authorized for publication and use the reorganization of civil jury instructions, and the Supreme Court authorized the proposals. The new instructions included, among other things, instructions on disparate treatment, legal cause, damage, and burden of proof.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
The Supreme Court authorized various changes to a number of standard jury instructions following a proposal by the Supreme Court Committee on Standard Jury Instructions in Civil Cases under Section 417, Unlawful Discrimination, based on the Florida Civil Rights Act (FCRA) and several other discrimination-related statutes. The FCRA makes it unlawful for an employer to discriminate based upon race, color, religion, sex, pregnancy, national origin, age, handicap, or marital status. The Committe submitting the jury instructions proposed the instructions using the FCRA and other statutes as a basis for the changes. The instructions were in a format and style consistent to that approved by the Court in 2010 when the Court authorized for publication and use the reorganization of civil jury instructions, and the Supreme Court authorized the proposals. The new instructions included, among other things, instructions on disparate treatment, legal cause, damage, and burden of proof.
Link to Opinion
|
||||
|
In re State, 602 S.W.3d 549 (Tex. 2020)
|
Texas | 2020 | Democracy and Voting, Voting Rights |
State:
Texas
Year:
2020
Topics:
Democracy and Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn March 2020, the Texas Democratic Party filed suit arguing that under Section 82.002 lack of immunity to COVID-19 qualifies as a "disability," one of the five conditions that make a Texas voter eligible for a mail-in ballot. The Supreme Court held that a prospective voter's lack of immunity to COVID-19, without more, is not a “disability” within the meaning of the Election Code, as would provide basis for obtaining mail-in ballot. The majority reasoned that under section 82.002, for something to be a “disability,” it must satisfy two necessary statutory criteria: (1) it must be a “sickness or physical condition,” and (2) it must “prevent[] the voter from appearing at the polling place on election day without a likelihood of needing personal assistance or of injuring the voter’s health.” The majority held that a lack of immunity from COVID-19 is not a “disability” for purposes of Section 82.002 since it did not meet either prong. The majority relied upon the Texas legislature’s historical and textual intent through an analysis of section 82.002’s meaning as expressed by the definitions of its terms and the statute’s relationship to the history of Texas’s absentee voting legislative scheme.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
In March 2020, the Texas Democratic Party filed suit arguing that under Section 82.002 lack of immunity to COVID-19 qualifies as a "disability," one of the five conditions that make a Texas voter eligible for a mail-in ballot. The Supreme Court held that a prospective voter's lack of immunity to COVID-19, without more, is not a “disability” within the meaning of the Election Code, as would provide basis for obtaining mail-in ballot. The majority reasoned that under section 82.002, for something to be a “disability,” it must satisfy two necessary statutory criteria: (1) it must be a “sickness or physical condition,” and (2) it must “prevent[] the voter from appearing at the polling place on election day without a likelihood of needing personal assistance or of injuring the voter’s health.” The majority held that a lack of immunity from COVID-19 is not a “disability” for purposes of Section 82.002 since it did not meet either prong. The majority relied upon the Texas legislature’s historical and textual intent through an analysis of section 82.002’s meaning as expressed by the definitions of its terms and the statute’s relationship to the history of Texas’s absentee voting legislative scheme.
Link to Opinion
|
||||
|
In re State, 682 S.W.3d 890 (Tex. 2023)
|
Texas | 2023 | Health Care, Reproductive Rights/Abortion, Public Health |
State:
Texas
Year:
2023
Topics:
Health Care, Reproductive Rights/Abortion, Public Health
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA woman was pregnant with her third child when she learned that it was diagnosed with Trisomy 18, or Edwards Syndrome. Fewer than half of all babies born with Trisomy 18 live longer than one week. The woman, along with her husband and her doctor, sued to prevent the enforcement of Texas laws prohibiting abortion. Included in the general prohibition against abortion is an exception that permits abortion if a doctor, “in the exercise of reasonable medical judgment” determines that the pregnant woman has a life-threatening condition “aggravated by, caused by or arising from [the] pregnancy” that makes it likely that carrying the pregnancy to term would result in the woman’s death or substantial impairment of a major bodily function. Here, the pleadings stated that the woman’s doctor believed that the woman qualified for the medical exception, but the doctor did not assert any “life-threatening physical condition” or that the abortion was necessary. Nonetheless, the trial court determined that the abortion would fall into the medical exception, and issued a restraining order preventing the Attorney General from enforcing the abortion prohibition against the doctor and other individuals related to the case. The State appealed. In its review, the Supreme Court noted that the woman’s doctor only asserted a “good faith belief” that the woman met the requirements of the exception, and did not assert the “reasonable medical judgment” standard required under the prohibition. Although the Court emphasized that the woman “[did] not need a court order to have a life-saving abortion in Texas,” it held that because the doctor had not specifically plead that the woman had a “life-threatening physical condition” placing her “at risk of death,” the temporary restraining order granted by the trial court was improper.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
A woman was pregnant with her third child when she learned that it was diagnosed with Trisomy 18, or Edwards Syndrome. Fewer than half of all babies born with Trisomy 18 live longer than one week. The woman, along with her husband and her doctor, sued to prevent the enforcement of Texas laws prohibiting abortion. Included in the general prohibition against abortion is an exception that permits abortion if a doctor, “in the exercise of reasonable medical judgment” determines that the pregnant woman has a life-threatening condition “aggravated by, caused by or arising from [the] pregnancy” that makes it likely that carrying the pregnancy to term would result in the woman’s death or substantial impairment of a major bodily function. Here, the pleadings stated that the woman’s doctor believed that the woman qualified for the medical exception, but the doctor did not assert any “life-threatening physical condition” or that the abortion was necessary. Nonetheless, the trial court determined that the abortion would fall into the medical exception, and issued a restraining order preventing the Attorney General from enforcing the abortion prohibition against the doctor and other individuals related to the case. The State appealed. In its review, the Supreme Court noted that the woman’s doctor only asserted a “good faith belief” that the woman met the requirements of the exception, and did not assert the “reasonable medical judgment” standard required under the prohibition. Although the Court emphasized that the woman “[did] not need a court order to have a life-saving abortion in Texas,” it held that because the doctor had not specifically plead that the woman had a “life-threatening physical condition” placing her “at risk of death,” the temporary restraining order granted by the trial court was improper.
Link to Opinion
|
||||
|
In re Steven Daniel P., 309 P.3d 1041 (Nev. 2013)
|
Nevada | 2013 | Criminal Justice, Juvenile Justice |
State:
Nevada
Year:
2013
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe State filed a delinquency petition alleging that juvenile Steven P. burglarized and conspired to burglarize. Steven P. negotiated a deal with the State to admit to the conspiracy in exchange for dismissal of the burglary allegation, which the juvenile court accepted. However, the juvenile court delayed entering a final disposition given its concern that the State's recommendation of formal probation was inappropriate. Ultimately, the juvenile court dismissed the conspiracy allegation without consent of the state. On appeal, the State argued that the juvenile court erred in dismissing its delinquency petition and referring Steven P. to informal supervision, not formal probation. The Court agreed with the State and held that under Nev. Rev. Stat. § 62C.230(1)(a), the juvenile court lacked authority to dismiss the delinquency petition or refer the juvenile for informal supervision without the State's written consent. Moreover, because the authority of the juvenile court is limited by statute, the juvenile court did not possess broad judicial discretion to act outside the bounds of its statutory powers.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
The State filed a delinquency petition alleging that juvenile Steven P. burglarized and conspired to burglarize. Steven P. negotiated a deal with the State to admit to the conspiracy in exchange for dismissal of the burglary allegation, which the juvenile court accepted. However, the juvenile court delayed entering a final disposition given its concern that the State's recommendation of formal probation was inappropriate. Ultimately, the juvenile court dismissed the conspiracy allegation without consent of the state. On appeal, the State argued that the juvenile court erred in dismissing its delinquency petition and referring Steven P. to informal supervision, not formal probation. The Court agreed with the State and held that under Nev. Rev. Stat. § 62C.230(1)(a), the juvenile court lacked authority to dismiss the delinquency petition or refer the juvenile for informal supervision without the State's written consent. Moreover, because the authority of the juvenile court is limited by statute, the juvenile court did not possess broad judicial discretion to act outside the bounds of its statutory powers.
Link to Opinion
|
||||
|
In re T.B., 874 S.E.2d 101 (Ga. 2022)
|
Georgia | 2022 | Criminal Justice, Juvenile Justice |
State:
Georgia
Year:
2022
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe State filed a delinquency petition alleging that T.B. was a delinquent child, after having evaded the police and resisting arrest when the officers found him locked up in a hotel storage closet. Following a detention hearing, the juvenile court ordered that T.B. receive a psychological evaluation. T.B. was diagnosed with Schizophreniform Disorder, among other things. Prior to adjudication, T.B. filed a notice of intent to offer a defense of insanity or delusional compulsion and moved the juvenile court to rule on whether he was incapable of appreciating the wrongfulness of his acts. The Juvenile Code does not expressly recognize an insanity defense, and according to the Juvenile court, children do not have a constitutional right to raise an insanity defense in delinquency proceedings. Thus, the juvenile court denied T.B.'s request for the insanity defense and his request for a forensic evaluation. On appeal, the Supreme Court decided whether a child charged with delinquency based on an alleged violation of Georgia's Criminal Code may assert an affirmative defense of insanity or delusional compulsion in a juvenile-court proceeding. Interpreting the language of the relevant statute, the Supreme Court held that a child whose action is executed by insanity or some form of delusional compulsion has not committed "[a]n act . . . designated a crime," and therefore has not committed a "delinquent act." Applying that holding to the instant case, the rule in Georgia is now as follows: if a child is defending against a charge of having committed a "delinquent act" based on an alleged violation of Georgia's Criminal Code, then they shall be permitted to raise a defense of insanity or delusional compulsion. Since the juvenile court refused to grant the motion seeking a psychological evaluation to determine if T.B. was insane or suffering from a delusional compulsion, the Supreme Court vacated the juvenile court's order.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
The State filed a delinquency petition alleging that T.B. was a delinquent child, after having evaded the police and resisting arrest when the officers found him locked up in a hotel storage closet. Following a detention hearing, the juvenile court ordered that T.B. receive a psychological evaluation. T.B. was diagnosed with Schizophreniform Disorder, among other things. Prior to adjudication, T.B. filed a notice of intent to offer a defense of insanity or delusional compulsion and moved the juvenile court to rule on whether he was incapable of appreciating the wrongfulness of his acts. The Juvenile Code does not expressly recognize an insanity defense, and according to the Juvenile court, children do not have a constitutional right to raise an insanity defense in delinquency proceedings. Thus, the juvenile court denied T.B.'s request for the insanity defense and his request for a forensic evaluation. On appeal, the Supreme Court decided whether a child charged with delinquency based on an alleged violation of Georgia's Criminal Code may assert an affirmative defense of insanity or delusional compulsion in a juvenile-court proceeding. Interpreting the language of the relevant statute, the Supreme Court held that a child whose action is executed by insanity or some form of delusional compulsion has not committed "[a]n act . . . designated a crime," and therefore has not committed a "delinquent act." Applying that holding to the instant case, the rule in Georgia is now as follows: if a child is defending against a charge of having committed a "delinquent act" based on an alleged violation of Georgia's Criminal Code, then they shall be permitted to raise a defense of insanity or delusional compulsion. Since the juvenile court refused to grant the motion seeking a psychological evaluation to determine if T.B. was insane or suffering from a delusional compulsion, the Supreme Court vacated the juvenile court's order.
