State Supreme Court Data Tracker

Summary of Case Context & HoldingDarryl L. Jones was convicted by a jury of various felonies for which the court sentenced him to approximately 51 to 134 years in prison. After his conviction and while pro se, Jones made several filings that the district court concluded were made in bad faith and solely to harass the State and the court. The Supreme Court reviewed whether the district court abused its discretion in designating an indigent, pro se criminal defendant, Jones, a vexatious litigant, thus limiting his ability to challenge his conviction and sentence. Citing Jordan v. State ex rel. Department of Motor Vehicles & Public Safety, 110 P.3d 30 (Nev. 2005), the Court held that the district court violated the Defendant's due process rights when (1) the district court restricted Jones from further filings even thought the State did not request that relief; (2) the record showed Jones had no opportunity to oppose the district court's restrictive order; and (3) Jones was not present at the hearing where the district court summarily designated him a vexatious litigant. Accordingly, the Court concluded that the district court acted arbitrarily and capriciously, in violation of Jones's due process rights, and issued a writ of mandamus directing the district court to vacate its order designating Jones a vexatious litigant and restricting his access to the courts.

Summary of Case Context & HoldingAppellant argued that his trial counsel, who was terminally ill at the time of the trial and died shortly thereafter, was impaired at trial and provided constitutionally ineffective assistance. The Strickland test requires Appellant to show both deficient performance of trial counsel as well as prejudice from the deficient performance. Strickland v. Washington, 466 U.S. 668 (1984). The Supreme Court found that no evidence was presented to defeat a strong presumption that exists that trial counsel's performance was reasonable and that counsel's decisions at trial fell within the broad range of professional conduct as assessed from counsel's perspective at the time of trial and under the specific circumstances of the case. The Supreme Court therefore affirmed the trial court's denial of Appellant's motion for new trial. Appellant further asserted that the repeated substitution of five different public defenders to represent him over 24 months, none of whom announced ready for trial or sought a speedy trial on his behalf, had the effect of denying his right to a speedy trial and therefore constituted ineffective assistance of counsel. The Supreme Court again applied analysis based upon Strickland. The Supreme Court noted that because a delay approaching one year is generally sufficient to raise a presumption of prejudice, if a motion for a speedy trial had been made in this case of a two-year delay, the trial court would have been required to consider the four Barker v. Wingo factors. See Barker v. Wingo, 407 U.S. 514 (1972) (listing the four factors as length of delay, reason for the delay, the defendant's assertion of his right to a speedy trial, and prejudice to the defendant.) But the Supreme Court found that Appellant made no showing that the failure of any attorneys appointed to represent him to seek a speedy trial was not a reasonable trial strategy of these attorneys, that he was subjected to any particular oppression, or suffered any unusual anxiety or concern as a result of his lengthy incarceration. Further, Appellant failed to present evidence of the most important interest protected by the right to a speedy trial in that he failed to present evidence that his ability to present a defense was prejudiced by the delay.

Summary of Case Context & HoldingAnthony Jones committed first-degree burglary at age 16 and armed robbery at age 17. He appeared in circuit court because armed robbery is a felony (and according to state statute, people 16 years or older who commit a felony are not considered “juveniles”). Jones pled guilty to both charges and received the statutory minimum sentence for both the burglary (15 years in prison) and armed robbery (10 years), to run concurrently. Following his sentencing, Jones filed an application for post-conviction relief (PCR), with the main argument being that subsection 63-19-20(1), which transferred him from family court to circuit court as an adult, was unconstitutional, because it does not allow discretion in sentencing for a defendant who is a juvenile at the time of the crime, which deprived him of due process. The PCR court dismissed his application, stating that the constitutional challenge was not a cognizable PCR claim, and, even if it were, the statute was constitutional. The Supreme Court reversed in part and affirmed in part. First, the Supreme Court found that Jones’s PCR application was cognizable, since a person who has been convicted of a crime can initiate a PCR proceeding when they allege that their conviction violates the U.S. or state constitution. Second, the Supreme Court found that subsection 63-19-20(1) was constitutional, characterizing it not as an “automatic waiver provision” (which would outline the process for automatically transferring a juvenile criminal matter to adult criminal court) but instead, simply a section that defined terms throughout the S.C. Children's code and not a section prescribing jurisdiction or procedure. The Supreme Court also found that mandatory minimum sentences were constitutional as applied to juveniles under subsection 63-19-20(1). Nonetheless, the Supreme Court emphasized the importance of the circuit court considering the mitigating factors of youth when sentencing juveniles under subsection 63-19-20(1), pointing courts to the Aiken v. Byars, 765 S.E.2d 572 (S.C. 2014) five factors of youth: "(1) the chronological age of the offender and the hallmark features of youth, including 'immaturity, impetuosity, and failure to appreciate the risks and consequence'; (2) the 'family and home environment' that surrounded the offender; (3) the circumstances of the homicide offense, including the extent of the offender's participation in the conduct and how familial and peer pressures may have affected him; (4) the 'incompetencies associated with youth—for example, [the offender's] inability to deal with police officers or prosecutors (including on a plea agreement) or [the offender's] incapacity to assist his own attorneys'; and (5) the 'possibility of rehabilitation.'" Here, the Supreme Court found that the plea court had sufficiently considered the five factors under Aiken (and that a separate Aiken hearing was not needed to do so). The Supreme Court also found that although the circuit court’s sentencing was subject to statutory minimums, the circuit court had a range of years in which to appropriately sentence Jones, and there was no difference between a circuit court’s and a family court’s ability to investigate Jones’s background. Based on all of these reasons, the Supreme Court affirmed Jones’s sentences. In a concurring opinion, Justices Hearn and Few argued that the circuit court did not fully satisfy what Aiken requires, but they concurred with the balance of the majority’s opinion because the circuit court sentenced Jones to the statutory minimum sentence for both charges and ran them concurrently, so in this case, a more thorough hearing would not have led to a lesser sentence.

Summary of Case Context & HoldingKristin Joseph, a licensed physical therapist, along with two orthopedic surgeons, Dr. Thomas Joseph and Dr. William McCarthy, challenged a position statement issued in 2011 by the South Carolina Board of Physical Therapy (the Board), which interpreted a provision of the South Carolina Physical Therapy Practice Act. The challenged statement permitted physical therapists (PTs) employed within a physical therapy group practice to treat patients referred by other PTs within the same practice without violating state law. However, the Board continued to prohibit PTs from treating patients referred by physicians if the PTs were employed directly by those physicians or physician practice groups, relying on its interpretation of S.C. Code Ann. § 40-45-110(A)(1), previously upheld by the South Carolina Supreme Court in the 2006 case of Sloan v. South Carolina Board of Physical Therapy Examiners, 636 S.E.2d 598 (S.C. 2006). The circuit court dismissed the plaintiffs' action, ruling that it was bound by the South Carolina Supreme Court’s prior decision in Sloan, which upheld the Board's interpretation prohibiting physician-to-PT referrals within employment relationships. The plaintiffs appealed directly to the South Carolina Supreme Court. On appeal, the South Carolina Supreme Court reversed the circuit court’s decision and explicitly overruled its previous ruling in Sloan. The Supreme Court found that the Board’s interpretation, upheld in Sloan, was unconstitutional because it violated equal protection and substantive due process rights of physical therapists by arbitrarily prohibiting physician-to-PT employment relationships while allowing similar referral arrangements within PT group practices. The Court determined that there was no rational basis to distinguish PTs from other healthcare professionals (such as occupational therapists and speech pathologists) who are permitted to be employed directly by physicians. The Supreme Court also held that the Board’s 2011 position statement constituted improper rulemaking under the Administrative Procedures Act (APA) because the Board failed to follow required procedures such as public notice, public hearings, and legislative review, rendering the position statement invalid.

