State Supreme Court Data Tracker

Summary of Case Context & HoldingIn consolidated actions, patient's estate and patient's husband brought an action against Defendants including physician, hospital's chief executive officer (CEO), and hospital's director of risk management, asserting claims including for malpractice, lack of informed consent, products liability, and punitive damages arising from patient's death from leiomyosarcoma following a laparoscopic hysterectomy performed at the hospital with the use of a power morcellation device. Defendants moved for partial summary judgment to dismiss the claim for punitive damages, which the superior court denied. Defendants appealed to the Supreme Court. The Supreme Court reversed and remanded, holding that: (1) the alleged acts or omissions of physician were not motivated by actual malice or accompanied by wanton and willful disregard for patient's health and safety and thus could not support an award of punitive damages; and (2) the alleged acts or omissions of hospital executives also were not motivated by actual malice or accompanied by wanton and willful disregard for patient's health and safety and thus could not support an award of punitive damages. Under the New Jersey Punitive Damages Act, punitive damages are available only in exceptional cases.

Summary of Case Context & HoldingAfter his request for an internal affairs report regarding the former civilian head of police department, who allegedly engaged in racist and sexist behavior while in office, was denied by the prosecutor's office, requester filed a complaint against the prosecutor's office and its records custodian, relying on the Open Public Records Act (OPRA) and common law. The prosecutor's office argued that there was a need for confidentiality based on witnesses' expectation of privacy. The City of Elizabeth intervened, also emphasizing the need for confidentiality. The issue before the New Jersey Supreme Court was how to balance the public interest of transparency with the confidentiality in internal affairs. The Court held that OPRA does not permit access to internal affairs reports, but those records can and should be disclosed under the common law right of access—subject to appropriate redactions—when interests that favor disclosure outweigh concerns for confidentiality. Further, the Court ruled that the appellate court should remand the case to the trial judge to review in camera the internal affairs report and to complete the fact-sensitive balancing test to determine whether the requester was entitled to the internal affairs report under common access to public records.

Summary of Case Context & HoldingAn employee was a Coach Counselor for Rite of Passage (ROP) and signed a Coach Counselor Payroll Declaration, which provided for an unpaid 8-hour "sleep period" in accordance with 29 C.F.R. § 785.22 (2012). The employee filed a wage complaint alleging ROP failed to pay her for time worked, and the Labor Commissioner held an administrative hearing where it ruled that the employee had "worked" within the meaning of NRS 608.016 during her sleep period, for which she should have been paid. Whether an employee "worked" as defined in the federal Fair Labor Standards Act is a factual determination made by the appropriate administrator. The Supreme Court found that ROP required the employee to stay on its premises during her sleep period in case an emergency arose and that this requirement benefited ROP as it helped keep the youth safe and promoted bonding between the children and the Coach Counselor. The Supreme Court held that the evidence supported the Labor Commissioner's determination that the employee had worked during her sleep period based on the definition of "work" and affirmed the district court's judgment denying a petition for judicial review of the Labor Commissioner's ruling.

Summary of Case Context & HoldingDefendant Javier Righetti sought a writ of prohibition or mandamus that would direct the district court to enforce his plea. In an attempt to limit the grounds on which the State could seek the death penalty, Defendant Javier Righetti attempted to plea guilty to only certain theories of murder alleged by the State. Specifically, Righetti attempted to plead guilty only to murder by means of torture and felony murder but not that he had murdered the victim willfully, deliberately, or with premeditation. The court rejected this strategy and held instead that Righetti could not plead guilty "à la carte," which impinged on the State's authority to charge a defendant under one or more alternatives theories. Rather, by pleading guilty to murder, without a plea agreement, Righetti necessarily admitted that he committed a willful, deliberate, premeditated murder. The district court therefore correctly rejected Righetti's guilty plea as nonconforming. Accordingly, jeopardy did not attach as to prevent the trial of Righetti. Thus, the Court denied Righetti's requested relief.

Summary of Case Context & HoldingPlaintiff, a middle school teacher who had Type 1 diabetes and was injured in school during a hypoglycemic event, sued the Board of Education, alleging disability discrimination in violation of the New Jersey Law Against Discrimination (LAD) for failure to accommodate her diabetes. The superior court granted the Board's motion for summary judgment, and denied the teacher's motion for reconsideration on the ground that Plaintiff did not suffer an adverse employment action because she was not fired or reassigned, and thus did not have a prima facie claim. Plaintiff appealed. The appellate court reversed the grant of summary judgment in favor of Defendants stating that the LAD's broad remedial purpose may permit Plaintiffs to proceed against employers who failed to reasonably accommodate disabilities. The Supreme Court affirmed and held that an adverse employment action is not a required element for a failure-to-accommodate claim under the LAD and concluded that Plaintiff’s LAD claim based on Defendants’ alleged failure to accommodate her pre-existing diabetic condition is not barred by the state's Workers' Compensation Act (WCA). This decision clarified the required elements of a cause of action for failure to accommodate a disability under the LAD and also held that the WCA’s exclusive remedy provision does not preclude LAD claims because it would purportedly result in a “double recovery” to successful plaintiffs.

Summary of Case Context & HoldingOn June 22, 2021, the 2021-2022 Appropriations Act was enacted in South Carolina, containing two provisos restricting the use of mask mandates and virtual education in K-12 public schools. Proviso 1.103 of the Act permitted school districts to offer virtual education programs for up to five percent of their student population. For each student above the five percent threshold, a school district would not receive 47.22% of the per pupil funding otherwise allocated to them by the state. Proviso 1.108 of the Act prohibited school districts and schools from imposing a mask mandate requirement on any students or employees. The Richland School District and a parent of Richland students petitioned the Supreme Court to review the constitutionality of these provisos in its original jurisdiction. The Supreme Court held that neither of these provisos were unconstitutional. First, with respect to Proviso 1.108, the Court noted that it had already discussed the proviso and found it constitutional in the recently decided Wilson v. City of Columbia, Op. No. 28056 (S.C. Sup. Ct. Sept. 2, 2021), where the Supreme Court held that the proviso was reasonably related to the spending of tax revenue and, therefore, of the same subject to the rest of the Appropriations Act, and that municipalities were not granted the power to "effectively overrule" the General Assembly merely by declaring a state of emergency. Second, the Court held that the provisos did not deprive children of their rights to education and equal protection under the state constitution. The Court found no evidence to suggest that students were receiving disparate treatment due to the provisos, as the provisos applied equally to all public K-12 schools. Further, the Court noted that the right to an education was not infringed upon by the provisos, nor were students prohibited from wearing masks if they wished.

Summary of Case Context & HoldingA gasoline tank leak caused an explosion in a nearby condominium, killing a resident. The family of the resident brought suit under multiple statutes. The Plaintiff argued that the relationship between the federal Resource Conservation and Recovery Act, which implements the Leaking Underground Storage Tank Program, and the state Gasoline Storage Act creates a private right of action. The Court held that the statutes contain no explicit or implied private right of action. First, none of the statutes explicitly provide for a private right of action. Second, the Court conducted a four-step analysis to determine if there was an implied right of action. Specifically, the Court analyzed whether (1) the Plaintiff is a member of the class for whose benefit the statute was enacted; (2) the Plaintiff’s injury is one the statute was designed to prevent; (3) a private right of action is consistent with the underlying purpose of the statute; and (4) implying a private right of action is necessary to provide an adequate remedy for violations of the statute. The Court found that none of the four requirements were met. The central thread of the Court's opinion was that each of the applicable environmental statutes were meant to benefit the environment as a whole rather than specific individuals; therefore, should be enforced by the state. Accordingly, the Court determined that the statutes do not convey a private right of action.