Link to Opinion
|
||||
|
In re Teton Coop. Reservoir Co., 414 P.3d 1249 (Mont. 2018)
|
Montana | 2018 | Environment, Water Rights |
State:
Montana
Year:
2018
Topics:
Environment, Water Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIrrigation company (Teton Reservoir) appealed an order from the Montana water court adjudicating its water rights. The Supreme Court affirmed that Teton Reservoir was barred by laches from asserting its senior priority date over Teton Canal. Teton Reservoir argued it was entitled to presume that the water commissioners were properly distributing water according to priority. A party asserting laches must provide evidence, more than conclusory statements, to prove prejudice. The water court found, and the Supreme Court agreed, that there was a lack of diligence because it could be demonstrated that Teton Reservoir was aware of the development of the reservoir and that it would provide additional water storage not previously available to Teton Canal. For nearly 70 years, Teton Reservoir did not file an objection. The water court correctly concluded that Teton Reservoir's delay in bringing a claim for a senior priority right against Teton Canal constituted an unexplainable delay and was of such character as to render enforcement of its newly asserted right inequitable. Further, allowing Teton Reservoir to have priority would deplete the water in the river and compromise Teton Canal's shareholders ability to store water it relied upon for the past 70 years, and businesses of shareholders would be significantly impacted, showing prejudice.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Irrigation company (Teton Reservoir) appealed an order from the Montana water court adjudicating its water rights. The Supreme Court affirmed that Teton Reservoir was barred by laches from asserting its senior priority date over Teton Canal. Teton Reservoir argued it was entitled to presume that the water commissioners were properly distributing water according to priority. A party asserting laches must provide evidence, more than conclusory statements, to prove prejudice. The water court found, and the Supreme Court agreed, that there was a lack of diligence because it could be demonstrated that Teton Reservoir was aware of the development of the reservoir and that it would provide additional water storage not previously available to Teton Canal. For nearly 70 years, Teton Reservoir did not file an objection. The water court correctly concluded that Teton Reservoir's delay in bringing a claim for a senior priority right against Teton Canal constituted an unexplainable delay and was of such character as to render enforcement of its newly asserted right inequitable. Further, allowing Teton Reservoir to have priority would deplete the water in the river and compromise Teton Canal's shareholders ability to store water it relied upon for the past 70 years, and businesses of shareholders would be significantly impacted, showing prejudice.
Link to Opinion
|
||||
|
In re Vega, 149 N.E.3d 401 (N.Y. 2020)
|
New York | 2020 | Labor, Employment & Economic Justice |
State:
New York
Year:
2020
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingBased on negative reviews from customers alleging fraudulent activity, Postmates (an on-demand delivery business that solicits employees and couriers using a website and smartphone application) blocked claimant from using the application. Thereafter, claimant filed for unemployment benefits. The Department of Labor (DOL), based in part on a statement of the claimant, initially determined that claimant was an employee of Postmates, requiring that Postmates pay unemployment insurance contributions on the claimant's earnings, as well as on the earnings of "all other persons similarly employed." Postmates disputed the determination and a hearing was held before an administrative law judge (ALJ) who sustained Postmates' objection, concluding that claimant was an independent contractor and reasoning that Postmates did not exercise sufficient supervision, direction and control over claimant to establish an employer-employee relationship. The Commissioner appealed the ALJ's decision to the Unemployment Insurance Appeals Board (the Board), which reversed the ALJ, overruled Postmates' objection and sustained the DOL's initial determination. Postmates appealed to the Appellate Division—who reversed the Board's ruling. The Commissioner then appealed to the Court of Appeals. The Court of Appeals held that substantial evidence supported the Board’s determination that couriers hired by Postmates Inc. are employees for whom Postmates is required to make unemployment insurance fund contributions, as opposed to independent contractors. Noting that the touchstone of the analysis is whether the employer exercised control over the results produced by the worker or the means used to achieve those results—and recognizing that the relevant indicia of control vary depending on the nature of the work—the Court concluded the Board’s finding was supported by record evidence that Postmates dominated significant aspects of its couriers’ work by dictating to whom they can deliver, where to deliver requested items, effectively limiting the time frame for delivery and controlling all aspects of pricing and payment. The fact that the couriers could choose their work schedules (by logging into the application) and specific delivery routes did not dictate a finding that they were independent contractors operating their own businesses.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Based on negative reviews from customers alleging fraudulent activity, Postmates (an on-demand delivery business that solicits employees and couriers using a website and smartphone application) blocked claimant from using the application. Thereafter, claimant filed for unemployment benefits. The Department of Labor (DOL), based in part on a statement of the claimant, initially determined that claimant was an employee of Postmates, requiring that Postmates pay unemployment insurance contributions on the claimant's earnings, as well as on the earnings of "all other persons similarly employed." Postmates disputed the determination and a hearing was held before an administrative law judge (ALJ) who sustained Postmates' objection, concluding that claimant was an independent contractor and reasoning that Postmates did not exercise sufficient supervision, direction and control over claimant to establish an employer-employee relationship. The Commissioner appealed the ALJ's decision to the Unemployment Insurance Appeals Board (the Board), which reversed the ALJ, overruled Postmates' objection and sustained the DOL's initial determination. Postmates appealed to the Appellate Division—who reversed the Board's ruling. The Commissioner then appealed to the Court of Appeals. The Court of Appeals held that substantial evidence supported the Board’s determination that couriers hired by Postmates Inc. are employees for whom Postmates is required to make unemployment insurance fund contributions, as opposed to independent contractors. Noting that the touchstone of the analysis is whether the employer exercised control over the results produced by the worker or the means used to achieve those results—and recognizing that the relevant indicia of control vary depending on the nature of the work—the Court concluded the Board’s finding was supported by record evidence that Postmates dominated significant aspects of its couriers’ work by dictating to whom they can deliver, where to deliver requested items, effectively limiting the time frame for delivery and controlling all aspects of pricing and payment. The fact that the couriers could choose their work schedules (by logging into the application) and specific delivery routes did not dictate a finding that they were independent contractors operating their own businesses.
Link to Opinion
|
||||
|
In re Wallach v. Town of Dryden, 16 N.E.3d 1188 (N.Y. 2014)
|
New York | 2014 | Environment, Pollution/Contamination, Actions Against Government |
State:
New York
Year:
2014
Topics:
Environment, Pollution/Contamination, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingRespondent Town of Dryden is a rural community in Tompkins County, in which land use is governed by a comprehensive plan and zoning ordinance. Petitioner Norse Energy Corp. (Norse) through its predecessors started acquiring oil and gas leases from landowners in Dryden to explore and develop natural gas resources. The Town Board took the view that gas extraction activities were prohibited in Dryden because the operations fell within the catch-all provision of its zoning ordinance, which precludes any uses not specifically allowed. The Town Board unanimously voted to amend its zoning ordinance to specify that all oil and gas exploration, extraction and storage activities were not permitted in Dryden. The amendment also purported to invalidate any oil and gas permits issued by a state or federal agency. Norse challenged the validity of the zoning amendment, asserting that Dryden lacked the authority to prohibit natural gas exploration and activities because the state Environmental Conservation Law demonstrated the state legislature intended to preempt local zoning laws that curtailed energy production. The Court of Appeals held that the state legislature did not eliminate the home rule capacity of municipalities—an authority derived from article IX of the New York State constitution and Municipal Home Rule Law, which empowers local governments to pass laws for both the "protection and enhancement of [their] physical and visual environments" and for the "government, protection, order, conduct, safety, morals, or the general welfare of the community"—to pass zoning laws that exclude oil, gas, and hydrofracking activities to preserve the character of their communities. Thus, the Court of Appeals ruled the municipal zoning laws were valid.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Respondent Town of Dryden is a rural community in Tompkins County, in which land use is governed by a comprehensive plan and zoning ordinance. Petitioner Norse Energy Corp. (Norse) through its predecessors started acquiring oil and gas leases from landowners in Dryden to explore and develop natural gas resources. The Town Board took the view that gas extraction activities were prohibited in Dryden because the operations fell within the catch-all provision of its zoning ordinance, which precludes any uses not specifically allowed. The Town Board unanimously voted to amend its zoning ordinance to specify that all oil and gas exploration, extraction and storage activities were not permitted in Dryden. The amendment also purported to invalidate any oil and gas permits issued by a state or federal agency. Norse challenged the validity of the zoning amendment, asserting that Dryden lacked the authority to prohibit natural gas exploration and activities because the state Environmental Conservation Law demonstrated the state legislature intended to preempt local zoning laws that curtailed energy production. The Court of Appeals held that the state legislature did not eliminate the home rule capacity of municipalities—an authority derived from article IX of the New York State constitution and Municipal Home Rule Law, which empowers local governments to pass laws for both the "protection and enhancement of [their] physical and visual environments" and for the "government, protection, order, conduct, safety, morals, or the general welfare of the community"—to pass zoning laws that exclude oil, gas, and hydrofracking activities to preserve the character of their communities. Thus, the Court of Appeals ruled the municipal zoning laws were valid.