Summary of Case Context & HoldingA group of landowners that held property along different waterways throughout Bamberg, Darlington, and Greenville counties jointly filed an action against the South Carolina Department of Health and Environmental Control (DHEC) challenging the registration provisions of the Surface Water Withdrawal, Permitting, Use, and Reporting Act (Act) as an unconstitutional taking, a violation of due process, and a violation of the public trust doctrine. The challenge was based on the fact that the Act requires water users who withdraw water in excess of three million gallons in one month for non-agricultural uses to obtain a time-limited permit. As to agricultural users, the Act requires only registration with the DHEC under two categories: (1) agricultural users already reporting their use to DHEC when the act was rewritten in 2010, who are allowed to maintain withdrawals at the user's highest reported level or at the design capacity of the intake structure; and (2) agricultural users who are not yet reporting their use, who are required to report their anticipated use for DHEC to make a determination as to whether the anticipated withdrawal amount is within the safe yield for the surface water source. The Act grants the DHEC oversight over registered withdrawals. As relevant to the case, the Act's registration system had three effects. First, unlike permits, which are issued for a term of years, registrations have no time limits. Second, the Act presumes all registered amounts are reasonable. And third, the Act changes the elements for a private cause of action for damages by requiring Plaintiffs to show a registered user is violating its registration. The circuit court granted summary judgment against the Plaintiffs on the grounds the case did not present a justiciable controversy, both because the Plaintiffs lack standing, and the dispute is not ripe for judicial determination. Plaintiffs appealed to the court of appeals and moved to certify the case to the Supreme Court of South Carolina. The Supreme Court of South Carolina affirmed the circuit court's ruling. Plaintiffs then filed a petition for rehearing as to the Court's ruling that their claims for a violation of the public trust doctrine did not present a justiciable controversy. As to that issue, the Court first determined that because Plaintiffs did not allege that any public trust assets had been lost as a result of any withdrawal of surface water that had already been made by any agricultural user, the claim was not justiciable. As to Plaintiff's novel theory of justiciability—that the registration provisions created a vested right for registered users to use the registered amount of water in perpetuity without regard to reasonableness and, therefore, the Act caused the state to permanently transfer public trust property to private registered users and simultaneously prevented the state from protecting trust assets against future loss—the Court determined that this theory did not make the controversy justiciable because it depended on future occurrences that might or might not cause the loss of trust assets. In addition, the Court rejected the theory because the Act provided several mechanisms for DHEC to protect against the loss of trust assets which rendered the Act consistent with the State’s obligations under the public trust doctrine. The Court further noted that only a plaintiff alleging that the State failed to utilize its power under the Act or was otherwise failed to protect public trust assets could mount a legitimate claim based on the public trust doctrine, which the Plaintiffs in this case did not do. As to the unconstitutional taking and due process claims, the Court maintained its prior determinations: that the Plaintiffs' allegations that the Act deprived them of their common law riparian rights were not supported by the terms of the Act because they may still challenge an agricultural use as unreasonable, they are still entitled to injunctive relief and may recover damages when they prove the required elements. Because the Act has not deprived the Plaintiffs of their riparian rights, they have no standing, and their claim for future injury was not ripe for the Court's determination and therefore not justiciable.

Summary of Case Context & HoldingKeith Russell Judd (Judd), an inmate in a Texas prison, sought a writ of mandamus requiring Montana to place his name on the 2012 Presidential primary ballot as a Democratic candidate for U.S. President under the 24th Amendment of the U.S. Constitution. Judd also requested that the Supreme Court requires all convicted and/or incarcerated felons to register to vote in the 2012 Presidential primary and general election. Citing to Article II of the U.S. Constitution, which disqualifies a citizen "serving a sentence for a felony in a penal institution" from voting, and Article IV, Section 4, which provides that "no person convicted of a felony shall be eligible to hold office until his final discharge from state supervision," the Supreme Court denied relief.

Summary of Case Context & HoldingPlaintiffs were former shareholders of Defendant-accounting firm, who alleged that a non-compete in their shareholders' employment agreement was unenforceable because the underlying shareholders' agreement itself was unenforceable as it was merely an agreement to agree which did not rise to the level of a legally binding contract. The lower court held for the Plaintiffs, agreeing that the agreement was merely an agreement to agree as it did not specify the amount of compensation, a required term in a contract for services. The Supreme Court overturned the lower court, finding that the underlying shareholders' employment agreement was enforceable because the amount or means of calculating compensation was not a mandatory term, and that the parties' intent to be bound and mutual consideration were evident in the agreement. The Supreme Court further held that the non-compete was not an absolute restraint on trade, and remanded to the lower court to analyze the reasonableness of the non-compete.

Summary of Case Context & HoldingPublic Act 97-695 (the Act) amended section 10 of the State Employees Group Insurance Act of 1971 to eliminate statutory standards for the State's contributions to health insurance premiums for three State retirement systems. To replace those standards, the Act would require the Director of the Illinois Department of Central Management Services to determine annually the amount of premiums charged to the State and to retired public employees. Plaintiffs contended that amending the law to authorize a system requiring retirees to contribute additional amounts toward the cost of their health care impaired the retirement system membership benefit within the meaning of Article XIII, Section 5 of the Illinois Constitution. Plaintiffs, members of the three retirement systems affected by the Act, brought four putative class actions challenging the constitutionality of the Act and certain Plaintiffs sought injunctive relief or damages for common-law claims based on contract and promissory estoppel. The circuit court dismissed the complaints, Plaintiffs appealed, and the Supreme Court granted Plaintiffs' motion for direct review of the four consolidated cases. The Supreme Court held that the General Assembly was precluded from diminishing health insurance subsidies provided to state retirees. Article XIII, section 5, provides that “[m]embership in any pension or retirement system of the State . . . shall be an enforceable contractual relationship, the benefits of which shall not be diminished or impaired.” The Court found that health care subsidies qualified as a benefit of membership because eligibility was conditioned on and flowed from membership in one of the State's various public pension systems. Subsidized health care had been one of several benefits of membership in a State retirement or pension system since article XIII, section 5 was proposed to Illinois voters for approval. Analyzing the context surrounding the proposal, the Court reasoned it was intended to eliminate uncertainty, guarantee contractual status for public employees' retirement rights, and insulate those rights from diminishment or impairment of the General Assembly. Therefore, the General Assembly was precluded from diminishing or impairing health care insurance subsidies through enacting Public Act 97-695. The dissent argued that this reading of Article XIII, Section 5 was too broad, and that it was meant to protect pensions, but not other non-pension benefits such as health insurance.

Summary of Case Context & HoldingEmployee-Plaintiff alleged that he was called racist names by a supervisor of employer-defendant, who denied having done so. The Montana Human Rights Commission appointed a Hearing Officer, which found in favor of the employee. The employer appealed on the basis of contradictory claims of whether the racist remarks were made. The Supreme Court, after reviewing the record and the Hearing Officer's findings of fact, found no clear error. The Supreme Court thus affirmed the judgment in favor of the employee, stating that the Hearing Officer's factual findings should be accorded great deference as to the credibility of witnesses and supporting evidence.

Summary of Case Context & HoldingDefendant William John Keck broke into his estranged wife's house with a chainsaw and shot her boyfriend to death. He also shot his estranged wife, who was pregnant. The wife survived, the child did not. Keck was convicted and sentenced to death for first-degree murder, attempted murder with a deadly weapon, and the manslaughter killing of an unborn quick child, among other offenses. Notable as to the death penalty, Keck argued that the State improperly elicited "holiday" testimony designed to inflame the jurors passions such that the jury would not render an impartial verdict. Specifically, the State gave a lengthy argument that asked the jury to consider how Keck's wife and boyfriend would never be able to marry and how the boyfriend's son would not have his father at his wedding. For example, the State asked the jury to imagine a hypothetical where the boyfriend's son had to explain why the jury let Keck live even though he killed his unborn baby brother. On the theory that the State opened the door to such testimony, Keck presented similar, though less severe hypotheticals in his defense. Additionally, the State told the jury that Keck's wife was forced to deliver the bullet that killed her baby, given that a bullet fell out of the wife during delivery. The Court found that the State engaged in prosecutorial misconduct. However, in light of the overwhelming evidence supporting the death sentence, the Court concluded that Keck's substantial rights were unaffected and he was therefore not entitled to relief. Keck also argued that the court improperly instructed the jury as to mitigation evidence, arguing that the instruction was likely to mislead the jury not to consider any mitigating circumstances. Relying on its decision in Watson v. State, 335 P.3d 157, 171-74 (Nev. 2014) (concluding "that there was no reasonable likelihood that the jury misunderstood the instruction to preclude it from considering any aspect of the defendant's character or record as a mitigating circumstance regardless of whether it reflected on his moral culpability"), the Court rejected this argument. The Court affirmed Keck's conviction and sentence. Dissenting, Justice Cherry stated that the cumulative effect of the State's inflammatory arguments together with an erroneous mitigation instruction warranted a new penalty hearing.