Summary of Case Context & HoldingOn December 29, 2022, the Republican National Committee (RNC) filed an emergency petition for writ of mandamus against the Clark County Elections Department regarding its process for signature verification. The RNC argued that, because the composition of the group of signature verifiers, the County Registrar "violated his duty under NRS 293B.360(2) to ensure that the 'members of each [special election] board . . . represent all political parties as equally as possible.'" The RNC first sought relief in district court but, after the district court denied their petition, the RNC filed an emergency motion for relief from the Supreme Court. On December 29, the Supreme Court denied the RNC's petition, explaining that the provision of state law (NRS 293B.360(1)) that requires the Registrar to ensure as equal as possible political party representation on boards established for processing ballots did not apply in this case. Rather, the Supreme Court said a different provision "govern[ed] the procedures for verifying the signatures used for mail ballots" and "[t]he statue contains no requirement that a board verify the signatures, nor . . . any requirement therein that signature verification on mail ballot returns is done by persons of different political parties." The Supreme Court also stated that "RNC appears to argue that anyone assisting the Registrar in election efforts is necessarily an election board to which NRS 293.260(2) applies" but that the Supreme Court would not read "such a substantive requirement into a definitional statute in this manner."

Summary of Case Context & HoldingThe Plaintiffs filed suit following the Board of State Canvassers' denial of certification for the Reproductive Freedom For All (RFFA)'s petition, despite the Plaintiff having obtained the requisite signatures. The Supreme Court found that the Board's duty with respect to petitions is "limited to determining the sufficiency of a petition's form and content and whether there are sufficient signatures to warrant certification." The only challenge to the petition was in regard to whether there was sufficient space between certain words of the text of the proposed amendment, but the Supreme Court found that the meaning of the words was not changed by the alleged insufficient spacing between them. Assuming that the challengers' objection to the spacing represents a challenge to the "form" of the petition that the Board properly considered, the petition fulfilled all statutory form requirements, and the Board thus had a clear legal duty to certify the petition. The Supreme Court granted the writ of mandamus and directed the Board of State Canvassers to certify the RFFA petition as sufficient for placement on the November 8 general election ballot.

Summary of Case Context & HoldingA jury convicted Guillermo Renteria-Novoa of 36 felony sex offenses for which the court sentenced him to life with the possibility of parole in 85 years. After unsuccessfully exhausting his direct appeals, Renteria-Novoa filed a timely habeas petition and moved for appointment of postconviction counsel. Under Nev. Rev. Stat. § 34.750(1), appointment of postconviction counsel is not mandatory but within the discretion of the district court, as Renteria-Novoa did not face the death penalty. The district court found that Renteria-Novoa satisfied the threshold issues for appointment of counsel (Renteria-Novoa was indigent and his petition was not summarily dismissed). However, in considering the non-exhaustive statutory factors—"the severity of the consequences that the petitioner faces, the difficulty of the issues presented, the petitioner's ability to comprehend the proceedings, and the necessity of counsel to proceed with discovery"—the district court found against Renteria-Novoa and declined to appoint him counsel. The Supreme Court disagreed, finding that the district court abused its discretion because Renteria-Novoa had limited proficiency in English, faced severe consequences for his 36 felony sex offense convictions, the petition was his only opportunity to assert ineffective assistance of counsel (and other claims not subject to direct appeal), and the petition might have required discovery and investigation of facts outside the record. Accordingly, the Court reversed the district court and remanded the case for appointment of counsel to assist Renteria-Novoa.

Summary of Case Context & HoldingAn employee of the Lehigh County Court of Common Pleas brought suit against a court employer, alleging discrimination and retaliation based on his serious mental health condition under the Pennsylvania Human Relations Act (PHRA). The Supreme Court held that the PHRA does not apply to the judiciary because, in accordance with separation of powers principles, only the Supreme Court provides protection to court employees through its own rules, policies, and procedures.

Summary of Case Context & HoldingParents of J.S. (age eleven) reported to the Jefferson County Sheriff's Office that A.R. (age ten) had sexually assaulted J.S. A special prosecutor performed an investigation which included a forensic investigation. The results concluded that the allegations against A.R. were greatly exaggerated. Parents of A.R. then brought a claim against the prosecutor and the State seeking damages based on an alleged violation of A.R.'s constitutional rights to be free from unreasonable searches and seizures. The First Judicial District Court granted prosecutor's motion to dismiss on grounds of immunity and entered summary judgment for the County. Parents appealed. The Court affirmed, holding that absolute prosecutorial immunity barred the claims against both the State and the prosecutor. Additionally, the public duty doctrine applied to the investigation, which precluded the personnel from liability for acting according to their duty to protect and preserve the peace.

Summary of Case Context & HoldingPlaintiff voters brought an action against the Secretary of State (Secretary) seeking to have Legislative Referendum No. 119 (LR-119) declared constitutionally defective and to enjoin the State from placing LR-119 on the ballot. LR-119 would have changed Mont. Code Ann. § 3-2-101, which requires that justices of the Montana Supreme Court be elected on a statewide basis, such that each justice would now be elected from one of seven districts of approximately equal population, and the voters of each district could vote for only one justice. Specifically, LR-119 would have the following effect: (1) a candidate for a seat on the Supreme Court must be a "qualified elector" of the district from which the candidate is elected; (2) LR-119 creates seven Supreme Court districts and requires that each justice be elected from a separate district; and (3) LR-119 changes the method of selecting the chief justice from a statewide election to a selection by the seven justices from among their number. The district court granted summary judgment to the voters, finding that (1) Plaintiffs' challenge to LR-119 is justiciable, (2) that LR-119 is unconstitutional on its face because it attempts, through statutory measures, to change the constitutionally established qualifications for Supreme Court justice by adding a new residency requirement, and (3) that LR-119 cannot be salvaged by severing the invalid portions of the referendum. On appeal, the Supreme Court agreed with the district court. In relevant part, the Supreme Court found the matter justiciable because the record is factually adequate to enable the court to make the necessary legal determinations, and that no additional facts would aid the court in its inquiry. Further, the Supreme Court held that LR-119 is constitutionally defective because the Montana Constitution intends Supreme Court justices to be elected and serve on a statewide basis and does not specify district elections—a structure that the Supreme Court found consistent with the justices' statewide appellate jurisdiction. The Supreme Court thus concluded that LR-119's attempt to alter the structure of the Supreme Court by making it into a representative body composed of members elected from districts is facially unconstitutional, as neither the Legislature nor the people have the power to alter the constitutionally established structure of government by means of a statutory referendum. The district court's decision was affirmed.

Summary of Case Context & HoldingRehfield was the principal of a Catholic school when she alerted teachers about an out-of-state parent who she believed to present a threat based on his emails about his daughter. Although the police issued an arrest warrant for the parent, Rehfield distributed a photograph of the parent, which sparked widespread rumors and false stories about the situation. Following parental uproar, the Diocese in charge of the Catholic school terminated Rehfield. Rehfield sued the Diocese, alleging retaliatory discharge and violations of the Whistleblower Act. The trial court dismissed, holding that Rehfield was employed by a contract which only allowed retaliatory discharge claims to be brought by employees terminable at will. Rehfield was terminated for cause, so the claim was barred. On appeal, the appellate court affirmed the trial court's ruling, as it determined that Rehfield's role made her a "member of the clergy," and that her dismissal could not be heard as it fell under the Ministerial Exception. Under this exception, the first amendment bars courts from reviewing religious institutions' decisions regarding who may speak for the church. On appeal, the Supreme Court affirmed, holding that, despite her title, Rehfield functioned as a minister. Rehfield was required to be a practicing Catholic and to specifically abide by the local diocesan handbook, and her role included specific establishment of a Catholic learning environment and furtherance of the Catholic mission. As a result of her ministerial status, Rehfield's dismissal was not protected under the Whistleblower Act.