Link to Opinion
|
||||
|
In re Welfare of J.H., 844 N.W.2d 28 (Minn. 2014)
|
Minnesota | 2014 | Criminal Justice, Juvenile Justice |
State:
Minnesota
Year:
2014
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingRespondent, a 17-year-old juvenile, was charged as both principal and accomplice, in connection with various crimes arising from the rape of a 14-year-old victim. The district court certified Respondent to adult court. The court of appeals reversed because the lower court had not explicitly weighed the seriousness of the alleged offense and Respondent's prior record of delinquency separately from the other public safety factors relevant to certification under Minn. Stat § 260B.125, subdivision 4. The six public safety factors are (i) the seriousness of the offense; (ii) the culpability of the child in committing the offense; (iii) the child's prior record of delinquency; (iv) the child's programming history; (v) the adequacy of the punishment/programming available in the juvenile system; and (vi) the dispositional options available. The Supreme Court found that factor (i) was implicated because the rape was violent involving multiple offenders; factor (ii) was implicated because Respondent planned to get the victim drunk before raping her; and the district court had properly analyzed the remaining factors and determined that they were not implicated. The Court held that the text of Section 260B.125, subdivision 4 does not require the court to expressly weigh factors (i) and (iii) separately from the other public safety factors, or specifically delineate how those two factors impacted its certification determination, but rather it must give greater weight to those two factors than the other factors identified in the statute. Because the district court did expressly weigh all factors, and afforded greater weight to those two factors in its analysis, the Supreme Court affirmed.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Respondent, a 17-year-old juvenile, was charged as both principal and accomplice, in connection with various crimes arising from the rape of a 14-year-old victim. The district court certified Respondent to adult court. The court of appeals reversed because the lower court had not explicitly weighed the seriousness of the alleged offense and Respondent's prior record of delinquency separately from the other public safety factors relevant to certification under Minn. Stat § 260B.125, subdivision 4. The six public safety factors are (i) the seriousness of the offense; (ii) the culpability of the child in committing the offense; (iii) the child's prior record of delinquency; (iv) the child's programming history; (v) the adequacy of the punishment/programming available in the juvenile system; and (vi) the dispositional options available. The Supreme Court found that factor (i) was implicated because the rape was violent involving multiple offenders; factor (ii) was implicated because Respondent planned to get the victim drunk before raping her; and the district court had properly analyzed the remaining factors and determined that they were not implicated. The Court held that the text of Section 260B.125, subdivision 4 does not require the court to expressly weigh factors (i) and (iii) separately from the other public safety factors, or specifically delineate how those two factors impacted its certification determination, but rather it must give greater weight to those two factors than the other factors identified in the statute. Because the district court did expressly weigh all factors, and afforded greater weight to those two factors in its analysis, the Supreme Court affirmed.
Link to Opinion
|
||||
|
In re Welfare of J.J.P., 831 N.W.2d 260 (Minn. 2013)
|
Minnesota | 2013 | Criminal Justice, Juvenile Justice |
State:
Minnesota
Year:
2013
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingRespondent was found delinquent of felony burglary and misdemeanor theft as a juvenile, and subsequently obtained a district court order expunging his juvenile delinquency records held by the judicial branch. Respondent also petitioned the district court to expunge his juvenile delinquency records held by the executive branch. The district court denied the request because while Minn. Stat. § 260B.198, subdivision 6 authorizes expunging of executive branch records, the case at hand did not demonstrate a case for expungement because Respondent would not suffer undue hardship because he could seek a "set aside," and Respondent failed to show that the benefits of expungement do not outweigh the potential detriment to society. The court of appeals reversed, concluding the district court abused its discretion in denying the petition, on the grounds that the district court applied the wrong guidelines for imposition of expungement in a delinquency case (those from chapter 609A), whereas the correct guidelines are set forth in Minn. R. Jun. Delinq. P. 15.05. The Supreme Court held that under Minn. Stat. Section 260B.198, subdivision 6, the district court has the authority to expunge juvenile delinquency records in executive branch files, but this authority is limited to the order adjudicating the juvenile delinquent. Further, the district court must weigh the benefit to the petitioner against the detriment to the public and the burden on the court in order to determine whether expungement is advisable within the meaning of section 260B.198, subdivision 6. Because the district court denied Respondent's expungement petition using the chapter 609A guidelines, the case was remanded to the district court for reconsideration of whether the facts of the case warrant expungement under the benefit/burden test.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Respondent was found delinquent of felony burglary and misdemeanor theft as a juvenile, and subsequently obtained a district court order expunging his juvenile delinquency records held by the judicial branch. Respondent also petitioned the district court to expunge his juvenile delinquency records held by the executive branch. The district court denied the request because while Minn. Stat. § 260B.198, subdivision 6 authorizes expunging of executive branch records, the case at hand did not demonstrate a case for expungement because Respondent would not suffer undue hardship because he could seek a "set aside," and Respondent failed to show that the benefits of expungement do not outweigh the potential detriment to society. The court of appeals reversed, concluding the district court abused its discretion in denying the petition, on the grounds that the district court applied the wrong guidelines for imposition of expungement in a delinquency case (those from chapter 609A), whereas the correct guidelines are set forth in Minn. R. Jun. Delinq. P. 15.05. The Supreme Court held that under Minn. Stat. Section 260B.198, subdivision 6, the district court has the authority to expunge juvenile delinquency records in executive branch files, but this authority is limited to the order adjudicating the juvenile delinquent. Further, the district court must weigh the benefit to the petitioner against the detriment to the public and the burden on the court in order to determine whether expungement is advisable within the meaning of section 260B.198, subdivision 6. Because the district court denied Respondent's expungement petition using the chapter 609A guidelines, the case was remanded to the district court for reconsideration of whether the facts of the case warrant expungement under the benefit/burden test.
Link to Opinion
|
||||
|
J.S. by M.S. v. Manheim Twp. Sch. Dist., 263 A.3d 295 (Pa. 2021)
|
Pennsylvania | 2021 | Criminal Justice, Juvenile Justice, Education |
State:
Pennsylvania
Year:
2021
Topics:
Criminal Justice, Juvenile Justice, Education
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA high school student was expelled for "terroristic threats and cyberbullying" because of two Snapchat memes he made depicting another student as a school shooter. The lower courts reversed the expulsion, and the school district appealed to the Supreme Court. The Supreme Court held that the posts were not true threats and did not constitute a substantial disruption to the school environment and affirmed the reversal of the student's expulsion.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
A high school student was expelled for "terroristic threats and cyberbullying" because of two Snapchat memes he made depicting another student as a school shooter. The lower courts reversed the expulsion, and the school district appealed to the Supreme Court. The Supreme Court held that the posts were not true threats and did not constitute a substantial disruption to the school environment and affirmed the reversal of the student's expulsion.
Link to Opinion
|
||||
|
Jackson v. Costco Wholesale Corp., 429 P.3d 641 (Mont. 2018)
|
Montana | 2018 | Labor, Employment & Economic Justice, Disability Rights |
State:
Montana
Year:
2018
Topics:
Labor, Employment & Economic Justice, Disability Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingUnder the Montana Human Rights Act (MHRA), modelled after the federal American with Disabilities Act (ADA), an employer must know about a disability before it can intentionally discriminate against an employee based on that disability. Mont. Code Ann. § 49-2-303; Americans with Disabilities Act of 1989, Pub. L. No. 101-336, 104 Stat. 327 (1990). An employer is not obligated to accommodate a disability if the first time they learn about it is during termination proceedings arising from legitimate reasons. Here, the lower court found that the employee had failed to inform the employer of his disabilities prior to the termination meeting, which had been set up for unrelated, job-related reasons such as the employee's insubordinate conduct. The Supreme Court affirmed the lower court's finding that the employer presented legitimate nondiscriminatory reasons for terminating the employee's employment due to insubordination, even if the employee later revealed during his termination meeting that the insubordination was caused by discontinuing his medication for a disability.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Under the Montana Human Rights Act (MHRA), modelled after the federal American with Disabilities Act (ADA), an employer must know about a disability before it can intentionally discriminate against an employee based on that disability. Mont. Code Ann. § 49-2-303; Americans with Disabilities Act of 1989, Pub. L. No. 101-336, 104 Stat. 327 (1990). An employer is not obligated to accommodate a disability if the first time they learn about it is during termination proceedings arising from legitimate reasons. Here, the lower court found that the employee had failed to inform the employer of his disabilities prior to the termination meeting, which had been set up for unrelated, job-related reasons such as the employee's insubordinate conduct. The Supreme Court affirmed the lower court's finding that the employer presented legitimate nondiscriminatory reasons for terminating the employee's employment due to insubordination, even if the employee later revealed during his termination meeting that the insubordination was caused by discontinuing his medication for a disability.
Link to Opinion
|
||||
|
Jackson v. DeSantis, 268 So. 3d 662 (Fla. 2019)
|
Florida | 2019 | Labor, Employment & Economic Justice |
State:
Florida
Year:
2019
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff, the Superintendent of Schools for Okaloosa County, was suspended by Governor Ron DeSantis for alleged misconduct constituting neglect of duty and incompetence. Plaintiff challenged the suspension on the grounds that the alleged misconduct had occurred during her previous term and, therefore, she could not be suspended from her current term under Florida state precedent. The Florida Supreme Court ruled against Plaintiff, holding that some of the misconduct which formed the basis for the suspension had occurred during her current term, therefore, DeSantis did not exceed his suspension power under the Florida Constitution.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Plaintiff, the Superintendent of Schools for Okaloosa County, was suspended by Governor Ron DeSantis for alleged misconduct constituting neglect of duty and incompetence. Plaintiff challenged the suspension on the grounds that the alleged misconduct had occurred during her previous term and, therefore, she could not be suspended from her current term under Florida state precedent. The Florida Supreme Court ruled against Plaintiff, holding that some of the misconduct which formed the basis for the suspension had occurred during her current term, therefore, DeSantis did not exceed his suspension power under the Florida Constitution.