Summary of Case Context & HoldingThe estate of a worker who died of mesothelioma pursued an action against the corporate successor of the company that had contracted with the worker's employer for services. The company Defendant argued that the worker was a "statutory employee," and that South Carolina's Workers' Compensation Law provided the exclusive remedy for his claims. The trial court and court of appeals both held that the worker was not a statutory employee and permitted the case to proceed with causes of action for negligence, failure to warn, wrongful death, and survival. The South Carolina Supreme Court noted that the provision in the Workers' Compensation Law giving rise to the statutory employee doctrine was intended to "forestall evasion of the act by those who might be tempted to subdivide their regular operations among subcontractors, thus escaping direct employment relations with the workers." The Court rejected the Defendant's argument that public policy required application of the statutory employee doctrine, reasoning that the applicable public policy is not to limit avenues for recovery for injury but rather to "ensure that workers are covered under the Workers' Compensation Law," regardless of who provides the coverage. The Court also noted that the public policy underlying the statutory employee doctrine "is not to provide civil immunity to employers . . . or their corporate successors," so that the policy does not require that an employer be made immune from liability when coverage is satisfied from some source. The Court affirmed the court of appeals decision and held that the worker was not the statutory employee of the predecessor company and accordingly the action for civil liability was proper.

Summary of Case Context & HoldingThe Montana Supreme Court held that a senior water right holder (1) may make requests for water of selective junior water right holders; and (2) is not required to make the request of the most junior user and work up the priority list; and (3) does not have to wait until the river is dry to make any request for water to which it has a senior right. This case originated after Appellees, senior water right holders, observed that the flow of a river for which they had senior water rights had decreased over a couple of month period. Given the diminishing flows, the Appellees first sent requests for water letters to junior right holders who had been observed diverting water from the river and, after no change happened, eventually filed a suit in district court. The district court granted Appellees' motion for summary judgment finding that junior water right holder violated the "Prior Appropriation Doctrine," the underlying principle of which is that the person who first acquires a right to water is entitled to full appropriation before subsequent right holders may maximize their rights. Pursuant to that doctrine, if senior water right holders, like Appellees, found that they were not receiving the full appropriation, the court determined that they were permitted to request that junior water right holders cease further diversion of any water. Accordingly, the Montana Supreme Court affirmed the district court's decision to grant Appellees' motion for summary judgment.

Summary of Case Context & HoldingIn this case, the Supreme Court considered whether an employer can make reasonable modifications to employee lifetime retirement healthcare benefits. Here, retired Macomb County employees brought putative class action against the county alleging that the county breached their collective bargaining agreements (CBAs) by making unilateral changes to retiree healthcare benefits. The circuit court granted summary disposition in favor of the county. The court of appeals affirmed in part and reversed in part. The Supreme Court reversed and remanded the case, concluding that the CBAs did not grant the Plaintiffs a vested right to lifetime and unalterable retirement healthcare benefits and therefore the CBAs guaranteed healthcare benefits only until agreements expired and no longer.

Summary of Case Context & HoldingAfter the Macomb County made unilateral changes to retiree healthcare benefits (resulting in higher prescription copays, changed deductible amounts and reduced plan options), 1600 retired county employees brought a putative class action against the county. Plaintiffs alleged that their collective bargaining agreements with the county granted them a vested right to lifetime and unalterable retirement healthcare benefits. The Supreme Court held that the collective bargaining agreements did not guarantee healthcare benefits for life, but instead because the collective bargaining agreements were silent on whether the benefits were meant to be paid after the agreements expired (all agreements at issue had 3 year durational terms), the retired employees were only guaranteed benefits until the agreements expired.

Summary of Case Context & HoldingKenneh, a former employee, brought an action against former employer Homeward Bound, a nonprofit organization, alleging sexual harassment by co-worker Johnson, a maintenance coordinator, based on a hostile work environment in violation of the Minnesota Human Rights Act (MHRA). The district court granted summary judgment for the employer after concluding that Kenneh had failed to allege conduct sufficiently severe or pervasive to support a claim for sexual harassment, and the court of appeals affirmed. The Supreme Court unanimously held that: (i) Title VII's "severe-or-pervasive" standard in determining a hostile work environment remains a framework for evaluating sexual harassment claims in Minnesota but with consideration of evolving societal attitudes about acceptable workplace behavior; (ii) a zero-tolerance statement in the employee handbook that no harassment of any kind would be tolerated did not alter elements of statutory claim for sexual harassment; and (iii) factual issues as to the severity and pervasiveness of coworker's alleged conduct and employer's knowledge and response precluded summary judgment and should be decided by a jury at trial. According to this decision, Minnesota courts are not bound by restrictive federal court guidance in determining what constitutes sexual harassment under the MHRA and must consider the totality of the circumstances while construing the MHRA liberally.

Summary of Case Context & HoldingKiawah Development Partners, II, Inc. (Kiawah) was the owner of a small barrier island stretching approximately ten miles along the Kiawah River off South Carolina’s coast. Kiawah wanted to start developing homes on the island and applied for a permit to do so. The application sought approval from the South Carolina Department of Health and Environmental Control (DHEC) to construct a structure along a 2,783 foot stretch of tidelands primarily in order to stop ongoing erosion of the coastline. The DHEC denied most of the proposal but granted a small portion to protect an existing county park. Kiawah challenged the decision, and an administrative law court (ALC) eventually reversed DHEC’s decision, granting the permit for the entire structure. The decision was then appealed to the Supreme Court of South Carolina challenging the ALC's findings that the structure would (1) not contravene the Coastal Zone Management Act (CZMA); (2) would not contravene the CZMA's implementing regulation 30-11; and (3) would not contravene the CZMA's implementing regulation 30-12(c). The Court ultimately reversed the ALC’s decision and remanded the case for further consideration. As to the first issue, the Court found that the ALC erred as a matter of law by misinterpreting the requirement that tidelands be used in a way that provides maximum public benefit. The Court explained that the purpose of the public trust doctrine as it pertains to the environment is to protect and benefit the public at large and that recognizing the financial benefit to one company does not constitute such a public benefit. As to the second issue, the Court determined that the ALC erred as a matter of law by interpreting regulation 30-11 as allowing DHEC to only consider a project's impacts within the critical area. The Court found that deference to DHEC's interpretation of implementing regulation—namely, that the agency must consider the entire coastal zone in order to protect it as mandated by the CMZA—was appropriate as this interpretation was neither arbitrary nor capricious and comported with the CMZA's mandate. As to the third issue, the Court determined that the ALC's interpretation of implementing regulation 30-12(c), which creates public access requirements for bulkheads and revetments (the proposed structures), was erroneous to the extent that the ALC read a substantiality requirement on a project's effect on public access for the regulation to apply. Siding with Appellants, the Court determined that reading a substantiality requirement would improperly favor private interests in contravention of the CMZA and the public trust doctrine. The Court then went further, holding that even if the ALC's interpretation of implementing regulation 30-12(c) were correct, its finding that the project's effect on public access would be insignificant was not supported by the uncontroverted evidence at trial, which proved that the project would replace with concrete the only stretch of sandy beach on the Kiawah River, a rare feature for a tidal river. In finding the impact on recreational beach goers insignificant, the Court determined that the ALC misapprehended public use and failed to accord it the importance it deserves.