Summary of Case Context & HoldingRelevant to this case is a discrepancy between O.C.G.A. § 16-6-4(d)(2), which provides for a misdemeanor sentence for aggravated child molestation where the victim is at least 13 years old (among other conditions) and O.C.G.A. § 16-6-4(b)(2), which provides for a misdemeanor sentence for child molestation where the victim is at least 14 years old. Because the victim in this case was 13 years old, Defendant failed to qualify for the lower sentence he would have received if he had instead committed aggravated child molestation. On appeal, Defendant argued that he was subject to a felony sentence for child molestation despite the fact that he was similarly situated to certain defendants who would have received only a misdemeanor sentence for aggravated child molestation. Contending that there is no rational basis for such disparate treatment, Defendant argued that his equal protection rights were violated. Georgia law classifies aggravated child molestation as an act of child molestation that also physically injures the child or involves an act of sodomy. With respect to the sentencing schemes behind these crimes, a first offense of child molestation is punishable by a prison term of five to 20 years, whereas a first offense of aggravated child molestation is punishable by either life in prison or a prison term of at least 25 years followed by probation for life. It was undisputed that Defendant did not commit sodomy yet was imposed a sentence far harsher than members of the comparative class that committed that act as part of the molestation. Upon review, the Supreme Court explained that this point, coupled with a review of the legislative purpose of the statute, formed the Supreme Court’s viewpoint that the act of sodomy cannot be the basis that distinguished defendant from the comparative class. Thus, the Supreme Court reversed the lower court’s order denying Defendant’s challenge of the state’s child molestation statute. Justice Pinson concurred in the judgment, writing separately to note that the Equal Protection Clause's use of "similarly situated" is just a restatement of what the clause requires, rather than a separate analysis that the majority applied to reach its holding. The dissenting justices found no validity in Defendant's equal-protection claim because he did not stand in equal footing with other defendants charged with and convicted of aggravated child molestation.

Summary of Case Context & HoldingDefendant Reed-Kaliher pled guilty to possession of marijuana for sale and attempted possession of a narcotic drug for sale. A superior court judge sentenced Defendant to 1.5 years in prison on the marijuana count and suspended the sentence on the narcotic drug count, imposing three years probation. One of the conditions of Defendant's probation required him to "obey all laws." While Defendant was serving his prison term, Arizona passed Proposition 203, the Arizona Medical Marijuana Act (AMMA), which permits "a person who has been diagnosed by a physician as having a debilitating medical condition" to apply for a card identifying the marijuana possessor as a "registered qualifying patient." Defendant had chronic pain resulting from a fractured hip and obtained a "registry identification card” under AMMA so that he could obtain medical marijuana to ease his pain. During the term of Defendant’s probation, his probation officer added a new condition to his probation, specifying that he "not possess or use marijuana for any reason." Defendant opposed this condition and sought relief in the superior court. Defendant claimed that the AMMA's immunity provision shielded him from prosecution, revocation of probation, or other punishment for his possession or use of medical marijuana. That provision specifies that "[a] registered qualifying patient . . . is not subject to arrest, prosecution or penalty in any manner, or denial of any right or privilege . . . [f]or . . . medical use of marijuana pursuant to [AMMA], as long as the patient complies with statutory limits on quantity and location of marijuana use." Defendant requested that the superior court amend his probation conditions to delete the "no marijuana" term. The superior court denied the motion. Defendant filed a special action in the court of appeals, and the court of appeals granted relief. The Arizona Supreme Court affirmed the decision of the court of appeals. Specifically, the Supreme Court held that (1) the probation officer’s no-marijuana-use condition was prohibited by the immunity provision of AMMA; (2) Arizona state law prohibiting probationers convicted under certain sections from engaging in illegal drug use could not prohibit legal use under AMMA as a condition of probation; and (3) nothing in federal law required state judges to prohibit the use of medical marijuana as a condition of probation, and AMMA prohibited such a condition.

Summary of Case Context & HoldingPlaintiff was a student loan borrower who sought to sue his loan servicer over improper, deceptive, and negligent practices that the servicer had enacted which affected his eligibility for certain federal student loan programs. Plaintiff specifically sought to bring claims under state law, including Montana's Consumer Protection Act. The district court ruled that the Higher Education Act (HEA) expressly preempted Plaintiff's claims, and granted the Defendant loan servicer's motion to dismiss. After reviewing Plaintiff's claims under the preemption doctrine, the Court held that his claims were neither expressly preempted nor preempted via conflict. Further, the Court held that even if the HEA had sought to ensure national uniformity in student loan servicing, allowing Plaintiff's claims regarding unfair, deceptive and negligent practices to go forward would not prevent the Defendant, or any other servicer, from properly complying with the HEA's uniform requirements.

Summary of Case Context & HoldingIn 2009, South Carolina Supreme Court Chief Justice Toal issued an Administrative Order to ensure compliance with the Home Affordable Modification Program (HAMP) of the United States Department of the Treasury. This order was intended to ensure that eligible homeowners received the benefits under HAMP and to provide procedures for handling related issues and foreclosure actions. A revised order was issued in 2011, which included additional obligations to ensure foreclosure intervention occurred in required cases. In December 2016, the United States Congress ended the Making Home Affordable Program, making HAMP inapplicable to new foreclosure actions unless a borrower sought a modification prior to December 31, 2016. The South Caroline Supreme Court determined that, since HAMP had ended, the 2009 and 2011 Orders must be rescinded. As a result, the Mortgagee-Plaintiffs in the instant foreclosure actions were no longer required to comply with federal regulations regarding loss mitigation in South Carolina.

Summary of Case Context & HoldingIn 2011, Stacey Miller was diagnosed with hepatitis C and received a series of intravenous injections of lipoic acid. During one of the injections, Miller had an adverse reaction and had to be hospitalized for several weeks, seemingly due to improperly compounded lipoic acid. As a result of these complications, Miller became permanently blind in both eyes. Miller and her husband sued her doctor, the pharmacy that had provided the acid for the treatment, as well as several pharmacists who had produced the acid. The claims brought against the doctor were eventually dismissed, however against the pharmacy and the pharmacists, Miller brought negligence and product liability claims, and breach of implied warranties of "design, manufacture, inspection, marketing, and/or distribution." The pharmacy and pharmacist Defendants argued that the claims asserted by Miller were governed by the Texas Medical Liability Act (Act), and moved to dismiss Miller's claims for failure to serve an expert report within 120 days of suing, a requirement under the Act. The Defendants' motion to dismiss was denied by the trial court and the court of appeals affirmed, holding that neither the pharmacy, nor the individual pharmacists were heath care providers, and that the claims brought against them were not health care liability claims. On appeal, the Supreme Court reviewed the Act and held that Miller's claims were health care liability claims (subject to the Act). Pharmacists are explicitly covered in the delineated types of health care providers covered under the Act, and here, although the pharmacists were compounding pharmacists, their actions still fell under the types of actions protected under the Act. The Court reviewed the Texas Pharmacy Act's definition of "dispense," which includes a pharmacist compounding and delivering medicine to the patient or the patient's agent. The Court applied this definition to the compounding of the lipoic acid, holding that the pharmacists had dispensed the medicine, and therefore engaged in actions covered by the Act. As a result, Miller had failed to comply with the Act and serve the Defendants with an expert report within 120 days of filing suit, and her claims had to be dismissed.

Summary of Case Context & HoldingThe Employee-Plaintiff was hired via a professional employment organization (PEO), which under Montana law is treated as an employer for employee tort claims. Mont. Code Ann. § 39-8-207(8)(b)(ii). Under Montana's PEO Act, workers with tort claims are exclusively limited to remedies available under the Montana Workers' Compensation Act, and have no other redress against PEOs. Mont. Code Ann. § 39-8-207(8)(b)(i). The employee sued his employer, arguing that the PEO Act is unconstitutional under the Montana Constitution because it extended the exclusive remedy of workers' compensation to both the PEO and its client (the Plaintiff's employer), thus depriving the employee of full legal redress under the Montana Constitution. Mont. Code Ann. § 39-8-207(8)(b)(i); Mont. Const. art II, § 16. The Supreme Court held that the PEO Act did not violate the Montana Constitution because the state has a compelling interest in allowing its citizens the opportunity to pursue employment, and the PEO Act is narrowly tailored to balance the interests of both employers and employees in providing that workers' compensation is the exclusive remedy for claims against PEOs and their client-employers.