Link to Opinion
|
||||
|
Jackson v. Groenendyke, 369 P.3d 362 (Nev. 2016)
|
Nevada | 2016 | Environment, Water Rights |
State:
Nevada
Year:
2016
Topics:
Environment, Water Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingProperty owners filed exceptions pursuant to NRS 533.170 to the State Engineer’s final order of determination of spring water rights under NRS 533.160. Downstream owner filed a supplement, which included a request for access to upstream owners’ property for purposes of repair and maintenance of waterway facilities. The Ninth Judicial District Court, Douglas County, concluded both of the upstream owners, the downstream owner, and the eastern properties had vested rights in water, and granted the downstream owner’s request. The upstream owners appealed. The Supreme Court affirmed holding that the district court could hear the land access claims because they arose out of the same transaction or occurrence as the vested water rights and that the district court’s water rights determination was supported by substantial evidence.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Property owners filed exceptions pursuant to NRS 533.170 to the State Engineer’s final order of determination of spring water rights under NRS 533.160. Downstream owner filed a supplement, which included a request for access to upstream owners’ property for purposes of repair and maintenance of waterway facilities. The Ninth Judicial District Court, Douglas County, concluded both of the upstream owners, the downstream owner, and the eastern properties had vested rights in water, and granted the downstream owner’s request. The upstream owners appealed. The Supreme Court affirmed holding that the district court could hear the land access claims because they arose out of the same transaction or occurrence as the vested water rights and that the district court’s water rights determination was supported by substantial evidence.
Link to Opinion
|
||||
|
Jackson v. State, 883 N.W.2d 272 (Minn. 2016)
|
Minnesota | 2016 | Criminal Justice, Access to Justice, Juvenile Justice |
State:
Minnesota
Year:
2016
Topics:
Criminal Justice, Access to Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was convicted in district court of first-degree murder in connection with the shooting death of a 15-year old victim when the Appellant was 17 years old in connection with a gang altercation. Appellant filed for post-conviction relief, which was denied. Appellant appealed to the Supreme Court of Minnesota claiming (among other things) that his mandatory sentence of life imprisonment without the possibility of release (LWOR) should be reversed based on the U.S. Supreme Court's decision in Miller v. Alabama, 567 U.S. 460 (2012), which held that mandatory imposition of LWOR sentences are unconstitutional as applied to juveniles under the Eighth Amendment to the U.S. Constitution. The Supreme Court of Minnesota agreed, and vacated the Appellant's LWOR sentence because the mandatory statutory scheme under which the sentence was imposed was unconstitutional. In particular, U.S. Supreme Court precedent makes clear the decision has retroactive effect, and it is undisputed that the district court imposed a mandatory sentence of LWOR and did not consider Appellant's youth-related factors, whether Appellant fell within the vast majority of juvenile offenders whose crimes reflect ‘‘transient immaturity,’’ or whether Appellant was one of the ‘‘rare’’ juveniles whose crimes reflect ‘‘irreparable corruption’’ or ‘‘permanent incorrigibility,’’ as described in Miller. Of note, this holding overruled the Supreme Court of Minnesota's holding in Martin v. State, 865 N.W.2d 282 (Minn. 2015), which held that the U.S. Supreme Court's decision in Miller did not apply retroactively to a juvenile whose LWOR sentence became final before Miller was decided.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Appellant was convicted in district court of first-degree murder in connection with the shooting death of a 15-year old victim when the Appellant was 17 years old in connection with a gang altercation. Appellant filed for post-conviction relief, which was denied. Appellant appealed to the Supreme Court of Minnesota claiming (among other things) that his mandatory sentence of life imprisonment without the possibility of release (LWOR) should be reversed based on the U.S. Supreme Court's decision in Miller v. Alabama, 567 U.S. 460 (2012), which held that mandatory imposition of LWOR sentences are unconstitutional as applied to juveniles under the Eighth Amendment to the U.S. Constitution. The Supreme Court of Minnesota agreed, and vacated the Appellant's LWOR sentence because the mandatory statutory scheme under which the sentence was imposed was unconstitutional. In particular, U.S. Supreme Court precedent makes clear the decision has retroactive effect, and it is undisputed that the district court imposed a mandatory sentence of LWOR and did not consider Appellant's youth-related factors, whether Appellant fell within the vast majority of juvenile offenders whose crimes reflect ‘‘transient immaturity,’’ or whether Appellant was one of the ‘‘rare’’ juveniles whose crimes reflect ‘‘irreparable corruption’’ or ‘‘permanent incorrigibility,’’ as described in Miller. Of note, this holding overruled the Supreme Court of Minnesota's holding in Martin v. State, 865 N.W.2d 282 (Minn. 2015), which held that the U.S. Supreme Court's decision in Miller did not apply retroactively to a juvenile whose LWOR sentence became final before Miller was decided.
Link to Opinion
|
||||
|
Jackson-Hicks v. E. St. Louis Bd. of Election Comm'rs, 28 N.E.3d 170 (Ill. 2015)
|
Illinois | 2015 | Democracy & Voting, Voting Rights |
State:
Illinois
Year:
2015
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn December 2014, incumbent Mayor Parks sought reelection in the April 2015 municipal election. His nomination petitions with the East St. Louis Board of Election Commissioners appeared to contain 171 signatures, giving him 35 more than the minimum required. However, Emerka Jackson-Hicks, another candidate for mayor, challenged the validity of at least 48 signatures, leaving Parks with no more than 123 valid signatures. Twelve additional signatures were questioned on the grounds that those persons were not actually registered to vote at the time they signed the petition. The Election Board concluded that despite the fact that Parks' nominating papers had "insufficient signatures as required by law," there had been substantial compliance in that 136 signatures are required and Parks' nominating papers contained 123 valid signatures. Thus, the Election Board ordered that Parks' name would appear on the ballot at the upcoming primary election. The circuit and appellate court affirmed. The Supreme Court reversed the decision of the Election Board and remanded to the circuit court directing that the court enter judgment that (1) Parks' nominating petitions do not contain the minimum number of valid signatures required by law; (2) Parks has not qualified to have his name appear on ballot as a candidate for the office of mayor in the April 2015 municipal election; (3) Parks' name should be immediately removed from the ballot for that election. The Court reached this decision because it determined that substantial compliance is not a valid justification for deviating from the clear and unambiguous minimum signature threshold set by the legislature. Further, while Atkinson v. Schelling, 988 N.E.2d 700 (Ill. 2013) and Merz v. Volberding, 419 N.E.2d 628 (Ill 1981) represent situations where the candidates in an election cycle discovered later that election authorities had miscalculated and set the requisite number of signatures too low, the appellate court and Atkinson court overlooked that the Merz court limited its holding, expressly noting that "[f]or future reference, the minimum statutory signature requirement is mandatory and should be strictly followed." Merz, 419 N.E.2d at 1118. The Court further determined that if the Election Board receives any ballots cast prior to removal of Parks' name, the Election Board must disregard any votes cast for Parks when determining the winner of the election for office of mayor.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
In December 2014, incumbent Mayor Parks sought reelection in the April 2015 municipal election. His nomination petitions with the East St. Louis Board of Election Commissioners appeared to contain 171 signatures, giving him 35 more than the minimum required. However, Emerka Jackson-Hicks, another candidate for mayor, challenged the validity of at least 48 signatures, leaving Parks with no more than 123 valid signatures. Twelve additional signatures were questioned on the grounds that those persons were not actually registered to vote at the time they signed the petition. The Election Board concluded that despite the fact that Parks' nominating papers had "insufficient signatures as required by law," there had been substantial compliance in that 136 signatures are required and Parks' nominating papers contained 123 valid signatures. Thus, the Election Board ordered that Parks' name would appear on the ballot at the upcoming primary election. The circuit and appellate court affirmed. The Supreme Court reversed the decision of the Election Board and remanded to the circuit court directing that the court enter judgment that (1) Parks' nominating petitions do not contain the minimum number of valid signatures required by law; (2) Parks has not qualified to have his name appear on ballot as a candidate for the office of mayor in the April 2015 municipal election; (3) Parks' name should be immediately removed from the ballot for that election. The Court reached this decision because it determined that substantial compliance is not a valid justification for deviating from the clear and unambiguous minimum signature threshold set by the legislature. Further, while Atkinson v. Schelling, 988 N.E.2d 700 (Ill. 2013) and Merz v. Volberding, 419 N.E.2d 628 (Ill 1981) represent situations where the candidates in an election cycle discovered later that election authorities had miscalculated and set the requisite number of signatures too low, the appellate court and Atkinson court overlooked that the Merz court limited its holding, expressly noting that "[f]or future reference, the minimum statutory signature requirement is mandatory and should be strictly followed." Merz, 419 N.E.2d at 1118. The Court further determined that if the Election Board receives any ballots cast prior to removal of Parks' name, the Election Board must disregard any votes cast for Parks when determining the winner of the election for office of mayor.