Summary of Case Context & HoldingThe complete history of litigation surrounding the installation of erosion control structures on Captain Sam's Spit can be found in the court’s earlier opinion, Kiawah Development Partners, II v. South Carolina Department of Health and Environmental Control, 766 S.E.2d 707 (2014), for which there is a case summary. This case came to the Court a second time following an order issued by the administrative law court (ALC) on remand ordering the installation of an erosion control structure along the shoreline of the Kiawah River on Captain Sam's Spit. On remand, the ALC reconsidered the evidence presented at the hearing and authorized the installation of a 270-foot tandem bulkhead and revetment along the shoreline adjacent to the parking lot of Beachwalker Park, as well as a vertical bulkhead only that spanned an additional 2,513 feet along the shoreline of Captain Sam's Spit. Following approval by the ALC, the South Carolina Department of Health and Environmental Control (DHEC) and the South Carolina Coastal Conservation League (League) appealed. The DHEC argued that the ALC erred in approving the 2,513 feet of vertical bulkhead without a revetment, while the League contested the entirety of the erosion control structure based on three arguments. As to the DHEC’s claim, the Court agreed and determined that the ALC erred by approving the construction of 2,513 feet of vertical bulkhead, without a revetment, because this structure was not supported by substantial evidence and as such, the ALC impermissibly authorized an entirely different structure from that for which Kiawah Development Partners, II, Inc. (Kiawah) had applied. The Court found that throughout the original record and on remand, the evidence indicated that Kiawah had maintained that the vertical bulkhead and sloping revetment constituted one unified structure, and that the testimony presented to the ALC illustrated that each component served a complementary function: the vertical bulkhead would prevent erosion of the upland, the revetment would prevent erosion of the sandy shoreline along the toe of the bulkhead, and neither structure, taken alone, would accomplish the result desired by Kiawah. On this basis, the Court determined that the ALC erred and modified its order by approving only the 270-foot bulkhead and revetment along the Beachwalker Park access area because that structure was supported by substantial evidence. As to the League’s claim, in adjudicating it, the Court explained that the League’s interests diverged from the DHEC’s to the extent that the DHEC agreed with the ALC's authorization of this section of the structure but the League contested this decision. The Court then ruled against the League’s first argument, finding no error in the ALC's decision to authorize a permit for the erosion control structure in that area based on both the abundance of evidence regarding the public benefit from protecting the parking lot and the fact that the installation of the structure in this area would have a de minimis impact on the public trust lands. The Court also dismissed League’s second argument that the ALC erred in its interpretation of Regulation 30-11(C)(1) (2011) as applied to the 270-foot structure because ensuring continued access to Beachwalker Park by protecting the parking area was in line with the current character of the Spit as a valued recreational destination. As to League’s third argument, the Court determined that there was no reversible error by the ALC when performing a feasible alternatives analysis pursuant to Regulation 30-12(C) (2011) because there was evidence in the record to suggest building the structure in that limited location was critical to protecting the Beachwalker Park parking lot.

Summary of Case Context & HoldingEmployees Christopher Kieninger and Dewayne Meek sought compensation from their employer, Crown Equipment Corporation, for time spent traveling in a company-provided vehicle between their residences and jobsites. The Plaintiffs argued that the travel was part of the workday and thus they were required to be compensated under Wis. Stat. § 109.03(1)'s mandate that employers pay employees "engaged in the employer's business." The Supreme Court held that such travel did not constitute a part of the employer's business under the statute, and was thus not compensable.

Summary of Case Context & HoldingIn 2017, the Nevada Legislature moved away from a uniform fee for piers and buoys and required that the State Land Registrar establish permit fees by regulation. The Registrar promulgated a regulation that set permit fees for residential use of piers and buoys on Nevada's navigable waters. The regulation was challenged by property holders on Lake Tahoe's shoreline who had piers and buoys on the lake. Appellants argued the agency exceeded its statutory authority because the statute's language read that the fee must be "reasonable based upon the fair market value of the use" and they believed this meant the fee should be based solely on the value of the state submerged land the pier or buoy occupies. The district court granted summary judgment in favor of the Registrar. The Supreme Court affirmed, holding that the Registrar did not exceed its statutory authority by referencing multiple methodologies when setting the fee because the statutes did not identify a particular formula for calculating fair market value.

Summary of Case Context & HoldingThe Texas Democratic Party sued King Street Patriots (KSP), a Texas-based nonprofit affiliated with the far-right Tea Party, in 2010, alleging that KSP had violated the Texas Election Code’s restraints on “political committees” and corporations. KSP primarily existed to train poll watchers and to hold rallies and weekly talks, all of which the Democratic Party claimed were only in support of Republican interests. The Democratic Party contended that KSP violated the Elections Code by making undisclosed contributions to Republic election efforts from funds received from its members, and that KSP coordinated with the Texas Republican Party and elected officials to target poll watchers to specific jurisdictions. Prior to trial, KSP brought counterclaims challenging the constitutionality of provisions of the Election Code that (1) define political committee; (2) provide a private right of action (3) restrict corporate political contributions; and (4) define political contributions. KSP argued that each of these four items, and the related provisions of the Election Code, violated its rights under the First and Fourteenth Amendments to the U.S. Constitution. As an unusual step, the parties agreed to sever the counterclaims challenging the constitutionality of the Election Code provisions into a new action, and pause the original action until the facial constitutional challenges had been completed. The parties filed cross motions for summary judgment regarding the constitutional challenges, and the trial court granted the Democratic Party’s motion, finding that none of the provisions of the Election Code at issue brought about any constitutional issues. The court of appeals then affirmed, after which KSP appealed to the Supreme Court. The Supreme Court in turn requested that the Texas Solicitor General provide the State’s viewpoint on the provisions of the Election Code at issue. The Solicitor General in turn argued that KSP did not qualify as a political committee under the Election Code, and that therefore KSP’s argument regarding the definition of political committees was not ripe. The Court agreed, holding that the plain meaning of the Election Code suggested that a political committee must have a “principal purpose” of accepting contributions intended to be used to further a political campaign. KSP argued that its forums and poll watcher training were always conducted on a nonpartisan basis, and the Court held that absent further evidence indicating KSP explicitly collected funds to further a campaign, KSP could not be considered a political committee. The Court next held that the provision of a private right of action under the Election Code was not overly broad, as it did not pose the litigative burden that KSP claimed. The Court noted that the right of action provided by the Election Code was relatively narrow and that any realistic application of the right would not pose an excessive burden on a defendant. The Court then considered the general prohibition against corporations making political contributions, and held that the U.S. Supreme Court’s decision in Citizens United v. Federal Election Commission, 558 U.S. 310 (2010) had not barred laws preventing corporations from contributing directly to political candidates, and that the prohibition under the Election Code was still constitutional under prior precedent. Finally, the Court held that although the definitions of a “political contribution” was intent-based, that alone did not make them unconstitutional.

Summary of Case Context & HoldingRodney St. Clair found an abandoned well on a property he purchased in 2013. He applied for a permit with the State Engineer to temporarily change the point of diversion of the underground water source from the well to another location on his property. He submitted a Proof of Appropriation to show a vested right to the underground water source. The State Engineer found that there was a right to appropriate underground water but a subsequent owner had abandoned it through years of non-use. The State Engineer argued that decades of nonuse were sufficient to establish that a prior owner intended to abandon the water right. The district court overruled the State Engineer's decision finding insufficient evidence that any owner of the property intended to abandon the property's water right. The Supreme Court affirmed the decision, finding non-use evidence alone did not shift the burden to St. Clair to prove an intent not to abandon the water right.

Summary of Case Context & HoldingJorge Melendez was participating in demolition work at a job site when a light fixture fell and lacerated his wrist. He was taken to the emergency room where Fred Quintana, Kings Aire's safety coordinator, assisted Melendez with a workers' compensation claim. Kings Aire notified Melendez about the Family and Medical Leave Act (FMLA), which informed Melendez that he was eligible for FMLA leave and entitled to up to twelve weeks of unpaid leave. The letter accompanying the notice stated that, effective July 3 (the first day Melendez was absent because of his injury), Melendez would be "placed on Family Medical Leave during your workers compensation leave." Melendez testified that he did not specifically request FMLA leave. However, the record did not reflect that he objected to that classification. When Melendez's twelve weeks of FMLA leave expired, he was not released to return to work. Kings Aire informed Melendez that his FMLA leave had expired and that his employment had been terminated pursuant to company policy. One month later, Melendez sued Kings Aire for breach of contract and for wrongfully discharging him in retaliation for filing a workers' compensation claim in good faith. Following a trial on the merits, the jury found in Melendez's favor on both his breach-of-contract claim and his retaliation claim. Kings Aire appealed only the portion of the judgment on the retaliation claim. The court of appeals affirmed. The Texas Labor Code states that "[a] person may not discharge or in any other manner discriminate against an employee because the employee has . . . filed a workers' compensation claim in good faith." An employer who violates this statute is subject to a retaliation claim, which constitutes "an exception to the traditional doctrine of 'employment at will' found in Texas law." Upon review, the Court stated that an employee must show that the employer’s prohibited action “would not have occurred when it did” absent the employee’s protected conduct. The Court stated that while a retaliation plaintiff may rely on circumstantial causation evidence, termination pursuant to a uniform enforcement of a reasonable absence-control policy does not constitute retaliatory discharge. The Court found that four other Kings Aire’s employees had been terminated for the same reason as Melendez. The Court also found that Kings Aire consistently applied its leave policy by terminating employees who did not return to work upon the expiration of their FMLA leave. The Court disagreed with Melendez and the court of appeals which argued that Melendez was disadvantaged by the FMLA designation, because it purportedly decreased the amount of allowable leave from "indefinite" to a twelve-week maximum. Instead, the Court found that the FMLA designation granted Melendez significant protections he otherwise would not have had. Moreover, the Court found that the trial evidence showed that Kings Aire terminated Melendez pursuant to uniform enforcement of a reasonable leave policy. Thus, the Court held there was legally insufficient evidence to support the jury’s finding that Kings Aire terminated Melendez because he filed a workers' compensation claim in good faith. The Court reversed.