Summary of Case Context & HoldingA certified lactation counselor and a nonprofit organization that provided lactation services filed suit against the Secretary of State arguing that the Georgia Lactation Consultant Practice Act, Ga. Code Ann. §§ 43-22A-1 to 43-22a-13, violated due process and equal protection of the Georgia Constitution because it only permitted lactation specialists to obtain licensure if they obtained a certain private certification. The Plaintiffs argued the Act’s licensure requirements lacked any real and substantial connection to public health, safety, and welfare because there is no evidence that providers who obtained a different certification provided below-standard care. The Supreme Court held that the Act (1) imposed a burden on the profession; and (2) Georgia’s proffered interest in promoting access to quality care was an insufficient basis for the Act’s restrictions. While an individual’s right to engage in the employment of their choosing can be restricted in the interest of public health, the choice of one certification over the other was not justifiable. The Supreme Court established a framework to address cases challenging occupational licensing schemes under the Georgia Constitution: (1) the challenger must establish that the act infringes on a constitutional provision or violates the rights of the people by showing that (a) the occupation sough is lawful but for the challenged restriction; and (b) the regulation unreasonably interferes with the ability to pursue that occupation free from unreasonable government interference; (2) the government has the burden to prove there is a legitimate interest behind the law that justifies the restriction; and (3) the challenger has the ultimate burden to prove that the regulation unreasonably interferes with their right to practice the occupation of their choosing. In cases involving occupational licenses associated with public health, a burden on the ability to practice will be balanced against the interest in protecting public health and safety.

Summary of Case Context & HoldingA man killed his girlfriend during a domestic dispute because, he claimed, she was abusive towards him. During his defense, he moved to compel her hospital to disclose her mental health records stemming from a visit she made to the hospital following a domestic dispute in which she assaulted him. The prosecution argued against such records being disclosed due to an Arizona statute governing physician-patient privilege, but the trial court found that the Defendant's constitutional due process rights required such disclosure in camera. The Supreme Court upheld the trial court's ruling, reasoning that evidence of her mental illness was material to his justification defense and could potentially establish that his fear of her was not a self-serving opinion.

Summary of Case Context & HoldingA father worked a job that exposed him to asbestos fibers that would stay on him when he returned home to his family. Years later, the now adult son of the father died of mesothelioma (cancer associated with asbestos). The surviving family, including the father, sued the former employer of the father alleging the job negligently caused his son's death. The issue at hand is whether an employer who used asbestos materials in its workplace before 1970 had a duty to protect the public from off-site contact with employees who may have been carrying asbestos fibers on their work clothes. The Majority held that there was no duty by the employer to protect the son from exposure to take-home asbestos as there was no special relationship between the two parties and no duty existed based on public policy. In Arizona, to determine whether the family can sustain a claim for negligence the first most important step is to determine whether the employer owed a duty to the employee to conform to a certain standard of care. The duty framework is established not by foreseeability (when a defendant realizes or should realize that his conduct creates an unreasonable risk of harm to a “foreseeable plaintiff”) but by whether there is a special relationship and public policy. A special relationship is a relationship created by either common law, contractual agreement, or conduct undertaken by the parties such as the relationship between a doctor and a patient or a teacher and a student. There is no special relationship between an employer and an employee's family. Specifically, the son did not have a relationship with the employer and the employer did not have a duty to the son who was not employed by nor had a relationship to the employer. Further, there is also no evidence the son had a contractual relationship with the employer, or held a landowner-invitee/licensee relationship with the employer or suffered an injury on the employer's property. Public policy in Arizona creates a duty based on state and federal statutes and common law. In this case, the family failed to identify a valid public policy creating a legal relationship giving rise to a duty. While public policy can be for the betterment of the state/community, the Court held there needs to be a legal basis for such a policy to create a duty. In the absence of a statute, the court exercises restraint in declaring public policy. Having a general "social concern" for public welfare as could be the case with asbestos and mesothelioma, is not enough for the court to determine a duty of care where one never existed before. Accordingly, the Court held while the employee-father was owed a duty of care from the employer, there is no special relationship or duty between the family of an employee and the employer. The Majority opinion found that a general duty of care, a duty to anyone who is injured by the risk creating conduct even when the harm occurs off premises, surpassed the bounds of Arizona law. There is no history in Arizona law to suggest such a broad understanding of duty. The dissent believed the Majority erred by refusing to recognize the risk of physical injury created by the employer's manner of operating its factory and exposing its workers without warning to toxic asbestos while failing to provide workplace protective measures.

Summary of Case Context & HoldingPetitioner employee was let go from her managerial role allegedly for not completing her assigned tasks on time, a termination for good cause which she disputes. The lower court granted the employer's motion for summary judgment on the basis that the employer has met its burden under the Wrongful Discharge from Employment Act (WDEA), which provides for good-cause termination when the employer loses confidence in a managerial employee. Mont. Code Ann. § 39-2-904(1)(b). The Supreme Court held that under the Montana common law, the employer has the burden of presenting evidence of reasonable-job related grounds for dismissal, including legitimate business reasons, even for managerial employees for whom the employer has the broadest discretion in handling. Sullivan v. Cont'l Constr. of Mont., LLC, 299 P.3d 832 (Mont. 2013). Once the employer submits this evidence, the burden shifts to the employee to rebut the substantive reason for dismissal as not good cause, or that it was pretextual. Here, the employee failed to sustain that burden, thus summary judgment was awarded to the employer. Additionally, the Supreme Court found that a written warning ten years prior to termination still functioned as adequate written notice as required by the employee handbook.

Summary of Case Context & HoldingAn employee working in a correctional facility experienced sexual harassment by an inmate. She requested that the inmate be transferred to the maximum security unit, which was denied. However, the employer offered to transfer the employee to work in another unit. The employee refused and filed suit for sexual harassment, hostile work environment, and retaliation. The lower court found for the employer on all claims, and the employee appealed. The Supreme Court held that the employer had made reasonable accommodations in response to the harassment complaints, and that the offer to transfer the employee was a reasonable means of protecting her from sexual harassment, and that it was not pretextual and, therefore, not retaliation. The Supreme Court also held that the employer correctional facility was not negligent in responding to the harassment of the inmate, and thus was not liable as a third party for the sexual harassment and hostile work environment claims.

Summary of Case Context & HoldingAppellant was convicted of first-degree murder. Appellant argued that the district court abused its discretion in denying Appellant's motion for a hearing in connection with the fact that a juror was Facebook friends with various members of the victim's family and did not disclose these relationships during jury selection, despite not having been asked a question that would have elicited disclosure of those relationships. The Court held that the district court did not abuse its discretion because the Appellant did not submit sufficient evidence warranting the conclusion that the juror gave false answers during voir dire that concealed prejudice or bias toward him, given that none of the juror's Facebook friends were listed as witnesses in the case, or shared a last name with the victim, and the juror had not interacted with any of those Facebook friends for several years before the jury selection, except for one wedding picture that they "liked" on Facebook.

Summary of Case Context & HoldingPlaintiff Puglia filed an action against a former employer under the Conscientious Employee Protection Act (CEPA), claiming that his employment was terminated after he complained about his employer's failure to pay him in accord with the Prevailing Wage Act. The superior court granted summary judgment to the employer on the ground that such state-law claim is preempted by federal labor law on multiple grounds and the appellate court agreed. Plaintiff appealed. The Supreme Court concluded that a collective bargaining agreement cannot be used by an employer as a defense to a CEPA claim. Also, the Supreme Court found that whether the Plaintiff was terminated because of his complaints was a question of fact and therefore summary judgment should have been denied.