Link to Opinion
|
||||
|
Jacobsen v. N.Y.C. Health & Hosps. Corp., 11 N.E.3d 159 (N.Y. 2014)
|
New York | 2014 | Health Care, Health Care Discrimination, Labor, Employment & Economic Justice, Disability Rights |
State:
New York
Year:
2014
Topics:
Health Care, Health Care Discrimination, Labor, Employment & Economic Justice, Disability Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff was a former employee of New York City Health and Hospitals Corporation (HHC). During his employment, Plaintiff developed lung conditions that limited his ability to perform certain aspects of his job. He asked for accommodations, which were not provided. Two days after filing a disability discrimination complaint against HHC, Plaintiff was placed on unpaid medical leave until his condition approved. His condition did not improve and HHC terminated Plaintiff. Plaintiff sued alleging disability discrimination and the trial court granted summary judgement for HHC. On appeal, the Court of Appeals held that where an employee seeks a specific accommodation for his or her disability, the employer must give individualized consideration to that request and may not arbitrarily reject the employee's proposal without further inquiry. The Court of Appeals also found that there was a genuine issue of material fact as to whether Plaintiff could have reasonably performed his essential job duties with accommodation and whether employee's proposed disability accommodations were reasonable. The Court of Appeals reinstated causes related to the same.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Plaintiff was a former employee of New York City Health and Hospitals Corporation (HHC). During his employment, Plaintiff developed lung conditions that limited his ability to perform certain aspects of his job. He asked for accommodations, which were not provided. Two days after filing a disability discrimination complaint against HHC, Plaintiff was placed on unpaid medical leave until his condition approved. His condition did not improve and HHC terminated Plaintiff. Plaintiff sued alleging disability discrimination and the trial court granted summary judgement for HHC. On appeal, the Court of Appeals held that where an employee seeks a specific accommodation for his or her disability, the employer must give individualized consideration to that request and may not arbitrarily reject the employee's proposal without further inquiry. The Court of Appeals also found that there was a genuine issue of material fact as to whether Plaintiff could have reasonably performed his essential job duties with accommodation and whether employee's proposed disability accommodations were reasonable. The Court of Appeals reinstated causes related to the same.
Link to Opinion
|
||||
|
James v. Heinrich, 960 N.W.2d 350 (Wis. 2021)
|
Wisconsin | 2021 | Education, Access to Education/Funding, Health Care |
State:
Wisconsin
Year:
2021
Topics:
Education, Access to Education/Funding, Health Care
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingJanel Heinrich, in her capacity as a local health officer of Public Health of Madison and Dane County (PHMDC), issued an emergency order closing all schools in Dane County for in-person instruction in grades 3-12. The Petitioner's argued that the order exceeded Heinrich's statutory authority under Wis. Stat. § 252.03 and violated their fundamental right to the free exercise of religion under Article I, Section 18 of the Wisconsin Constitution, as well as parents' fundamental right to direct the upbringing and education of their children under Article I, Section 1 of the Wisconsin Constitution. Heinrich countered that local health officers had the statutory authority under Wis. Stat. § 252.03 to issue school-closure orders. Further, she argued that the order was constitutional under the United States Supreme Court's ruling in Jacobson v. Massachusetts, 197 U.S. 11 (1905), and that, even if Jacobson did not apply, the order did not violate the Wisconsin Constitution. The Supreme Court held that the order restricting or prohibiting in-person school instruction was improper because local health officers did not have the statutory authority to close schools under Wis. Stat. § 252.03.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Janel Heinrich, in her capacity as a local health officer of Public Health of Madison and Dane County (PHMDC), issued an emergency order closing all schools in Dane County for in-person instruction in grades 3-12. The Petitioner's argued that the order exceeded Heinrich's statutory authority under Wis. Stat. § 252.03 and violated their fundamental right to the free exercise of religion under Article I, Section 18 of the Wisconsin Constitution, as well as parents' fundamental right to direct the upbringing and education of their children under Article I, Section 1 of the Wisconsin Constitution. Heinrich countered that local health officers had the statutory authority under Wis. Stat. § 252.03 to issue school-closure orders. Further, she argued that the order was constitutional under the United States Supreme Court's ruling in Jacobson v. Massachusetts, 197 U.S. 11 (1905), and that, even if Jacobson did not apply, the order did not violate the Wisconsin Constitution. The Supreme Court held that the order restricting or prohibiting in-person school instruction was improper because local health officers did not have the statutory authority to close schools under Wis. Stat. § 252.03.
Link to Opinion
|
||||
|
Jarrell v. Kaul, 123 A.3d 1022 (N.J. 2015)
|
New Jersey | 2015 | Health Care, Health Care Access/Funding |
State:
New Jersey
Year:
2015
Topics:
Health Care, Health Care Access/Funding
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA patient brought a medical negligence action against a physician for a surgical procedure and failure to maintain malpractice liability insurance or post a letter of credit as statutorily mandated, and against the hospital for negligent hiring. After all claims except the medical negligence claim were dismissed, a jury trial was held on the negligence claim, and the Superior Court entered judgment in favor of the patient holding that the physician negligently performed the surgery and his negligence proximately caused injury. The physician appealed and the patient cross-appealed. The Superior Court, Appellate Division, affirmed. The Supreme Court affirmed in part, reversed in part, and remanded, holding that: (1) the statute setting out mandatory medical malpractice liability insurance coverage for physicians does not expressly or impliedly create a private right of action for an injured patient to sue a physician who does not obtain or maintain statutorily-required medical malpractice insurance; (2) any failure of a physician to comply with such statute did not vitiate the patient's informed consent to surgical procedure; but (3) a genuine issue of material fact as to whether the physician complied with statutory letter of credit requirement precluded summary judgment in favor of the hospital as to the patient's negligent hiring claim against the hospital.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
A patient brought a medical negligence action against a physician for a surgical procedure and failure to maintain malpractice liability insurance or post a letter of credit as statutorily mandated, and against the hospital for negligent hiring. After all claims except the medical negligence claim were dismissed, a jury trial was held on the negligence claim, and the Superior Court entered judgment in favor of the patient holding that the physician negligently performed the surgery and his negligence proximately caused injury. The physician appealed and the patient cross-appealed. The Superior Court, Appellate Division, affirmed. The Supreme Court affirmed in part, reversed in part, and remanded, holding that: (1) the statute setting out mandatory medical malpractice liability insurance coverage for physicians does not expressly or impliedly create a private right of action for an injured patient to sue a physician who does not obtain or maintain statutorily-required medical malpractice insurance; (2) any failure of a physician to comply with such statute did not vitiate the patient's informed consent to surgical procedure; but (3) a genuine issue of material fact as to whether the physician complied with statutory letter of credit requirement precluded summary judgment in favor of the hospital as to the patient's negligent hiring claim against the hospital.
Link to Opinion
|
||||
|
Jefferson v. Dane Cnty., 951 N.W.2d 556 (Wis. 2020)
|
Wisconsin | 2020 | Democracy & Voting, Voting Rights |
State:
Wisconsin
Year:
2020
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingSimilar to Trump v. Biden, 951 N.W.2d 568 (Wis. 2020), the Plaintiff here challenges the indefinitely confined status for absentee ballots that were implemented during the pandemic. This action was brought by a Republican Party of Wisconsin leader, and challenges Dane County's election law allowing all electors in the County to obtain an absentee ballot without a photo identification and allowing all Wisconsin residents to be considered indefinitely confined due to the pandemic. The Supreme Court ruled that the absentee ballot statute requires that (1) each individual elector make his or her own determination as to whether the elector is "indefinitely confined"; (2) an elector’s determination may be based only upon age, physical illness or infirmity; and (3) an elector is "indefinitely confined" for his or her own age, physical illness, or infirmity, not those of another person. In addition, the Supreme Court concluded that the Emergency Order providing that all voters could obtain an absentee ballot without a photo identification and allowing all Wisconsin residents to be considered indefinitely confined due to the pandemic did not render all Wisconsin electors, “indefinitely confined,” thereby obviating the requirement of a valid photo identification to obtain an absentee ballot. The voters still had to affirmatively and individually determine that they were indefinitely confined.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Similar to Trump v. Biden, 951 N.W.2d 568 (Wis. 2020), the Plaintiff here challenges the indefinitely confined status for absentee ballots that were implemented during the pandemic. This action was brought by a Republican Party of Wisconsin leader, and challenges Dane County's election law allowing all electors in the County to obtain an absentee ballot without a photo identification and allowing all Wisconsin residents to be considered indefinitely confined due to the pandemic. The Supreme Court ruled that the absentee ballot statute requires that (1) each individual elector make his or her own determination as to whether the elector is "indefinitely confined"; (2) an elector’s determination may be based only upon age, physical illness or infirmity; and (3) an elector is "indefinitely confined" for his or her own age, physical illness, or infirmity, not those of another person. In addition, the Supreme Court concluded that the Emergency Order providing that all voters could obtain an absentee ballot without a photo identification and allowing all Wisconsin residents to be considered indefinitely confined due to the pandemic did not render all Wisconsin electors, “indefinitely confined,” thereby obviating the requirement of a valid photo identification to obtain an absentee ballot. The voters still had to affirmatively and individually determine that they were indefinitely confined.
Link to Opinion
|
||||
|
Jeffords v. Fulton Cnty., No. S22A0474 (Ga. 2021)
|
Georgia | 2023 | Democracy & Voting, Voting Rights |
State:
Georgia
Year:
2023
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff Caroline Jeffords, along with eight other individuals, sued five members of the Fulton County Board of Elections arguing their votes in the 2020 general election were diluted because of allegedly unlawful ballots that they claimed were cast in the election. Three of the board members moved to dismiss the case on grounds of standing. The motion was granted by the trial court which determined petitioners lacked standing because they did not allege a particularized injury. The court of appeals affirmed the trial court's decision. The Supreme Court subsequently granted certiorari and vacated the court of appeals' decision, instructing the court of appeals to reconsider following the Supreme Court's 2022 opinion regarding standing in Sons of Confederate Veterans v. Henry County Board of Commissioners, 880 S.E.2d 168 (Ga. 2022), which held that, under Georgia law, an "injury need not always be individualized [but could] sometimes be a generalized grievance shared by community members, especially other residents, taxpayers, voters, or citizens." Reconsidering the case at the direction of the Supreme Court, the court of appeals subsequently dismissed the claims for the residents that did not live in Fulton County, holding that these individuals did not meet the standard set forth in Sons of Confederate Veterans because they did not allege they were citizens, residents, or taxpayers of Fulton County and thus did not show they were community stakeholders. For the appellants that were Fulton County residents, the court of appeals "vacate[d] the dismissals of their claims and remand[ed] to the trial court for further consideration in the first instance of their standing in light of Sons of Confederate Veterans."