Summary of Case Context & HoldingKnight was convicted of attempted second-degree murder of his former girlfriend and sentenced to a thirty-year sentence. The evidence supported the conclusion that Knight used a heavy, metal hydraulic jack handle to beat the victim very severely in her face and head, breaking the arm she used to try to block the attack, and breaking one of her eye sockets, in addition to inflicting other serious injuries to her face and head, including a gash down to her skull, leaving her with permanent residual impairments. The emergency medicine physician who treated the victim testified that the injuries required a direct blow of great force. Defense counsel argued that (i) the attack was not premeditated; (ii) Knight had no intent to kill the victim; and (iii) the evidence was insufficient to establish that Knight had used the jack handle as his weapon for the attack. The jury was instructed on the following offenses in the following order: attempted first-degree premeditated murder with a weapon (the charged offense); attempted first-degree premeditated murder; attempted second-degree murder with a weapon (the offense of conviction); attempted second-degree murder; attempted voluntary manslaughter with a weapon (the erroneous instruction); attempted voluntary manslaughter; aggravated battery with a deadly weapon or great bodily harm; felony battery with great bodily harm; and battery. The instruction for attempted voluntary manslaughter that was provided to the jury included intent to kill language; however, less than one month before Knight’s trial, the Supreme Court approved a standard jury instruction for attempted manslaughter that eliminated the intent to kill language. See In re Standard Jury Instructions in Criminal Cases–Instruction 6.6, 132 So. 3d 1124, 1125 (Fla. 2014). On appeal, Knight argued that the trial court committed fundamental error and that he is entitled to relief from his conviction of attempted second-degree murder with a weapon, even though the evidence supports the elements of the conviction, because the jury instruction on the lesser included offense of attempted voluntary manslaughter with a weapon erroneously included the element of intent to kill. The Supreme Court concluded that it had previously erred in its fundamental error analysis of Florida’s Jury Pardon Doctrine (the jury’s inherent power to pardon a defendant by convicting the defendant of a lesser offense) (i) by transforming this jury pardoning power into a fundamental right of the defendant; and (ii) by treating the deprivation of the defendant’s nonexistent fundamental right as a structural defect that impairs the fairness of the trial. The Supreme Court receded from its prior caselaw to the extent such caselaw found fundamental error based on an erroneous jury instruction for a lesser offense that is one step removed from the offense of conviction. As a result, the Supreme Court affirmed Knight's conviction.

Summary of Case Context & HoldingPlaintiff, a child sex offender, filed a pro se complaint alleging that Section 11-9.3(b-10) of the Criminal Code, which prohibits “child sex offender[s]” from living within 500 feet of a “day care home,” was unconstitutional. Plaintiff filed the complaint after the police informed him that a day care was operating within 500 feet of his residence and, thus, he had to move from his residence within 22 days of being notified. About a year later, when plaintiff was living at a recreational vehicle resort, he was forced to move again after the resort owner notified him he was not permitted to live there based on his sex offender status. While the Circuit Court reviewing the case found that the residency restriction violated Plaintiff's equal protection rights, the Appellate Court and Illinois Supreme Court disagreed. The Illinois Supreme Court found that the residency restriction did not infringe on any fundamental rights, such as the right to live where one pleases or the right to intrastate travel, because it did not directly interfere with an offender's family life or ability to live with their family, it merely limited the geographic location of their residence. Since the restriction serves a legitimate state interest in protecting children from sexual abuse, and did not infringe on any fundamental right, the court found that it was constitutional. The Illinois Supreme Court also rejected Plaintiff's argument that child sex offenders constitute a protected class and, thus, treating sex offenders differently depending on the number of children that they live close to was not prohibited.

Summary of Case Context & HoldingPetitioner Bethany Kosmider submitted a Freedom of Information Law request for copies of electronic voting ballot images recorded by voting machines used by Essex County in the general election. The Essex County Board of Elections denied the request on the basis that these were “voted ballots,” which under Election Law § 3-222(2) may not be examined a period of two years following an election absent a court order or direction from a legislative committee. The Court of Appeals upheld the County Board’s decision, holding that electronic voting ballots are “voted ballots” protected from disclosure by the Election Law in order to safeguard ballot secrecy and the integrity of official results.

Summary of Case Context & HoldingThe Commissioner of Higher Education sought to overturn a summary judgment order entered in favor of journalist Jon Krakauer ordering the release/inspection of certain student disciplinary records. The student records related to allegations of sexual assault occurring near the Missoula campus of the University of Montana, which the Commissioner had refused to turn over due to concerns about the Family Educational Rights and Privacy Act of 1974 (FERPA). The Court reversed and remanded the district court's decision to turn over the documents and ordered the district court to conduct an in camera review of the documents to determine whether the documents fell within the exception to FERPA and Montana state law for the release of information pursuant to a lawfully issued court order. The Court explained that FERPA regulations—namely 34 C.F.R. § 99.3, which defines personally identifiable information to include information that is linkable to a specific student—applied to the requested documents because Krakauer "clearly knew the identity of the student that he named specifically in his request." The Court noted that FERPA prohibits the release of education records or personally identifiable information contained therein without consent. The Court went on to state that FERPA provides many exceptions that allow for the release of educational records, including the final results of a disciplinary proceeding if the school determines that a student violated the school's rules or policies (20 U.S.C. § 1232g(b)(6)(B)), which the district court was to consider after conducting the in camera review upon remand as the record was not clear whether the University determined a violation had occurred. Furthermore, both FERPA (20 U.S.C. § 1232g(b)(2)(B)) and Montana state law (§ 20-25-515, MCA) provide an exception for the release of educational records pursuant to a judicial order or lawfully issued subpoena. The Court emphasized that, under these exceptions, the student's right to privacy under the Montana Constitution must be balanced against the public's right to know when determining what, if any, documents may be released and what redactions would be appropriate. Thus, the Court remanded to the district court to conduct an in camera review to determine whether any exceptions applied and appropriately balance the competing interests.

Summary of Case Context & HoldingPlaintiff sued Montana Commissioner of Higher Education seeking the release of educational records of star student athlete, Doe, who had been investigated for sexual misconduct. The Court held that while a student has a separate, increased privacy interest from their general personal privacy, such education-related privacy is not absolute, and may at times come into conflict with other rights protected by the Montana Constitution. The Court looked to federal law, state privacy jurisprudence, and the university’s Student Code of Conduct to hold that Doe was not properly on notice that any of his rights to privacy regarding his educational records had diminished. The Court also held that Doe's role as a popular student athlete did not make him a public official to the extent that it would reduce his privacy interest, and that redaction of the requested records would be futile given the specific request of only one individual's records, rather than a group's. Finally, the Court held that the public's right to know protected under the Montana Constitution was not outweighed by Doe's reasonable privacy interests.

Summary of Case Context & HoldingOn October 23, 2020, Clark County voter Fred Kraus, Donald J. Trump for President, Inc., and the Nevada Republican Party filed an application for temporary restraining order with the district court to prevent Nevada Secretary of State Barbara Cegavske and Clark County Registrar Joseph Gloria from separating or counting ballots in Clark County as part of the procedures it put in place for public observation. Petitioners alleged that Clark County violated Nevada law because, among other things, it did not submit a plan for observation of ballot handling and processing (although it was required to under state law) and did not permit observers to watch the ballot counting process. Petitioners also alleged that Nevada's challenging statute violated the Equal Protection Clause because (1) the statute lacked a provision through which to challenge voters who vote by mail (and this dissimilar treatment violated the Equal Protection Clause); and (2) the County's use of voting machines to aid the signature matching process (which they alleged was different than those of other counties) violated the "fundamental rights of voters in Nevada" by creating two classes of voters (one which had signatures verified by machines and another whose signatures were verified by election officials). On October 29, the district court denied Petitioners' claims and said that Petitioners: (1) did not have standing for the voting machines, ballot handing, or secrecy arguments; (2) failed to prove the Clark County Registrar "failed to meet his statutory duty under NRS 293B.353(1) to allow members of the general public to observe the counting of ballots" because state law does not prohibit the use of electronic means to check signatures; and (3) lacked evidence that mail-in voters and in-person voters were treated differently. On November 3, the Petitioners filed an emergency motion for relief with the Supreme Court and, that same day, the Supreme Court issued an order granting the motion to expedite because the "matter involves the election process currently underway" but denied their request for a stay or injection because "appellants have not demonstrated a sufficient likelihood of success to merit" such relief. On November 6, the Supreme Court issued an order dismissing the appeal because the parties reached settlement agreement.