Summary of Case Context & HoldingIn 2006, the state's Department of Environmental Conservation (DEC) and the New York State Office of Parks, Recreation, and Historic Preservation prepared a plan to create a 27-mile system of snowmobile trails between communities in the Adirondack Park Forest Preserve. This plan would require the cutting and removal of thousands of trees, grading and leveling, and the removal of rocks and other natural components from the Forest Preserve to create such snowmobile paths. Plaintiff brought an action alleging the construction of the trails was in violation of the "forever wild" provision (article XIV) of the New York Constitution. This constitutional provision mandated that protected Forest Preserve lands "shall be forever kept as wild forest lands" with the intent of ending commercial destruction and despoliation of the soil and trees and protecting the state's watershed. The Court of Appeals ruled that the level of tree cutting needed to construct these trails exceeded the level of tree cutting permitted by prior court decisions regarding compliance with article XIV. Accordingly, the Court of Appeals held that the planned snowmobile trails violated the State Constitution's "forever wild" provision and that construction of these trails could only be accomplished with a constitutional amendment.

Summary of Case Context & HoldingLawsuit filed by Promote the Vote 2022 (PTV22) challenging the Michigan Board of State Canvassers’ decision to not put PTV22’s ballot initiative on the state’s ballot. Among other things, the ballot initiative would “amend the [Michigan] Constitution to add a fundamental right to vote;” extend deadlines for absentee ballots for certain voters; provide for drop boxes, postage, ballot tracking and guarantee early voting. PTV22 submitted more than 664,000 signatures when only 425,059 are needed. The measure was challenged and ultimately removed from the ballot. PTV22 alleges that the Board of State Canvassers violated PTV22’s right to due process under the Michigan Constitution by “refusing to certify the Proposal despite the Board approving the Proposal’s petition” and filed a writ of mandamus to force the board to certify the petition. The Supreme Court ordered the Board of State Canvassers to certify the Promote the Vote petition as sufficient for placement on the November 8 general election ballot, reasoning that the proposed amendments would not abrogate any of the constitutional provisions identified by the challenger.

Summary of Case Context & HoldingIn 2016, the New York City Water Board—which collects revenues to keep the City's water and sewer systems financially self-sustaining—approved a 2.1% rate increase, a one-time bill credit of $183 for the fiscal year to all account holders belonging in a particular tax class, as well as assistance programs for multi-unit apartments, seniors and low-income households and a low-consumption rate freeze. The City of New York also announced it would temporarily forbear collecting rents from the Water Board and provided that the savings from the rent forbearance would be passed on to all account holders. Petitioners, which included various landlords not eligible for the bill credit and not-for-profit assistance, commenced an action against the Water Board and New York Department of Environmental Protection (DEP), arguing the Water Board's determinations were irrational, arbitrary, and capricious and exceeded the Board's authority. The Court of Appeals held that the governing statutes provide that water and sewer rates may be determined in accordance with public policy goals, not just economic ones. Specifically, the Court found the Respondents' decision to allocate the relatively modest gain from the rent forbearance so as to be meaningful to a very large category of ratepayer, without requiring a complex application process, was not irrational. Thus, the Court of Appeals could not say the Respondents' actions were utterly arbitrary or unsupported by rational goals.

Summary of Case Context & HoldingIn August 2022, the Progressive Leadership Alliance of Nevada (PLAN) appealed to the Supreme Court after a district court denied its petition to block a temporary regulation by Republican Secretary of State Barbara Cegavske, which "allow[ed] counties, if they complied with certain requirements, to hand count votes as their primary vote count method in the November 2022 election." On October 25, the Supreme Court affirmed the district court's decision, holding that the district court did not "abuse[] . . . discretion in . . . finding that PLAN failed to show irreparable harm would result in the absence of an injunction." The Supreme Court reasoned that PLAN failed to show that using hand counting as a primary method to count ballots would cause harm and that no county planned to use hand counting as their primary method for counting votes in the upcoming election. The Supreme Court also noted that the regulation would expire before the next election (unless there was a special election held in the interim).

Summary of Case Context & HoldingIn a lawsuit filed on behalf of Priorities, USA and Rise, Inc., Plaintiffs challenged two Michigan laws: a proof of residency requirement that strictly limits acceptable documents and an automatic registration process which only applies to those older than 17.5 years old. The trial court denied the Plaintiffs’ motion and dismissed the case. The Supreme Court denied the Plaintiffs’ application to appeal the trial court’s order.

Summary of Case Context & HoldingPlaintiffs brought a class action against Philip Morris for violations of the Consumer Fraud and Deceptive Business Practices Act for using terms "lights" and "lowered tar and nicotine" on cigarette packaging and marketing. Plaintiffs alleged that when smoked under realistic conditions, these cigarettes failed to provide lower tar and nicotine compared to conventional cigarettes. The Defendant raised, among other defenses, Section 10b(1) of the Consumer Fraud Act, which provides that the Act shall not apply to "[a]ctions or transactions specifically authorized by laws administered by any regulatory body or officer acting under statutory authority of this State or the United States." The Defendant asserted Plaintiffs' complaint should not go forward because its use of "light" and "lowered tar and nicotine" complied with Federal Trade Commission (FTC) policies. The circuit court rejected the defenses, certified a class of approximately 1.14 million people, and awarded $10.1 billion in compensatory and punitive damages in favor of Plaintiffs. The Supreme Court reversed the judgment of the circuit court on December 15, 2005 on the basis that the FTC had authorized the use of descriptors "light" and "lowered tar and nicotine," hence barring Plaintiffs' complaint. The circuit court eventually dismissed Plaintiffs' complaint with prejudice in accordance with the Supreme Court's mandate. However, on Dec. 18, 2008, Plaintiffs petitioned for relief from judgment based on new evidence, pointing to an amicus brief the FTC filed in the U.S. Supreme Court case of Altria Group, Inc. v. Good, 555 U.S. 70 (2008), where the FTC indicated it did not authorize cigarette companies to use "light" or "lowered tar and nicotine." The circuit court dismissed the petition for untimeliness, but the appellate court reversed, concluding that the issue before it was whether the statements made by the FTC would have altered the court's resolution of the section 10(b)(1) issue. Holding that plaintiffs were entitled to relief, the appellate court effectively reinstated the original $10.1 billion judgment. The issue before the Illinois Supreme Court was whether the appellate court properly reversed the judgment of the circuit court that denied Plaintiffs' petition brought pursuant to Section 2-1401 of the Code of Civil Procedure, which provides a statuary procedure for obtaining relief from final orders and judgments more than 30 days after their entry. Plaintiffs sought to use section 2-2401 to vacate the judgment of the Supreme Court on December 15, 2005 in the circuit court. The Supreme Court held that the appropriate means would have been to file a motion in the reviewing court to recall its mandate, because Section 2-1401 does not authorize the circuit court to vacate the judgment of a reviewing court. The Supreme Court vacated the judgments of the appellate and circuit courts and dismissed the cause without prejudice, allowing Plaintiffs to file a motion to recall the mandate in the Supreme Court. The dissent found that the appellate court had properly applied Section 2-1401 because the statutory petition was a new action based on matters not in the original record, and Section 2-1401 contained unconditional language giving the circuit court equitable power to grant relief from judgment to prevent injustice. In 2016, the Illinois Supreme Court denied the Plaintiffs' motion to recall the mandate that struck down the $10.1 billion judgment. The U.S. Supreme Court also denied Plaintiffs' petition for review.