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Plaintiff Caroline Jeffords, along with eight other individuals, sued five members of the Fulton County Board of Elections arguing their votes in the 2020 general election were diluted because of allegedly unlawful ballots that they claimed were cast in the election. Three of the board members moved to dismiss the case on grounds of standing. The motion was granted by the trial court which determined petitioners lacked standing because they did not allege a particularized injury. The court of appeals affirmed the trial court's decision. The Supreme Court subsequently granted certiorari and vacated the court of appeals' decision, instructing the court of appeals to reconsider following the Supreme Court's 2022 opinion regarding standing in Sons of Confederate Veterans v. Henry County Board of Commissioners, 880 S.E.2d 168 (Ga. 2022), which held that, under Georgia law, an "injury need not always be individualized [but could] sometimes be a generalized grievance shared by community members, especially other residents, taxpayers, voters, or citizens." Reconsidering the case at the direction of the Supreme Court, the court of appeals subsequently dismissed the claims for the residents that did not live in Fulton County, holding that these individuals did not meet the standard set forth in Sons of Confederate Veterans because they did not allege they were citizens, residents, or taxpayers of Fulton County and thus did not show they were community stakeholders. For the appellants that were Fulton County residents, the court of appeals "vacate[d] the dismissals of their claims and remand[ed] to the trial court for further consideration in the first instance of their standing in light of Sons of Confederate Veterans."
Link to Opinion
|
||||
|
Jenkins v. State, 755 S.E.2d 138 (Ga. 2014)
|
Georgia | 2014 | Criminal Justice, Access to Justice, Juvenile Justice |
State:
Georgia
Year:
2014
Topics:
Criminal Justice, Access to Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 1995, Defendant Jenkins was convicted of the malice murders, kidnappings with bodily injury, armed robbery, and theft. The jury recommended a death sentence for each of the murders. In 2003, the habeas court vacated Jenkins's death sentences and convictions, finding that Jenkins was 17 years old at the time of the crimes and that the U.S. Supreme Court had declared death sentences for crimes committed by persons under the age of 18 to be unconstitutional. The Supreme Court affirmed the judgment of the habeas court and ordered a new trial based upon the habeas court's determination that Defendant's counsel rendered ineffective assistance in the guilt/innocence phase of the trial. The habeas court further found that Jenkins's trial counsel had a conflict of interest, and that there was prosecutorial misconduct in that the State suppressed evidence of the involvement of an unindicted suspect, evidence related to the mental state of a key prosecution witness, and contradictory prior statements of testifying prosecution witnesses. After appeal, the Court affirmed the judgment of the habeas court, ordering a new trial based upon the habeas court's determination that Jenkins's counsel rendered ineffective assistance in the guilt/innocence phase of the trial. Jenkins contended that the trial court erred in denying his motions and pleas because his retrial would constitute double jeopardy under the U.S. and Georgia Constitutions for the reason that the prosecution committed intentional misconduct which violated due process, and thus, denied him his right to a fair trial. The Supreme Court disagreed, finding that the evidence at trial was sufficient to enable a rational trier of fact to find Jenkins guilty, and there was no showing that the State's conduct was aimed at aborting the trial and securing an opportunity to retry the case. There was likewise no merit to Jenkin's further claim that the trial court erred when it denied his plea alleging that the State had violated his Federal and State Constitutional rights to a speedy trial. While the relevant time was six years and nine months, the State and the defense shared responsibility for much of the delay, Jenkin's assertion of the right was not made early on, and Jenkins failed to show prejudice as a result of the delay.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
In 1995, Defendant Jenkins was convicted of the malice murders, kidnappings with bodily injury, armed robbery, and theft. The jury recommended a death sentence for each of the murders. In 2003, the habeas court vacated Jenkins's death sentences and convictions, finding that Jenkins was 17 years old at the time of the crimes and that the U.S. Supreme Court had declared death sentences for crimes committed by persons under the age of 18 to be unconstitutional. The Supreme Court affirmed the judgment of the habeas court and ordered a new trial based upon the habeas court's determination that Defendant's counsel rendered ineffective assistance in the guilt/innocence phase of the trial. The habeas court further found that Jenkins's trial counsel had a conflict of interest, and that there was prosecutorial misconduct in that the State suppressed evidence of the involvement of an unindicted suspect, evidence related to the mental state of a key prosecution witness, and contradictory prior statements of testifying prosecution witnesses. After appeal, the Court affirmed the judgment of the habeas court, ordering a new trial based upon the habeas court's determination that Jenkins's counsel rendered ineffective assistance in the guilt/innocence phase of the trial. Jenkins contended that the trial court erred in denying his motions and pleas because his retrial would constitute double jeopardy under the U.S. and Georgia Constitutions for the reason that the prosecution committed intentional misconduct which violated due process, and thus, denied him his right to a fair trial. The Supreme Court disagreed, finding that the evidence at trial was sufficient to enable a rational trier of fact to find Jenkins guilty, and there was no showing that the State's conduct was aimed at aborting the trial and securing an opportunity to retry the case. There was likewise no merit to Jenkin's further claim that the trial court erred when it denied his plea alleging that the State had violated his Federal and State Constitutional rights to a speedy trial. While the relevant time was six years and nine months, the State and the defense shared responsibility for much of the delay, Jenkin's assertion of the right was not made early on, and Jenkins failed to show prejudice as a result of the delay.
Link to Opinion
|
||||
|
Jenkins v. State, 894 S.E.2d 566 (Ga. 2023)
|
Georgia | 2023 | Criminal Justice, Access to Justice |
State:
Georgia
Year:
2023
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was originally convicted on two counts of malice murder, armed robbery and other crimes, and was sentenced to death. The Supreme Court affirmed the convictions and death sentence in 1998. In 2005, the U.S. Supreme Court decided Roper v. Simmons, 543 U.S. 551 (2005), holding that the death penalty is unconstitutional for defendants younger than 18. That watershed holding, coupled with the Defendant’s successful motion for ineffective assistance of counsel, engendered a new trial in 2014. Defendant was convicted after the new trial. On appeal, Defendant argued that the trial court erred in concluding that his invocation of his rights was ineffective on the ground that it was anticipatory. The Supreme Court of Georgia stated that the law is clear on the point in time of when Miranda warnings must be given—that is, when a person is (1) formally arrested or (2) restrained to the degree associated with a formal arrest. It was undisputed that the Defendant was in custody for the crimes at issue when he was advised of his Miranda rights, yet the trial court ruled that the invocation was invalid since Defendant was not being interrogated at the time the statement was made. In other words, the trial court focused on the fact that the invocation occurred in the interim between interrogations and relied on that basis to render the invocation invalid. The Supreme Court disagreed finding no applicable authority that suggested Defendant’s invocation of Miranda was impermissibly anticipatory where Defendant had been read his rights and subject to custodial interrogation about the crime at issue. Accordingly, the Supreme Court determined the State's failure to honor Defendant's valid invocation and it rendered Defendant's statements inadmissible. The Supreme Court reversed Defendant's conviction. Similar to the trial court, the dissent found that Defendant was not being interrogated within the meaning of Miranda when he invoked his right to counsel and therefore it was ineffective.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Defendant was originally convicted on two counts of malice murder, armed robbery and other crimes, and was sentenced to death. The Supreme Court affirmed the convictions and death sentence in 1998. In 2005, the U.S. Supreme Court decided Roper v. Simmons, 543 U.S. 551 (2005), holding that the death penalty is unconstitutional for defendants younger than 18. That watershed holding, coupled with the Defendant’s successful motion for ineffective assistance of counsel, engendered a new trial in 2014. Defendant was convicted after the new trial. On appeal, Defendant argued that the trial court erred in concluding that his invocation of his rights was ineffective on the ground that it was anticipatory. The Supreme Court of Georgia stated that the law is clear on the point in time of when Miranda warnings must be given—that is, when a person is (1) formally arrested or (2) restrained to the degree associated with a formal arrest. It was undisputed that the Defendant was in custody for the crimes at issue when he was advised of his Miranda rights, yet the trial court ruled that the invocation was invalid since Defendant was not being interrogated at the time the statement was made. In other words, the trial court focused on the fact that the invocation occurred in the interim between interrogations and relied on that basis to render the invocation invalid. The Supreme Court disagreed finding no applicable authority that suggested Defendant’s invocation of Miranda was impermissibly anticipatory where Defendant had been read his rights and subject to custodial interrogation about the crime at issue. Accordingly, the Supreme Court determined the State's failure to honor Defendant's valid invocation and it rendered Defendant's statements inadmissible. The Supreme Court reversed Defendant's conviction. Similar to the trial court, the dissent found that Defendant was not being interrogated within the meaning of Miranda when he invoked his right to counsel and therefore it was ineffective.