Summary of Case Context & HoldingPlaintiff filed two separate actions against medical providers alleging violations of the Florida Consumer Collection Practices Act. The providers treated plaintiff following an injury while at work that was covered by workers' compensation, but for which the providers billed Plaintiff directly. Plaintiff alleged that the providers' direct billing attempts constituted an attempt to collect an illegitimate debt in violation of Florida Statute. The trial court sided with Defendants, reasoning that because the matter was one regarding reimbursement for services, exclusive jurisdiction over the dispute was vested with the Florida Department of Financial Services and not the courts. The appellate court reversed the decisions related to each provider and certified the same question to the Florida Supreme Court. The Florida Supreme Court sided with Plaintiff and held that the cases could continue in Florida state courts, reasoning that the plain meaning of "reimbursement" as used in the workers' compensation law was inconsistent with the meaning that the Defendants ascribed to it, and, therefore, against the "presumption of consistent usage" given that payments from Plaintiff directly to the providers did not constitute reimbursements.

Summary of Case Context & HoldingTwo Nevada residents, Mrs. LaFrance and Mrs. Cline, had a civil union ceremony in Vermont in 2020, and married in Canada in 2003 when same-sex marriage became lawful there. After returning to Nevada, the couple initiated a divorce proceeding in 2014. For purposes of determining what constitutes "community property" in connection with the divorce proceeding, Mrs. Cline maintained the boundaries of community property started at the time of the Vermont civil union in 2000, while Mrs. LaFrance contended that, for purposes of Nevada law, their marital community came into effect in 2014—the year that Nevada recognized same-sex marriage. The trial court found that the community came into effect when the parties entered into their civil union in 2000. Mrs. LaFrance appealed. The Supreme Court reversed and found that (1) the date of the civil union would be the proper date only if the couple had registered their union as a Nevada domestic partnership, which they had not done; and (2) the U.S. Supreme Court's decision in Obergefell v. Hodges, 576 U.S. 644 (2015) must be applied retroactively in determining the commencement date of the marital “community” for purposes of dividing assets in a divorce, such that the 2003 Canadian marriage should be deemed the date when the community was formed. Thus, the issue was remanded to the trial court “to apply community property principles, including tracing, to the parties’ property acquired after their 2003 Canadian marriage.”

Summary of Case Context & HoldingOver 22,000 retired former state employees sued the state and relevant agencies in response to the North Carolina General Assembly's enactment of a statute eliminating the ability of Plaintiffs to remain enrolled in a premium-free provider organization health insurance plan allocating eighty percent of the health care services to the insurer and twenty percent to the insured (i.e., the 80/20 plan). The Supreme Court held that the court of appeals erred in concluding Plaintiffs did not have vested rights within the meaning of the Contracts Clause of the U.S. Constitution to the benefit of lifetime enrollment in any particular premium-free health insurance plan, holding that the trial court correctly determined that Plaintiffs had obtained a protected vested right in remaining eligible to enroll in a non-contributory health insurance plan for life. However, the Supreme Court also held that the trial court erred in holding that Plaintiffs' rights were substantially impaired when the General Assembly eliminated the premium-free 80/20 plan.

Summary of Case Context & HoldingA real estate developer purchased land located in a critical dune area subject to certain regulations under the Sand Dunes Protection and Management Act (SDPMA). The developer received the required permits and special exceptions needed to develop the property, and Petitioners, who owned property immediately adjacent to the land, filed petitions under the SDPMA, which allows aggrieved owners of immediately adjacent property to challenge the grant of a permit or special exception. The real estate developer subsequently conveyed certain portions of the land it had purchased to non-affiliated third parties, with the result that Petitioners' properties were no longer immediately adjacent to the developer's land. The court of appeals held that the Petitioners lost standing to challenge the permitting decision after such conveyances because they were no longer immediately adjacent property owners. The Supreme Court reversed, holding that under the SDPMA, the Petitioners had a right to a hearing because they qualified as an eligible party under the statute when the hearing was requested and continued to desire a hearing, and there was no requirement that a petitioner maintain their original eligible party status throughout the proceedings.

Summary of Case Context & HoldingLancaster County sought judicial review of a final order from the Labor Relations Board, which concluded that the County committed unfair labor practices in violation of the Public Employee Relations Act (PERA) when it terminated two employees for union activities. The Supreme Court reasoned that, under the PERA, “a complainant meets the knowledge requirement by proving a supervisor, who by definition acts in the interest of the public employer, had knowledge of the employee’s protected activity.” The Supreme Court further reasoned that, in determining whether employees were fired for anti-union animus, “the manner in which an employer conducts its investigation may properly lend insight into its motivations for so doing,” particularly where supervisors involved in the investigation “had knowledge of the subject employees’ union activity.” Accordingly, the Supreme Court held that the employees had met the PERA’s knowledge requirement by proving that their supervisor had knowledge of their protected union activity and that there was substantial evidence supporting the finding that their termination was motivated by unlawful motive or anti-union animus.

Summary of Case Context & HoldingA union petitioned the Pennsylvania Labor Relations Board for a determination that maintenance mechanics assigned to prison were included in the prison guard bargaining unit. Lancaster County opposed the union, asserting that maintenance mechanics were instead support staff not included in the prison guard bargaining unit. The Labor Relations Board found that the mechanics were guards for purposes of the Public Employee Relations Act. The Supreme Court held that "the Board's conclusion that the Maintenance Mechanic I and Maintenance Mechanic II positions were 'guards at prisons,' as they supervise inmates and are responsible for the security of inmates as a part of the overall security of the prison, is reasonable, in accord with the Board's consistent interpretation of the statutory term 'guards at prisons,' and is not capricious, arbitrary, or illegal."

Summary of Case Context & HoldingLand Baron Investments, Inc., Michael Chernine, and Robert Black, Jr. (collectively, Land Baron), brought an action against Bonnie Springs Family Limited Partnership, Bonnie Springs Management Company, Alan Levinson, Bonnie Levinson, and April Boone (collectively, Bonnie Springs) in connection with a contract to purchase land from Bonnie Springs for $17,190,000 for the purpose of building a subdivision. Prior to signing the purchase agreement, Land Baron verified that Bonnie Springs had title to the property but did not inquire into water or access rights. Land Baron sought rescission of the contract based on mutual mistake, misrepresentation and nondisclosure when water rights turned out to be difficult to obtain. Bonnie Springs filed counterclaims for abuse of process and nuisance related to Land Baron’s difficulty in obtaining access and water rights for the purchased land. The Supreme Court affirmed in part and reversed in part the decision of the trial court, holding that Land Baron bore the risk of mistake, there was no evidence that Bonnie Springs misrepresented facts, Bonnie Springs was not liable for alleged nondisclosure, there was no evidence that Land Baron had an improper motive as required for abuse of process counterclaim, and sufficient evidence supported an award of damages for the nuisance claim.

Summary of Case Context & HoldingLandrum was sentenced to life in prison without parole for second-degree murder committed when she was 16 years old. This sentence was discretionary for the sentence trial court, and was decided without taking into account the juvenile offender's youth. The Second District Court of appeal upheld the sentence. Landrum appealed, and the Supreme Court found this to be a violation of the Eighth Amendment as "cruel and unusual," pursuant to the U.S. Supreme Court's decision in Miller v. Alabama, 567 U.S. 460 (2012), because a sentence of life without parole for a juvenile defendant must be made with an individualized consideration of one's youth and its attendant characteristics. Subsequently, Landrum's case was remanded for resentencing, requiring individualized consideration of one's youth to be taken into account when giving life without parole sentences.