Summary of Case Context & HoldingPlaintiff brought an action against an oil company claiming, among other things, noneconomic damages for the mental anguish, emotional distress and psychological injuries that she sustained when the company negligently pumped 400 gallons of fuel oil into the basement of her house, which created an environmental hazard that required that the house be demolished. On the issue of noneconomic damages, the oil company moved for summary disposition, arguing that noneconomic damages resulting from real property damage were not compensable. The Supreme Court decided in favor of the oil company, holding that Michigan common law provided that the appropriate measure of damages in cases involving the negligent destruction of property is the cost of replacement or repair of the property, and because the Court found no compelling argument for altering the common law, it held that any change in the rule could only come from the Michigan legislature.

Summary of Case Context & HoldingGa. Code Ann. § 31-6-40 requires hospitals to obtain a certificate of need (CON) for specified new health services. The Georgia Department of Community Health promulgated a rule implementing Ga. Code Ann. § 31-6-40 that requires hospitals to obtain a CON prior to the establishment of a new or the expansion and an existing acute care adult psychiatric and/or substance abuse in-patient program. Expansion is defined as the addition of beds. A hospital held a CON for 49 total in-patient beds, 12 of which were under a CON for a psychiatric/substance abuse program. The hospital redistributed beds between the in-patient and psychiatric/substance abuse beds, but never exceed the total of 49 authorized by the CON. The Department issued a cease and desist letter to the hospital claiming that, because of the redistribution, the hospital had exceeded its CON for psychiatric/substance abuse beds, claiming the redistribution resulted in more than 12 beds. The hospital challenged the Department’s decision, arguing that requiring a new CON for bed redistribution was an impermissible expansion of the rule which only required a new CON for increasing bed capacity. The court of appeals ruled in favor of the Department, finding that the Department was authorized to create a category of services requiring a CON even if that service is not listed in the rule. The Supreme Court reversed, holding that a new CON was not required for redistribution because the text of the statute, Ga. Code Ann. § 31-6-40, provides for an exhaustive list of the situations that require a new CON and redistribution was not on the list. The Supreme Court reasoned that the Department did not have the authority to expand the list because, if it did, there would be issues with the constitutionality of the authority delegated to the Department.

Summary of Case Context & HoldingA dairy farmer sued a septic pumping service and its commercial general liability insurers, alleging negligence in storing and applying septage to its fields, which contaminated the water supply and harmed the farmer's cattle. The Supreme Court held that the septage decomposing into the farmer's water supply was an "occurrence" within the meaning of the insurance policies (triggering coverage), and considered a "pollutant" within the meaning of the pollution exclusion of the insurance policies.

Summary of Case Context & HoldingDefendant Kitrich Powell was convicted of first-degree murder for the repeated abuse of a four-year-old girl that ultimately killed her. After exhausting his direct appeals, Powell petitioned the Court for postconviction relief, which the district court dismissed as procedurally barred. Powell's claim was based in part on an 18-month delay in obtaining third-party expert witness declarations. The Court found that Powell's delay was unreasonable because he did not allege "any external impediment to the defense prevented him from obtaining both declarations earlier." The Court affirmed, holding that Powell's claims were procedurally barred as (1) trial errors should have been addressed on direct appeal; (2) the petition was untimely; and (3) the petition improperly raised new or previously litigated claims. The Court did not excuse these procedural bars based on Powell's actual innocence of first-degree murder or the death penalty. Even in light of the new evidence, the Court found that no reasonable juror would have been persuaded against conviction. Further, Powell did not prove his actual innocence as he did not challenge the validity of any aggravating circumstance. In dissent, Justice Cherry, joined by Justice Saitta, stated that the Court should have applied a reasonableness test to the timeliness of the late evidence rather than a bright-line rule. Under their test, the dissenters would have remanded the case for an evidentiary hearing on whether the delay was reasonable. If reasonable, an evidentiary hearing to determine the merit of Powell's ineffective assistance of counsel claim should have followed. Further, the dissenters would reverse Powell's death sentence and remand for an evidentiary hearing on whether Powell could demonstrate he was ineligible for the death penalty considering "the significant evidence his abusive upbringing and psychiatric conditions."

Summary of Case Context & HoldingAn oyster-farming business brought an inverse condemnation claim against the Alabama Department of Conservation and Natural Resources based on the Department's decision to build a breakwater and marsh for coastal protection, which allegedly caused sediment and silt to kill the oysters being farmed in Plaintiffs’ oyster beds in the shellfish aquaculture easement held by Plaintiffs. The trial court dismissed the action, holding that Plaintiffs had not alleged a valid inverse-condemnation claim for which relief could be granted. Plaintiffs appealed. The Alabama Supreme Court reversed and remanded the case, concluding that the Department’s actions foreseeably resulted in an interference with the private-property rights acquired by the oyster farmers and that the shellfish aquaculture easement acquired from the State created private-property rights that were disrupted by the sediment and silt for which a right to damages for a taking is recognized in Ala. Const. art. I § 23. Because leasehold interests can be taken by eminent domain, and therefore by inverse condemnation, the Court reasoned that easements, another real-property interest allowing the use of a property right held by the owner of the land, can be taken by eminent domain and therefore by inverse condemnation. Accordingly, the Court held that the oyster farmers properly stated claims for inverse condemnation upon which relief can be granted. It further held that because the exception from State immunity based on the taking of property for public use applies, the defense of State immunity was not available as to the oyster farmers' inverse-condemnation claims.

Summary of Case Context & HoldingOhio statute prohibited public sector unions from inducing or encouraging the picketing of private residences or private jobs of public officials. Oh.R.C. 4117.11(B)(7) describes employee organizations “[i]nduc[ing] or encourag[ing] any individual in connection with a labor relations dispute to picket the residence or any place of private employment of any public official or representative of the public employer” as an unfair labor practice. Resolving a split appellate court, the Supreme Court held that picketing was an expressive activity protected by the First Amendment, and therefore content-based restrictions on picketing are subject to strict scrutiny. The Supreme Court found that the restriction was content-based because it only restricted activity if it was connected with a labor dispute and done by an employee organization, and that this prohibition failed to clear the compelling government interest hurdle. The Supreme Court did not thoroughly address the distinction between the nominally permitted act of picketing and “encouraging or inducing” picketing. However, a concurrent opinion reasoned that “inducement” and “encouragement” were protected speech, agreed that the regulation was inarguably content-based. Under the statute an organization could discourage its members from picketing, and it could encourage its members to picket on any issue whose message was not related to an on-going labor dispute—thus meaning the content of the encouragement was the basis for its restriction or permissibility.

Summary of Case Context & HoldingLarry Porchia, the Appellant, alleged that emergency medical technicians had denied him medical treatment and transportation to the hospital after negligently misdiagnosing him and/or because he was homeless and uninsured. After EMTs had placed the Appellant on a stretcher, took his vitals, and asked him questions about his condition, the Appellant requested they transport him to the hospital. According to the Appellant's amended complaint, once he informed the technicians that he was homeless and did not have insurance, the technicians diagnosed Porchia with gas pain, removed him from the stretcher, and concluded he did not need to be transported to the hospital. Porchia would later need to undergo emergency surgery, which he was informed would not have been necessary if he had received treatment earlier. The district court dismissed Porchia's complaint after concluding that his claims were barred by the public duty doctrine and the Good Samaritan statute. On appeal, the Supreme Court accepted Porchia's allegations as true and considered whether failing to render medical assistance or provide transport based solely on a patient's socioeconomic status qualified as an affirmative act exempted from the public duty doctrine. First, the Supreme Court affirmed the district court's ruling, holding that the specific duty exception to the public duty doctrine did not apply here. The paramedics did not have a duty to transport a patient who did not require further medical attention based on their medical expertise. This lack of duty was further supported when the technicians made no specific promise to Porchia to transport him which he could have relied upon to his detriment. The Court also upheld the district court's dismissal of Porchia's negligence claims which were brought on a misdiagnosis theory, viewing a misdiagnosis as akin to an omission, rather than an affirmative action. However, the Supreme Court reversed the district court and held that the EMTs took affirmative action when they removed the Plaintiff from the stretcher and refused to transport him when they learned of his socioeconomic status and lack of insurance. Finally, the Supreme Court held that dismissing Porchia's claims under Nevada's Good Samaritan statute was improper, as the EMTs' actions could be considered grossly negligent and an aggravated act.