Link to Opinion
|
||||
|
Jeremias v. State, 412 P.3d 43 (Nev. 2018)
|
Nevada | 2018 | Criminal Justice, Death Penalty |
State:
Nevada
Year:
2018
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant argued, among other things, that the prosecutor committed misconduct during the penalty phase of his trial. Specifically, appellant first argued that the prosecutor mislead the jury by questioning a mitigation expert about the case of a different convicted individual whose sentence had been commuted (i.e., lessened). The individual was then released, and went on to murder another person. The prosecutor insinuated in their questioning that if Appellant received a lesser sentence, he could go on to commit additional violent acts, just as that other individual had done. The court held that though this question was improper, it did not mislead the jury because the prosecutor did not argue or suggest that Appellant had the option of a commuted or lessened sentence. Next, Appellant argued that the prosecutor's following statements mislead the jury: “what's the punishment for [the murder of] Brian? Because whatever you give short of death won't be a day longer in prison. And [Brian's] life is virtually meaningless by a verdict like that.” The Court acknowledged that the statement was improper, but reasoned that it did not affect the outcome of the proceedings. Finally, Appellant argued that the judge was required to give an instruction explaining that the aggravating circumstances had to outweigh the mitigating circumstances beyond a reasonable doubt in order to impose the death sentence. According to Appellant, a recent Supreme Court case, Hurst v. Florida, 136 S. Ct. 616 (2016) required this instruction. The Nevada court disagreed, holding that the weighing process is not a factual determination that needs to be proven beyond a reasonable doubt.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Appellant argued, among other things, that the prosecutor committed misconduct during the penalty phase of his trial. Specifically, appellant first argued that the prosecutor mislead the jury by questioning a mitigation expert about the case of a different convicted individual whose sentence had been commuted (i.e., lessened). The individual was then released, and went on to murder another person. The prosecutor insinuated in their questioning that if Appellant received a lesser sentence, he could go on to commit additional violent acts, just as that other individual had done. The court held that though this question was improper, it did not mislead the jury because the prosecutor did not argue or suggest that Appellant had the option of a commuted or lessened sentence. Next, Appellant argued that the prosecutor's following statements mislead the jury: “what's the punishment for [the murder of] Brian? Because whatever you give short of death won't be a day longer in prison. And [Brian's] life is virtually meaningless by a verdict like that.” The Court acknowledged that the statement was improper, but reasoned that it did not affect the outcome of the proceedings. Finally, Appellant argued that the judge was required to give an instruction explaining that the aggravating circumstances had to outweigh the mitigating circumstances beyond a reasonable doubt in order to impose the death sentence. According to Appellant, a recent Supreme Court case, Hurst v. Florida, 136 S. Ct. 616 (2016) required this instruction. The Nevada court disagreed, holding that the weighing process is not a factual determination that needs to be proven beyond a reasonable doubt.
Link to Opinion
|
||||
|
Jessie D. v. Dep't of Child Safety, 495 P.3d 914 (Ariz. 2021)
|
Arizona | 2021 | Civil Rights |
State:
Arizona
Year:
2021
Topics:
Civil Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingArizona law permits courts to terminate a parent-child relationship if the parent in question is convicted of a felony and sentenced to a term of imprisonment which would deprive the child of a normal home. Under Arizona precedent, courts apply a six-factor test to determine whether to terminate parental rights on this basis. The Arizona Department of Child Safety (DCS) sought to terminate a father's parental rights when he was sentenced to a maximum seven-year term of imprisonment for aggravated driving under the influence. The Arizona Supreme Court concluded that the six-factor test was satisfied, but that the juvenile court had misapplied one of the factors: "the degree to which the parent-child relationship can be continued and nurtured during the incarceration." The juvenile court reasoned that incarceration itself would prohibit this factor from being satisfied, but the factor presupposes incarceration. Noting that parents have a fundamental liberty interest in retaining custody and control of their children, the Arizona Supreme Court ruled that DCS must make reasonable efforts upon request to provide reunification services, such as visitation, to incarcerated parents. The concurrence would have found that the termination-of-rights statute did not satisfy constitutional due process.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Arizona law permits courts to terminate a parent-child relationship if the parent in question is convicted of a felony and sentenced to a term of imprisonment which would deprive the child of a normal home. Under Arizona precedent, courts apply a six-factor test to determine whether to terminate parental rights on this basis. The Arizona Department of Child Safety (DCS) sought to terminate a father's parental rights when he was sentenced to a maximum seven-year term of imprisonment for aggravated driving under the influence. The Arizona Supreme Court concluded that the six-factor test was satisfied, but that the juvenile court had misapplied one of the factors: "the degree to which the parent-child relationship can be continued and nurtured during the incarceration." The juvenile court reasoned that incarceration itself would prohibit this factor from being satisfied, but the factor presupposes incarceration. Noting that parents have a fundamental liberty interest in retaining custody and control of their children, the Arizona Supreme Court ruled that DCS must make reasonable efforts upon request to provide reunification services, such as visitation, to incarcerated parents. The concurrence would have found that the termination-of-rights statute did not satisfy constitutional due process.
Link to Opinion
|
||||
|
Joerg v. State Farm Mut. Auto. Ins. Co., 176 So.3d 1247 (Fla. 2015)
|
Florida | 2015 | Civil Rights, Disability |
State:
Florida
Year:
2015
Topics:
Civil Rights, Disability
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff, a disabled man who never worked, was awarded damages in a negligence case by a trial court. The trial court followed an evidentiary rule that payments from collateral source benefits are not admissible as evidence. The collateral source rule states that the court must reduce awards by the total of all amounts which have been paid for the benefit of the claimant, or which are otherwise available to the claimant. There are exceptions to this rule, for example, there are no reductions for collateral sources for which a subrogation or reimbursement right exists. The intermediate appellate court ruled that Plaintiff's Medicare benefits were free and unearned and should not have been excluded from evidence by the collateral source rule. Florida statute Section 768.76(1) also provides that "benefits received under Medicare . . . shall not be considered a collateral source." The Florida Supreme Court ruled that Medicare benefits were excluded and should not have been admitted as evidence in the original trial. Medicare benefits are excluded because they are not gratuitous. Medicare retains a right of reimbursement from any settlements by beneficiaries and as a result the benefits could be a potential liability. Medicare benefits could also potentially lead to unfair outcomes where tortfeasors could benefit from taxpayer funded Medicare payments for the injured parties. Accordingly, the Supreme Court found that the trial court properly excluded evidence of Plaintiff's eligibility for Medicare, quashed the intermediate court's decision, and remanded for further proceedings.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Plaintiff, a disabled man who never worked, was awarded damages in a negligence case by a trial court. The trial court followed an evidentiary rule that payments from collateral source benefits are not admissible as evidence. The collateral source rule states that the court must reduce awards by the total of all amounts which have been paid for the benefit of the claimant, or which are otherwise available to the claimant. There are exceptions to this rule, for example, there are no reductions for collateral sources for which a subrogation or reimbursement right exists. The intermediate appellate court ruled that Plaintiff's Medicare benefits were free and unearned and should not have been excluded from evidence by the collateral source rule. Florida statute Section 768.76(1) also provides that "benefits received under Medicare . . . shall not be considered a collateral source." The Florida Supreme Court ruled that Medicare benefits were excluded and should not have been admitted as evidence in the original trial. Medicare benefits are excluded because they are not gratuitous. Medicare retains a right of reimbursement from any settlements by beneficiaries and as a result the benefits could be a potential liability. Medicare benefits could also potentially lead to unfair outcomes where tortfeasors could benefit from taxpayer funded Medicare payments for the injured parties. Accordingly, the Supreme Court found that the trial court properly excluded evidence of Plaintiff's eligibility for Medicare, quashed the intermediate court's decision, and remanded for further proceedings.
Link to Opinion
|
||||
|
Johnson v. Ames, 76 N.E.3d 1283 (Ill. 2016)
|
Illinois | 2016 | Democracy & Voting, Voting Rights |
State:
Illinois
Year:
2016
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn November 2016, Appellee Johnson filed a referendum petition seeking to place the question of imposing term limits on the elected office of Broadview village president on the November 2016 general election ballot. The Broadview electoral board relied on the state Supreme Court's decisions of Leck v. Michaelson, 491 N.E.2d 414, 417 (Ill. 1986) (holding when voters challenged a referendum vote and subsequent ordinance for being vague and ambiguous, the proposition was fatally defective because of "vagueness and ambiguity" as the referendum could not "stand on its own terms") and Lipinski v. Chicago Board of Election Commissioners, 500 N.E.2d 39, 44 (Ill. 1986) (holding that the referendum proposition was too vague and ambiguous to qualify as a binding referendum "because it leaves in its wake significant questions unanswered and details which conflict with the Election code") to seek to invalidate the referendum as vague and ambiguous. The Circuit Court of Cook County concluded that the referendum was self-executing, not vague or ambiguous and applied prospectively. The appellate court affirmed the trial court's reversal of the board's decision and ordered that the proposition remain on the ballot. After applying the "vagueness and ambiguity" criteria described in Leck and Lipinski, the Court found that the proposition (1) clearly defined the new eligibility requirements which do not result in vagueness or ambiguity; and (2) properly provided for prospective application of the approved term limit restriction by changing the eligibility requirements for those candidates running for village president in elections beginning with the one slated for April 2017. Accordingly, the Court affirmed the judgment of the appellate court .
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
In November 2016, Appellee Johnson filed a referendum petition seeking to place the question of imposing term limits on the elected office of Broadview village president on the November 2016 general election ballot. The Broadview electoral board relied on the state Supreme Court's decisions of Leck v. Michaelson, 491 N.E.2d 414, 417 (Ill. 1986) (holding when voters challenged a referendum vote and subsequent ordinance for being vague and ambiguous, the proposition was fatally defective because of "vagueness and ambiguity" as the referendum could not "stand on its own terms") and Lipinski v. Chicago Board of Election Commissioners, 500 N.E.2d 39, 44 (Ill. 1986) (holding that the referendum proposition was too vague and ambiguous to qualify as a binding referendum "because it leaves in its wake significant questions unanswered and details which conflict with the Election code") to seek to invalidate the referendum as vague and ambiguous. The Circuit Court of Cook County concluded that the referendum was self-executing, not vague or ambiguous and applied prospectively. The appellate court affirmed the trial court's reversal of the board's decision and ordered that the proposition remain on the ballot. After applying the "vagueness and ambiguity" criteria described in Leck and Lipinski, the Court found that the proposition (1) clearly defined the new eligibility requirements which do not result in vagueness or ambiguity; and (2) properly provided for prospective application of the approved term limit restriction by changing the eligibility requirements for those candidates running for village president in elections beginning with the one slated for April 2017. Accordingly, the Court affirmed the judgment of the appellate court .