Summary of Case Context & HoldingThe beneficiary of a life insurance policy brought an action against an insurer for breach of contract by rescinding the policy and refusing to pay the death benefit, and against the medical clinic's medical-records contractor for failing to comply with the limits of the consent the insured provided for the release of his medical records in violation of the Minnesota Health Records Act, Minn. Stat. § 144.293, subd. 10(c). Based on the information supplied in the insured's application, the insurer approved the life insurance policy but once the beneficiary made claim, the insurer discovered that the insured had failed to disclose that he had consulted with a cardiologist and undergone a CAT scan angiogram. The insurer informed the beneficiary that it was rescinding the life insurance policy because it would not have issued the policy if the insured had disclosed that information. The contractor failed to disclose all of the insured's medical records that the medical clinic possessed, among those items being letters related to the insured's consultation with a cardiologist and the results of his CAT scan angiogram. The district court granted summary judgment in favor of the insurer and contractor concluding that the insured's knowledge of and failure to disclose the cardiology consultation and test made his statements willfully false or intentionally misleading as a matter of law, and that a patient does not have a cause of action under the Minnesota Health Records Act unless the release of the patient's medical records exceeds the scope of the patient's consent. The beneficiary appealed and the court of appeals affirmed. The Supreme Court affirmed in part, reversed in part, and remanded, holding that: (1) to rescind a life insurance policy, the insurer was required to prove insured's intent to deceive insurer; (2) an issue of fact existed as to whether the insured's failure to disclose fact that he saw a cardiologist and had a CAT scan angiogram was willfully false or intentionally misleading, so as to permit rescission of life insurance policy, precluding summary judgment; and (3) penalty provision of Minnesota Health Records Act did not create private cause of action for the beneficiary for under-disclosure of medical records.

Summary of Case Context & HoldingIn Montana, if a political party did not have a candidate in either of the last two general elections who received 5% or more of the total votes cast for the last-elected governor, the party may qualify to nominate candidates for public offices by timely submitting a qualified petition to the appropriate county election administrators "signed by a number of registered voters equal to 5% or more of the total votes cast" for the last-elected governor, or 5,000 registered voters, whichever is less. Mont. Code Ann. § 13-10-601. In 2017, two Montana Green Party leaders began gathering signatures to qualify the Green Party for the 2018 elections. Although the leaders were struggling to obtain the requisite number of signatures, Advanced Micro Targeting, a Nevada political consulting firm operating through 13 paid signature gatherers, many from out of state, independently collected an additional 9,461 signatures from four counties. The signature gatherers submitted their signature sheets and accompanying certification affidavits to the respective county election administrators just before expiration of the deadline. Upon examination of the 10,160 signatures submitted, local county election administrators timely certified 7,386 signatures, including signatures from 38 legislative districts, to the Secretary of State (Secretary) as verified, and the Secretary subsequently certified the Green Party as qualified to nominate candidates for public office. Plaintiffs James Larson, Donald Judge, Jean Price, and the Montana Democratic Party filed a complaint seeking declaratory judgment that the act of Secretary certifying the eligibility of the Green Party to nominate candidates for election to public offices in Montana was invalid due to noncompliance with Mont. Code Ann. § 13-10-601. Specifically, Plaintiffs alleged various defects with 210 signatures from nine districts. The District Court found that 87 signatures did not comply with Montana requirements (e.g., false affidavits). The district court also affirmatively enjoined the Secretary to remove the Green Party from Montana's 2018 election ballot. The ruling in effect brought the number of qualifying districts from 38 to 30, below the minimum of 34 districts mandated by Mont. Code Ann. § 13-10-601. Of relevance, and on appeal, the Secretary argued that (1) Plaintiffs did not state a cognizable claim for relief because remedies for non-compliance with Mont. Code Ann. § 13-10-601 are limited to administrative remedies, rather than private right of action, and (2) the issue involved a non-justiciable political question. As to the first item, the Supreme Court held that nothing in the legislative history of the statute, or the statute itself, insulate political party ballot qualification petitions—or the officials charged with administering them—from private actions. As to the second item, the Supreme Court found that adjudication of the legal sufficiency of the Green Party ballot petition in accordance with prescribed statutory processes and standards fell squarely and exclusively in the judicial power granted to the Supreme Court, and did not infringe upon the reserved political power of the people. The Supreme Court also found that the district court had properly invalidated 87 signatures due to noncompliance with Mont. Code Ann. § 13-10-601 due to defects.

Summary of Case Context & HoldingAn employee of Las Vegas Club Hotel & Casino (Casino) began using medical marijuana to treat a disability. A year later, the employee filed an industrial injury claim with the Casino and was directed to report for a drug test. The employee tested positive for marijuana and was terminated by the Casino for violation of its drug and alcohol policy. The employee applied for unemployment benefits, which the employer opposed. The Employment Security Division (ESD) denied the employee's application, concluding that he was discharged for misconduct under NRS 612.385. The employee appealed, and a referee issued a decision reversing the determination that the employee's use of medical marijuana was misconduct concluding that the employee was eligible for benefits. The Supreme Court held that the employer did not provide evidence to show that the employee was aware that his conduct constituted a violation of its policy and therefore the employee's actions did not amount to misconduct.

Summary of Case Context & HoldingThe Las Vegas Police Protective Association Metro, Inc. (LVPPA) claimed that the Las Vegas Metropolitan Police Department (LVMPD) mandated overtime for its employees in violation of their collective bargaining agreement. LVPPA brought suit, asking the district court to find that the agreement could not be interpreted to allow LVMPD to mandate overtime and to grant LVPPA a preliminary injunction to stop LVMPD from mandating overtime. The Supreme Court held that the plain language of the CBA permitted LVMPD to mandate overtime and affirmed the district court's denial of LVPPA's request for declaratory relief and motion to enjoin LVMPD from mandating overtime.

Summary of Case Context & HoldingGeorgia adopted a bill that limited the circumstances under which abortions may be performed. The bill forbade physicians to perform abortions when the probable gestational age of a fetus is 20 months or more unless the pregnancy is medically futile or the abortion is necessary to avoid death or substantial and irreversible physical impairment of the pregnant woman. The law also required that the physician perform the abortion by means that offer the best opportunity for the unborn child to survive. Physicians were also required to report procedures. Weeks before the bill took effect, doctors brought suit against the Governor and 19 other state officers in their official capacities for a declaratory judgment that certain provisions of the bill were unconstitutional under the Georgia Constitution. The lower court dismissed the case, ruling that the claims were barred by sovereign immunity. The Supreme Court affirmed the dismissal, holding that the doctrine of sovereign immunity extends generally to the State and its officials acting in their official capacity for injunctive and declaratory relief that rests on constitutional grounds. The Supreme Court found that the State did not consent to suit in the constitution or a statute. However, the Supreme Court acknowledged other ways by which citizens may obtain relief for unconstitutional acts. These include suit under the Georgia Tort Claims Act, the Georgia Administrative Procedure Act, or suit against state officers in their individual capacities.

Summary of Case Context & HoldingJacob Laurence and his minor son sued Salt River Project Agricultural Improvement & Power District (SRP), a public entity, and its employee John Gabrielson for damages resulting from an accident that occurred when Gabrielson collided with Petitioners' vehicle. Petitioners sued the employee driver for negligent driving and SRP under the respondeat superior doctrine because Gabrielson was driving SRP's truck. In Arizona, plaintiffs intending to sue a public entity or employee must first file a claim with that entity within 180 days after the cause of action accrues. Petitioners filed a timely claim against SRP but were unable to file a claim with Gabrielson until nearly 15 months after the accident. When Petitioners filed this action against SRP and Gabrielson, Gabrielson immediately filed a motion to dismiss based on Petitioners' failure to timely comply with the 180-day rule. The superior court granted the motion as it pertained to Petitioner Jacob, but since the son was a minor, he was not required to file a claim until 180 days after turning eighteen, making his claim timely. SRP moved for partial summary judgment against Petitioner Laurence, arguing based on DeGraff v. Smith, 157 P.2d 342 (Ariz. 1945), that it could not be held vicariously liable for Gabrielson's negligence because the court granted summary judgment for Gabrielson on that claim. Petitioner Laurence argued that because the court had granted summary judgment for reasons unrelated to the merits of the claim, SRP could still be found vicariously liable. The superior court agreed with SRP and granted its motion, and the court of appeals affirmed. The Arizona Supreme Court overturned DeGraff and held that a respondeat superior claim can proceed against an employer if the claim against the employee is dismissed for reasons unrelated to the merits of the case.