Summary of Case Context & HoldingA patient's wife brought a medical malpractice action against a hospital system based on the alleged negligence of independent contractors involved in providing care for a patient in the emergency rooms of two different hospitals owned by the hospital system. The district Court granted the healthcare system's motion to dismiss on the grounds that a hospital can be vicariously liable for a physician's negligence only if the physician is an employee of the hospital. The court of appeals affirmed. The Supreme Court reversed and remanded, holding that: (1) as a matter of first impression, a plaintiff may assert a claim against a hospital to hold the hospital vicariously liable for the professional negligence of an independent contractor based on a theory of apparent authority; (2) as a matter of first impression, a plaintiff states such a claim where the hospital held itself out as a provider of emergency medical care and the plaintiff relied on the hospital to select the personnel to provide services; (3) the wife's complaint adequately alleged that the healthcare system held itself out as a provider of emergency medical care; and (4) the wife's complaint satisfied the reliance element of her vicarious liability claim.

Summary of Case Context & HoldingPlaintiff School District sued Defendant School District challenging a transfer of territory from Poplar School District (the Plaintiff) to Froid School District (the Defendant). The Supreme Court reviewed the transfer under MCA Section 20-6-105(6), which sets out factors a superintendent must weigh when determining whether to grant a transfer of territory from one school district to another. The Court considered the extent to which the transfer would affect the tax burden of the affected areas, the impact that both state and federal aid has on educational funding, and the impact of transportation to and from the school. Notably, the Court held that the acting superintendent acted properly when considering state and local funding in the decision to grant the transfer of territory, and that state and local funding would be able to fill any gap created by the loss of tax revenue. The Court held that the district court had properly balanced the factors, and affirmed in favor of the transfer of territory.

Summary of Case Context & HoldingThe Supreme Court upheld the lower court's ruling that the Industrial Commission (an agency of the state of North Carolina that administers among other things, the state's Workers’ Compensation Act) did not err in awarding injured Plaintiff continued medical treatment and disability payments. Plaintiff became injured while working for his employer, the University of North Carolina (UNC). UNC tried to suspend disability payments, alleging the Plaintiff was not complying with rehabilitation efforts. The Industrial Commission ordered UNC to reinstate disability payments. The Supreme Court upheld the lower court's ruling in support of the Industrial Commission's decision because the Plaintiff's claim was only suspended, not terminated as in other cases, and could therefore be reinstated at any time and because the Plaintiff's doctor was an authorized treating physician as UNC had previously accepted the Plaintiff's claims for treatment through that doctor.

Summary of Case Context & HoldingPoole was convicted of first-degree murder, among other crimes, and sentenced to death by a unanimous jury. Poole appealed his conviction to the Supreme Court. The Supreme Court vacated the sentence of death due to issues in the penalty phase. The Court ordered a new penalty phase to be conducted, wherein Poole was again sentenced to death. Poole again appealed on the basis of prosecutorial misconduct, racial discrimination, and arguments against the constitutionality of the death penalty. The claims for racial discrimination were based on questions of the genuineness of the State's race-neutral explanations for striking two African American jurors. The prosecution's race-neutral explanation was that both jurors were asked if they would vote to keep the death penalty in Florida, and both were struck because they answered "not sure." The Supreme Court upheld these jury strikes as race-neutral because they were based on political philosophy and not race.

Summary of Case Context & HoldingThe Alabama Supreme Court considered whether a candidate, Irva E. Reed, could remain on the primary election ballot after missing a key filing deadline. Reed had sought to run for a seat on the Montgomery County Commission in 2024 and submitted her qualifying papers to the county Democratic Party. However, she failed to file a legally required Statement of Economic Interests (SEI) with the Alabama Ethics Commission within the five-day period mandated by Ala. Code § 36-25-15(a) (1975). She filed the SEI 41 days late and requested an extension from the Commission, citing illness. The Commission denied her request. Reed filed suit in Montgomery Circuit Court against the state election and ethics officials, asking the court to require her inclusion on the ballot. The trial court granted a preliminary injunction in her favor, ordering her to be certified as a candidate. State officials appealed. The Alabama Supreme Court stayed the order while reviewing the case, and the election took place. After the election took place, the Alabama Supreme Court dismissed the case as moot, explaining that a judgment in Reed's favor would no longer affect the rights of the parties. The Court rejected all three exceptions that could have allowed the case to continue: (1) the issue was not "capable of repetition but evading review" because Reed failed to show that interpretation of Ala. Code § 36-25-15(a) was significant enough to justify an exception; (2) the case did not present a matter of public interest rising to the level required under precedent; and (3) Reed's claimed "collateral rights" were in fact central to her case, not secondary. In a concurring opinion, Justice Mitchell agreed with the outcome but wrote separately to argue that Alabama should adopt a narrower standard for when courts can hear election cases that are otherwise moot. He suggested limiting such exceptions only to cases where there is a demonstratable likelihood that the plaintiff will suffer the same injury again, aligning Alabama law more closely with modern federal standards.

Summary of Case Context & HoldingFollowing the South Carolina Supreme Court’s decision invalidating the 2021 Fetal Heartbeat Act, the state legislature enacted a revised version in 2023, again titled the Fetal Heartbeat and Protection from Abortion Act. Like its predecessor, the 2023 law generally banned abortions after detection of cardiac activity in the embryo, with exceptions for rape, incest, fatal fetal anomalies, and threats to the mother’s health. However, the 2023 Act included revised legislative findings to justify the law, placing a stronger emphasis on the State’s asserted “compelling interest” in protecting unborn life and striking a more deliberate balance between that interest and the rights of pregnant individuals. Planned Parenthood and other medical providers again filed suit, arguing that the revised law remained unconstitutional under the same provision of the state constitution—the right to privacy under Article I, Section 10. The circuit court issued a temporary injunction preventing the law from taking effect, but the South Carolina Supreme Court agreed to hear the case directly. This time, however, the Court upheld the law in a 4-1 decision, declaring the 2023 Act constitutional and vacating the lower court’s injunction. Writing for the majority, Justice Kittredge acknowledged the Court’s prior ruling but emphasized key differences in the new law’s language, particularly its expanded legislative findings and removal of certain phrases from the 2021 Act that had troubled at least one justice. The Court stated that statutes are presumed constitutional and must be shown to be unconstitutional beyond a reasonable doubt—a high bar that Planned Parenthood failed to meet in this case. The majority reiterated that the legislature has broad authority to enact laws unless they clearly violate constitutional provisions. The Court emphasized that policy judgments about abortion are primarily for the legislature, not the judiciary, and that the constitution does not expressly guarantee a right to abortion. The ruling emphasized judicial restraint, the principle of separation of powers, and deference to the legislature’s findings—especially given the politically charged nature of abortion law. In effect, the Court found that while South Carolina’s constitution protects against unreasonable invasions of privacy, the 2023 Act was not arbitrary or unreasonable. Instead, it reflected a legitimate exercise of the legislature’s policymaking power based on its stated intent to protect fetal life while providing exceptions and access to early pregnancy care.