Link to Opinion
|
||||
|
Johnson v. Sec'y of State, 951 N.W.2d 310 (Mich. 2020)
|
Michigan | 2020 | Democracy & Voting, Voting Rights |
State:
Michigan
Year:
2020
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn a lawsuit filed by the Thomas More Society, a conservative legal group, Plaintiff asked the Supreme Court to segregate ballots, order an audit of election results, and delay Michigan’s certification of its 2020 presidential election results, alleging that election officials engaged in fraudulent and improper conduct in administering the election. The Supreme Court denied the petition’s request for declaratory relief.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
In a lawsuit filed by the Thomas More Society, a conservative legal group, Plaintiff asked the Supreme Court to segregate ballots, order an audit of election results, and delay Michigan’s certification of its 2020 presidential election results, alleging that election officials engaged in fraudulent and improper conduct in administering the election. The Supreme Court denied the petition’s request for declaratory relief.
Link to Opinion
|
||||
|
Johnson v. State, 402 P.3d 1266 (Nev. 2017)
|
Nevada | 2017 | Criminal Justice, Death Penalty |
State:
Nevada
Year:
2017
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAs a matter of first impression, the Court considered whether the deadline to file a postconviction habeas petition ran from the Court's order of resentencing or from when the defendant was actually resentenced by the district court on remand. Here, Defendant Donte Johnson was convicted of numerous felonies, including multiple counts of first-degree murder, for which he received death sentences. On direct appeal from that original sentence, the Court affirmed his convictions but reversed his death sentences and remanded the case with instructions for a new sentencing hearing. At the new hearing, a jury returned death sentences for the murder convictions, which the Court affirmed on direct appeal. The Court held that Johnson's time to file a postconviction habeas petition did not begin to run until the district court resentenced him. When the Court reversed his original death sentence, that removed the final judgment from which the deadline to file a postconviction petition ran under Nev. Rev. Stat. § 34.726(1). Thus, Johnson timely filed his petition, which was filed within one-year of his resentencing. However, the Court found that because the district court entertained and correctly denied the petition on the merits (separate from timeliness), the Court affirmed the denial of Johnson's petition for postconviction relief.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
As a matter of first impression, the Court considered whether the deadline to file a postconviction habeas petition ran from the Court's order of resentencing or from when the defendant was actually resentenced by the district court on remand. Here, Defendant Donte Johnson was convicted of numerous felonies, including multiple counts of first-degree murder, for which he received death sentences. On direct appeal from that original sentence, the Court affirmed his convictions but reversed his death sentences and remanded the case with instructions for a new sentencing hearing. At the new hearing, a jury returned death sentences for the murder convictions, which the Court affirmed on direct appeal. The Court held that Johnson's time to file a postconviction habeas petition did not begin to run until the district court resentenced him. When the Court reversed his original death sentence, that removed the final judgment from which the deadline to file a postconviction petition ran under Nev. Rev. Stat. § 34.726(1). Thus, Johnson timely filed his petition, which was filed within one-year of his resentencing. However, the Court found that because the district court entertained and correctly denied the petition on the merits (separate from timeliness), the Court affirmed the denial of Johnson's petition for postconviction relief.
Link to Opinion
|
||||
|
Johnson v. State, 805 S.E.2d 890 (Ga. 2017)
|
Georgia | 2017 | Criminal Justice |
State:
Georgia
Year:
2017
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA jury found Defendant guilty of malice murder and other crimes. All of the original verbatim trial transcript materials were later destroyed in a fire at the court reporter’s house. The State provided defendant with a 14-page, double-spaced document purported to be a complete narrative recreation of the trial transcript. The Supreme Court concluded that a 14-page summary drafted to re-create the events of a six-day trial was a bare-bones, insufficient summary that would not give Defendant a fair opportunity to appeal or to allow meaningful appellate review. The Supreme Court reversed the trial court’s denial of Defendant’s motion for new trial and remanded this case for further proceedings.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
A jury found Defendant guilty of malice murder and other crimes. All of the original verbatim trial transcript materials were later destroyed in a fire at the court reporter’s house. The State provided defendant with a 14-page, double-spaced document purported to be a complete narrative recreation of the trial transcript. The Supreme Court concluded that a 14-page summary drafted to re-create the events of a six-day trial was a bare-bones, insufficient summary that would not give Defendant a fair opportunity to appeal or to allow meaningful appellate review. The Supreme Court reversed the trial court’s denial of Defendant’s motion for new trial and remanded this case for further proceedings.
Link to Opinion
|
||||
|
Johnson v. Vanderkooi, 918 N.W.2d 785 (Mich. 2018)
|
Michigan | 2018 | Criminal Justice, Police Misconduct and Bias |
State:
Michigan
Year:
2018
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThis holding arises out of consolidated cases wherein plaintiffs were individually stopped and questioned by Grand Rapids Police Department (GRPD) officers and their photographs and fingerprints were taken in accordance with the GRPD’s “photograph and print” (P&P) procedures. In both cases, Plaintiffs were released without being charged with a crime. Plaintiffs filed civil lawsuits against the city and police officers involved arguing that the P&P’s violated their federal constitutional rights. While performing a P&P during a field interrogation when an officer deems it appropriate was a custom of the GRPD, it was unclear if it was official procedure. The Supreme Court held that that a policy or custom that authorizes, but does not require, police officers to engage in specific conduct may form the basis for municipal liability. This decision opened up the possibility of municipal liability for constitutional violations under these circumstances. The consolidated cases were remanded to the court of appeals to determine whether Plaintiffs' rights were violated and, subsequently, if the city should be held liable.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
This holding arises out of consolidated cases wherein plaintiffs were individually stopped and questioned by Grand Rapids Police Department (GRPD) officers and their photographs and fingerprints were taken in accordance with the GRPD’s “photograph and print” (P&P) procedures. In both cases, Plaintiffs were released without being charged with a crime. Plaintiffs filed civil lawsuits against the city and police officers involved arguing that the P&P’s violated their federal constitutional rights. While performing a P&P during a field interrogation when an officer deems it appropriate was a custom of the GRPD, it was unclear if it was official procedure. The Supreme Court held that that a policy or custom that authorizes, but does not require, police officers to engage in specific conduct may form the basis for municipal liability. This decision opened up the possibility of municipal liability for constitutional violations under these circumstances. The consolidated cases were remanded to the court of appeals to determine whether Plaintiffs' rights were violated and, subsequently, if the city should be held liable.
Link to Opinion
|
||||
|
Johnson v. Wis. Elections Comm'n, 972 N.W.2d 559 (Wis. 2022)
|
Wisconsin | 2022 | Democracy & Voting, Redistricting/Gerrymandering |
State:
Wisconsin
Year:
2022
Topics:
Democracy & Voting, Redistricting/Gerrymandering
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingVoters sought to remedy alleged malapportionment in Wisconsin's state legislative and congressional maps after the 2020 census. Previously, a court in this state recognized that the Wisconsin Constitution, as with the U.S. Constitution, imposes a requirement for population equality among legislative districts. Although “perfect exactness in the apportionment, according to the number of inhabitants, is neither required nor possible,” “there should be as close an approximation to exactness as possible.” Because of the imbalance after the census, voters petitioned to have existing maps of legislative districts declared unconstitutional and to have a mandatory injunction as a remedy. The Supreme Court set out the basic process and criteria that it would use to guide its decision. After parties to the litigation submitted proposed maps, the Supreme Court, accepted the maps proposed by the Governor. Voters and the Wisconsin state legislature applied for an emergency stay or certiorari review to the U.S. Supreme Court. The U.S. Supreme Court, construed the application as one for certiorari, and reversed as to the selection of the Governor's State Assembly and Senate maps. It also remanded for further proceedings and noted that the Wisconsin court was free to take additional evidence if it prefers to reconsider the Governor's maps rather than choose from among the other submissions. Any new analysis, however, must comply with our equal protection jurisprudence. On remand, the Supreme Court of Wisconsin held: (1) there was not strong basis in evidence that the Voting Rights Act required use of race to draw majority-minority legislative districts; (2) the maps proposed by the legislature did not violate the Voting Rights Act by having Black voting-age population at 45.8% in one assembly district and 71.5% in another; (3) the maps proposed by the legislature complied with the U.S. Constitution's Equal Protection Clause's “one person, one vote” requirement as well as the Wisconsin Constitution's equal-apportionment requirement; (4) the maps proposed by the legislature complied with the Wisconsin Constitution's requirement to observe governmental boundaries; and (5) the maps proposed by the legislature would be adopted.
|
|
|
Justice Vote Breakdown
|
Summary of Case Context & Holding
Voters sought to remedy alleged malapportionment in Wisconsin's state legislative and congressional maps after the 2020 census. Previously, a court in this state recognized that the Wisconsin Constitution, as with the U.S. Constitution, imposes a requirement for population equality among legislative districts. Although “perfect exactness in the apportionment, according to the number of inhabitants, is neither required nor possible,” “there should be as close an approximation to exactness as possible.” Because of the imbalance after the census, voters petitioned to have existing maps of legislative districts declared unconstitutional and to have a mandatory injunction as a remedy. The Supreme Court set out the basic process and criteria that it would use to guide its decision. After parties to the litigation submitted proposed maps, the Supreme Court, accepted the maps proposed by the Governor. Voters and the Wisconsin state legislature applied for an emergency stay or certiorari review to the U.S. Supreme Court. The U.S. Supreme Court, construed the application as one for certiorari, and reversed as to the selection of the Governor's State Assembly and Senate maps. It also remanded for further proceedings and noted that the Wisconsin court was free to take additional evidence if it prefers to reconsider the Governor's maps rather than choose from among the other submissions. Any new analysis, however, must comply with our equal protection jurisprudence. On remand, the Supreme Court of Wisconsin held: (1) there was not strong basis in evidence that the Voting Rights Act required use of race to draw majority-minority legislative districts; (2) the maps proposed by the legislature did not violate the Voting Rights Act by having Black voting-age population at 45.8% in one assembly district and 71.5% in another; (3) the maps proposed by the legislature complied with the U.S. Constitution's Equal Protection Clause's “one person, one vote” requirement as well as the Wisconsin Constitution's equal-apportionment requirement; (4) the maps proposed by the legislature complied with the Wisconsin Constitution's requirement to observe governmental boundaries; and (5) the maps proposed by the legislature would be adopted.
Link to Opinion
|
||||