Summary of Case Context & HoldingOn November 17, 2020, six individual plaintiffs, all of whom were candidates for presidential electors on behalf of Donald J. Trump, sued a group of candidates for presidential elector chosen by Joseph R. Biden Jr. alleging "statutory violations and voting irregularities" which they argued were sufficient to raise doubt about the outcome of the election and asked the Supreme Court to declare then-President-elect Biden's victory "null and void." Plaintiffs made a number of allegations of voting irregularities including claims that Agilis voting machines produced "highly unusual results," that there were "illegal or improper votes cast and counted," and that the Nevada Native Vote Project improperly offered incentives (such as gift cards, t-shirts) in exchange for votes. Plaintiffs also argued that the use of voting machines to verify signatures violated NRS 293.8874(1) and that election board members were guilty of malfeasance under NRS 293.10(2)(a) due to their "[f]ailing to ensure continuous and proper operation of the voting machines [and f]ailing to protect the integrity of voting information." The district court granted Defendants' motion to dismiss finding Plaintiffs "failed to meet their burden to provide credible and relevant evidence to substantiate any of the grounds set forth in NRS 293.410" because Plaintiffs had no proof of voting device malfunctions, no proof any illegal or improper voters were cast, no proof any election board member was guilty of malfeasance, and no proof that Defendants had given or offered anything of value to manipulate the election outcome. On December 7, Plaintiffs filed an emergency motion to expedite appeal with the Supreme Court seeking review of the District Court's judgment before Nevada sent its six electors to the Electoral College on December 14. On December 8, the Supreme Court affirmed the district court's judgment, holding that "appellants have not demonstrated any legal error in the district court's application of NRS 293.410(2)(c) [and that] the district court's order thoroughly addressed the grounds asserted in the statement of contest filed by appellants."

Summary of Case Context & HoldingIn 2000, Lawrence pled guilty to first-degree murder, conspiracy to commit first-degree murder, providing alcoholic beverages to a person under twenty-one, and abuse of a dead human corps. He was sentenced to death. On appeal, Lawrence argued that his death sentence is disproportionate in comparison to other cases in which the sentence of death has been imposed. The State argued that the Florida Supreme Court should modify its precedent holding that it must review the comparative proportionality of every death sentence to "ensure uniformity of sentencing in death penalty proceedings." In support of its argument, the State contended that comparative proportionality review violates the conformity clause of the Florida Constitution. Notably, the U.S. Supreme Court has held that comparative proportionality review of death sentences is not required by the Eighth Amendment. Pulley v. Harris, 465 U.S. 37, 50-51, (1984). In Yacob v. State, 136 So. 3d 539, 546-49 (Fla. 2014), the Florida Supreme Court addressed whether state-law precedent requiring comparative proportionality review survived the addition of the conformity clause to the Florida Constitution in 2002. In holding that it did, Yacob held that comparative proportionality review flows from (i) Florida's capital punishment statute; (ii) the due process clause of the Florida Constitution; and (iii) Article V, Section 3(b)(1) of the Florida Constitution, which grants the Supreme Court mandatory, exclusive jurisdiction over appeals from final judgments of trial courts imposing the death penalty. Declining to review Lawrence's claim that his death sentence is disproportionate, the Florida Supreme Court receded from Yacob's requirement to review death sentences for comparative proportionality and thus eliminated comparative proportionality review from the scope of appellate review. The Florida Supreme Court reasoned that none of the provisions referenced in Yacob require the comparative proportionality review that the Florida Supreme Court has held to be required and codified in its procedural rules as within the scope of its appellate review.

Summary of Case Context & HoldingIn this case, the Florida Supreme Court addressed whether juvenile defendants can be sentenced to life without parole for non-homicide offenses under a "homicide-case exception," if they also commit a homicide in the same criminal event. In Graham v. Florida, 560 U.S. 48 (2010), the U.S. Supreme Court held that the Eighth Amendment’s prohibition on cruel and unusual punishment compels a categorical rule against sentencing a juvenile offender “to life without parole for a nonhomicide crime.” The Third District read Graham as creating a homicide-case exception to the categorical rule, which would permit a juvenile to be sentenced to life without parole for a nonhomicide offense if the juvenile also committed a homicide in the same criminal episode. Applying this homicide-case exception to the Defendant at issue, the Third District held that Lawton’s life-without-parole sentences for the nonhomicide offenses (committed as a juvenile) of attempted first-degree murder with a firearm and armed robbery with a firearm are constitutional under Graham because Lawton also committed a homicide in the same criminal episode. However, the Florida Supreme Court concluded that the ban on sentencing juveniles to life without parole for nonhomicide offenses is unqualified. As such, the Florida Supreme Court held that Graham’s categorical rule leaves no room for the homicide case exception recognized by Florida's Second, Third, and Fourth District Courts of Appeal, and reiterated the categorical rule under Graham that bars the imposition of a sentence of life imprisonment without the possibility of parole in all circumstances for every juvenile offender convicted of a nonhomicide offense. In the decision on review, the Florida Supreme Court limited its review of the Third District’s decision to its treatment of Lawton’s life-without parole sentences for the nonhomicide crimes Lawton committed in the same criminal episode as the homicide, and did not address Lawton’s homicide sentence.

Summary of Case Context & HoldingIn Arizona, a ballot initiative may be held after filing a petition containing a sufficient number of signatures with the Secretary of State. After a political action committee (PAC) filed a ballot initiative regarding healthcare reform, which on its face had the requisite number of signatures, another PAC challenged the petition. Part of the Arizona law regarding ballot initiatives requires any challenged circulator to respond to a subpoena, otherwise the signatures collected by such circulator are disqualified. During the trial, nearly one hundred challenged circulators did not respond to valid subpoenas, disqualifying their signatures and bringing the total number of signatures collected in the petition below the requisite threshold. The Court concluded that the circulators were not entitled to avoid subpoenas on the basis that they had been "de-registered" as circulators before the subpoenas were served. The initiative was invalidated.

Summary of Case Context & HoldingThe Court granted an emergency petition permitting the use of non-party documents from political consulting firms like Data Targeting, Inc. in a trial challenging the state's redistricting process. These documents, initially claimed to be privileged under the First Amendment, were vital in establishing the behind-the-scenes efforts to manipulate the redistricting process in League of Women Voters of Florida v. Detzner, 172 So. 3d 363 (Fla. 2015).

Summary of Case Context & HoldingIn 2010, Florida voters enacted the Fair Districts Amendment, which outlawed partisan political gerrymandering in Florida. This case was the first challenge to an electoral map under the Fair Districts Amendment. Plaintiffs challenged the 2012 electoral map enacted by the Florida legislature, arguing that the legislature conspired with outside political operatives to produce an electoral map that favored Republicans, including by secretly manipulating a process that was nominally transparent and open to the public. The trial court found that the legislature acted with impermissible partisan intent in drawing the map, but it invalidated only two districts in the map. The Florida Supreme Court affirmed the trial court's finding of impermissible partisan intent, but concluded that the trial court erred in two ways. First, it failed to consider whether the electoral map as a whole was invalid, as opposed to individual districts. Second, it gave inappropriate deference to the legislature's map despite finding that the legislature acted with partisan intent. The Court explained that the burden should have shifted to the legislature to justify its decisions. The Court determined that eight (8) districts must be redrawn and remanded to the trial court for it to order the legislature to redraw the map.

Summary of Case Context & HoldingIn this case, the Florida Supreme Court considered the remedial electoral map drawn following its decision in League of Women Voters of Florida v. Detzner, 172 So. 3d 363 (Fla. 2015). The Florida legislature had deadlocked on an electoral map, with the Florida House of Representatives and Senate unable to agree and separate proposals were submitted to the trial court for approval. The trial court adopted most of the House plan, but as to certain districts adopted a proposal submitted by Plaintiffs. After analyzing each of the districts challenged on appeal, the Florida Supreme Court affirmed the trial court's order and entered the remedial map. The dissent argued that in approving certain districts drawn by Plaintiffs in lieu of those drawn by the legislature, the Court was effectively selecting a map drawn by Democratic operatives, despite the involvement of Republican operatives being the basis for invalidating the original plan.

Summary of Case Context & HoldingThe League of Women Voters of Michigan, a coalition of voting and civil rights advocates and voters filed a petition against the new map for the Michigan House of Representatives adopted by the Independent Citizens Redistricting Commission (the Commission) drawn with 2020 census data. They argue that the map favors Republicans in violation of multiple provisions of the Michigan Constitution. The Plaintiffs ask the court to block the current map and order the creation of a new state House plan. The Supreme Court denied the requested relief and upheld the map, as the Plaintiffs had not sustained their burden to show that the map for the Michigan House of Representatives adopted by the Commission failed to comply with constitutional requirements.