Summary of Case Context & HoldingPlanned Parenthood South Atlantic and other medical providers challenged the constitutionality of South Carolina’s 2021 Fetal Heartbeat and Protection from Abortion Act. The law prohibited abortions once a “fetal heartbeat” could be detected, which often occurs around six weeks into pregnancy—frequently before many women realize they are pregnant. The Plaintiffs argued that this restriction amounted to an unconstitutional invasion of privacy under Article I, Section 10 of the South Carolina Constitution, which protects against “unreasonable invasions of privacy.” The law included limited exceptions for rape, incest, fatal fetal anomalies, and medical emergencies. The South Carolina Supreme Court asserted original jurisdiction and ultimately struck down the law in a 3-2 decision. The lead opinion, written by Justice Hearn, found that the decision to terminate a pregnancy is a deeply personal one and falls squarely within the scope of the state constitution’s privacy protections. The majority concluded that the law imposed an unreasonable burden on a woman’s ability to access abortion care and did not give women a meaningful window of time to make that decision, especially considering how early in pregnancy the law prohibited abortion. The Court emphasized that South Carolina’s constitution, unlike the federal Constitution, explicitly includes a right to privacy. The majority reasoned that accepting the State’s narrow interpretation—limiting the privacy right to only search and seizure contexts—would render key constitutional language meaningless. The Court also rejected arguments that this privacy right should be interpreted through the lens of the legislative intent of the 1960s-era West Committee, which drafted the state constitutional amendment. Instead, the Court focused on the plain language of the constitution and its evolution through state jurisprudence. Drawing on precedent from South Carolina and other states with similar constitutional provisions, the Court found that reproductive decision-making is part of a broader right to bodily autonomy and medical self-determination. Thus, the 2021 Act was declared unconstitutional.

Summary of Case Context & HoldingPlaintiff, a collection of healthcare providers, sued the state of Florida requesting that the court enjoin a statutory 15-week abortion ban from becoming effective. The trial court, relying on Florida Supreme Court precedent, applied strict scrutiny in determining that the statute violated the right to privacy outlined in the Florida Constitution, and granted the injunction. Upon appeal, an automatic stay went into effect, which Plaintiff argued should be vacated, but the appeals court determined Plaintiff could not demonstrate irreparable harm and continued to stay the temporary injunction of the 15-week abortion ban. Plaintiff appealed to the Florida Supreme Court arguing the ruling conflicted with the Court's precedent. The Florida Supreme Court upheld the 15-week ban and overturned all previous cases finding an abortion right implicit in the privacy provisions of the Florida Constitution. In rejecting the reasoning laid out in precedent, the Court noted that previous decisions rested on the privacy rationale from the U.S. Supreme Court decision of Roe v. Wade, 410 U.S. 113 (1973), without any distinct analysis of the privacy provision in Florida's own constitution. The Court went on to criticize Roe as doctrinally incoherent. In addressing the merits, the Court noted that Plaintiffs' must show that the public would have understood the operative text of the privacy amendment to encompass abortion when it was on the ballot. The Court noted that the operative language, the right to be "let alone" from "governmental intrusion into the person's private life," does not explicitly mention abortion. The Court also discussed how a "pregnant woman cannot be isolated in her privacy," because "the termination of a pregnancy typically involves the destruction of another entity: the fetus," and thus does not fit squarely into the Florida Constitution's privacy protections. In assessing the history of the Florida Constitution's privacy provision, the Court concluded the public would not have identified it with abortion for several reasons including, that "the right to be let alone" had an independent meaning in Florida law before the amendment; that pro-life and pro-choice groups did not participate in debate around the amendment, and that many legislators who supported the proposal also supported a nationwide "right-to-life" amendment. Thus the Court held that Plaintiff could not overcome the presumption of constitutionality by a reasonable doubt, partially adopting the reasoning of Dobbs v. Jackson Women's Health Organization, 597 U.S. 215 (2022), the U.S. Supreme Court decision that overturned Roe in upholding the ban. The concurrence attempted to elaborate on standing in Florida courts as distinct from standing in Federal courts, noting that Florida's patchwork jurisprudence has led to confusion among litigants and lower courts. The dissent argued that, the Florida public did associate the privacy amendment with protections for abortion, noting "[d]uring the seven-year interval between Roe and Florida voters’ adoption of the right of privacy, I find it inconceivable that Americans—and more specifically, Floridians—were not aware that the right of privacy encompassed the right to an abortion."

Summary of Case Context & HoldingThe state legislature passed new laws in 2021 related to regulating and restricting abortion services within the state. The laws included restricting abortion after 20 weeks of pregnancy, prohibiting abortion options provided through telemedicine, and requiring providers of abortions to offer patients the opportunity to view an ultrasound and to listen to the heartbeat prior to an abortion. The laws also contained reporting requirements including requiring medication-abortion providers to report certain patient information to the state. The laws would punish violating medical providers with criminal or civil penalties. In response, abortion providers challenged the laws and sought declaratory and injunctive relief. The district court previously granted providers' request to enjoin the implementation of the laws and the state appealed. The Supreme Court affirmed the lower court's ruling stating that the court acted within its discretion in finding providers made a prima facie showing that reporting requirements and the provision of the law requiring providers to offer patients the opportunity to view an ultrasound violated the state constitutional right to privacy. The Supreme Court also held that the trial court acted within its discretion in finding the providers would suffer irreparable injury if the challenged laws took effect. The case was able to proceed to trial. In 2024, the state district court judge ruled that the abortion restrictions passed in 2021 were unconstitutional. The laws were permanently enjoined in their entirety based on constitutional violations of privacy, equal protection, and free speech. They were also impermissibly vague regarding criminal penalties.

Summary of Case Context & HoldingPlaintiff purchased a medical complex consisting of several already-present medical service providers with the intention of opening a clinic providing services to women, which include, among other services, abortion. Defendant tenant sought to enjoin the clinic's operation, arguing that a restrictive covenant prohibited outpatient surgery, emergency services, and several radiological services, unless ancillary and incidental to a physician's practice of medicine, and that abortion services run afoul of these restrictions. The trial court granted the injunction, finding that Defendants had a substantial likelihood of showing that performing abortions would violate the restrictions and that such procedures were not incidental to a physician's practice of medicine. The trial court further enjoined Plaintiff from providing diagnostic imaging services. Plaintiff sought reconsideration, asserting several errors of law and fact, which the trial court denied without explanation. On appeal, the first panel addressed the request for an emergency stay, ultimately staying the injunction. A second panel of the same court addressed the merits, reversing the stay and holding that Plaintiff was required to show changed circumstances, which it failed to do. The merits appeals court went on to find that the trial court's findings were supported by competent, substantial evidence that Defendant had shown a likelihood of success on the merits, and affirmed the injunction in part, allowing Plaintiff to return to providing imaging services. The Florida Supreme Court reversed the appeals court and overturned the injunction, finding that the evidence relied upon by the trial court was not competent and substantial. The Court first addressed the changed circumstances requirement, determining that the procedural rules require no such showing, and that a judge's broad discretion to reconsider non-final orders renders such a showing unnecessary. The Court concluded "just as a trial court's denial of a motion to modify or dissolve a temporary injunction when changed circumstances is shown is an abuse of discretion, denial of a motion to modify or dissolve is also an abuse of discretion where a party can demonstrate clear legal error or misapprehension of facts on the part of the trial court." In assessing the merits of the injunction, the Court found that the facts relied upon by the trial court were wholly unsupported, and in some cases, even contradicted by the record evidence. The Court took issue with the trial court's findings that abortion was "central" to Plaintiff's services and that Plaintiff could not be a "physician's practice" as described in the exception because Plaintiff engaged in education and advocacy. The Court contrasted these findings with testimony noting that abortion accounted for 1% of Plaintiff's services and that Plaintiff, as a separate organization from its national counterpart, does not engage in education and advocacy. The Court concluded "[b]ecause the party seeking a temporary injunction must establish that the party has demonstrated a substantial likelihood of success on the merits, and because this prong was not established, this error alone requires that the temporary injunction order be vacated." The dissent argued that Plaintiff did not present the question of whether changed circumstances are required in seeking reconsideration of a temporary injunction and, therefore, the case should have been discharged.