State Supreme Court Data Tracker
Use this data to spot trends, anticipate what’s next, and supercharge your advocacy.
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League of Women Voters of Mich. v. Sec'y of State, 946 N.W.2d 307 (2020); League of Women Voters of Mich. v. Sec'y of State, 948 N.W.2d 70 (2020)
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Michigan | 2020 | Democracy & Voting, Voting Rights |
State:
Michigan
Year:
2020
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe League of Women Voters of Michigan filed a complaint for mandamus challenging the statutory requirement that absent-voter ballots be received by 8:00 p.m. on election day and the statutory requirement that voters pay the postage to return an absent-voter ballot. The court of appeals denied the petition, holding that the received-by deadline and requirement that absentee voters pay return postage were not unconstitutional as they did not impose a severe restriction on the right to vote and were reasonable, nondiscriminatory provisions that protect the integrity and reliability of the electoral process. The application for leave to appeal was denied by the Supreme Court. The Plaintiffs then filed a motion for reconsideration, which was denied by the Supreme Court.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The League of Women Voters of Michigan filed a complaint for mandamus challenging the statutory requirement that absent-voter ballots be received by 8:00 p.m. on election day and the statutory requirement that voters pay the postage to return an absent-voter ballot. The court of appeals denied the petition, holding that the received-by deadline and requirement that absentee voters pay return postage were not unconstitutional as they did not impose a severe restriction on the right to vote and were reasonable, nondiscriminatory provisions that protect the integrity and reliability of the electoral process. The application for leave to appeal was denied by the Supreme Court. The Plaintiffs then filed a motion for reconsideration, which was denied by the Supreme Court.
Link to Opinion
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League of Women Voters of Mich. v. Sec'y of State, 975 N.W.2d 840 (Mich. 2022)
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Michigan | 2022 | Democracy & Voting, Voting Rights |
State:
Michigan
Year:
2022
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe League of Women Voters of Michigan challenged the constitutionality of 2018 PA 608, which changed the procedures for circulating petitions to invoke referendum, initiative, and constitutional-amendment processes. Specifically, it required that no more than 15% of the signatures used to determine the validity of a petition could be from any one congressional district; required petitions to include checkboxes that would indicate whether the circulator of the petition was a paid signature gatherer or a volunteer; and required that paid signature gatherers file a signed affidavit to that effect with the Secretary of State. The Supreme Court held that: (1) the geographic restriction capping the percentage of direct-democracy signatures from any district was unconstitutional because it exceeded the legislature's power to adopt rules implementing Const. 1963, art 2, § 9 and exceeded the Legislature's power under Const. 1963, art 12, § 2 to prescribe the manner of signing and circulating petitions, thus unduly burdening self-executing constitutional procedures; (2) circulators could be required under MCL 168.482(7) to check a box disclosing paid or volunteer status because First Amendment rights were only minimally burdened; and (3) a precirculation affidavit requirement for paid circulators was invalid because it substantially burdened First Amendment activity without advancing state interests. The Supreme Court held that its decision would receive prospective-only effect.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The League of Women Voters of Michigan challenged the constitutionality of 2018 PA 608, which changed the procedures for circulating petitions to invoke referendum, initiative, and constitutional-amendment processes. Specifically, it required that no more than 15% of the signatures used to determine the validity of a petition could be from any one congressional district; required petitions to include checkboxes that would indicate whether the circulator of the petition was a paid signature gatherer or a volunteer; and required that paid signature gatherers file a signed affidavit to that effect with the Secretary of State. The Supreme Court held that: (1) the geographic restriction capping the percentage of direct-democracy signatures from any district was unconstitutional because it exceeded the legislature's power to adopt rules implementing Const. 1963, art 2, § 9 and exceeded the Legislature's power under Const. 1963, art 12, § 2 to prescribe the manner of signing and circulating petitions, thus unduly burdening self-executing constitutional procedures; (2) circulators could be required under MCL 168.482(7) to check a box disclosing paid or volunteer status because First Amendment rights were only minimally burdened; and (3) a precirculation affidavit requirement for paid circulators was invalid because it substantially burdened First Amendment activity without advancing state interests. The Supreme Court held that its decision would receive prospective-only effect.
Link to Opinion
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League of Women Voters of Ohio v. Ohio Redistricting Comm'n, 198 N.E.3d 812 (Ohio 2022)
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Ohio | 2022 | Democracy & Voting, Redistricting/Gerrymandering |
State:
Ohio
Year:
2022
Topics:
Democracy & Voting, Redistricting/Gerrymandering
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingVoters and organizations brought action alleging that the Ohio Redistricting Commission's second revised reapportionment plan for the General Assembly failed to comply with state constitutional anti-gerrymandering provisions. The organizations alleged that the Commission did not include input from its Democratic members, and that the district plan was drawn primarily to favor the Republican Party and to disfavor the Democratic Party. The Supreme Court evaluated the plan adoption timeline, party engagement, and hypothetical results of the map. After reviewing, the Supreme Court held that the main goals of the individuals who drafted the proposal was to favor the Republican Party, and that the proposed plan failed to comply with the state constitutional proportionality requirement. As a result, the Redistricting Commission was ordered to redraw the district lines yet again.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Voters and organizations brought action alleging that the Ohio Redistricting Commission's second revised reapportionment plan for the General Assembly failed to comply with state constitutional anti-gerrymandering provisions. The organizations alleged that the Commission did not include input from its Democratic members, and that the district plan was drawn primarily to favor the Republican Party and to disfavor the Democratic Party. The Supreme Court evaluated the plan adoption timeline, party engagement, and hypothetical results of the map. After reviewing, the Supreme Court held that the main goals of the individuals who drafted the proposal was to favor the Republican Party, and that the proposed plan failed to comply with the state constitutional proportionality requirement. As a result, the Redistricting Commission was ordered to redraw the district lines yet again.
Link to Opinion
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League of Women Voters of Wis. Educ. Network, Inc. v. Walker, 851 N.W.2d 302 (Wis. 2014)
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Wisconsin | 2014 | Democracy & Voting, Voting Rights |
State:
Wisconsin
Year:
2014
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiffs, the League of Women Voters of Wisconsin Education Network, Inc., brought action against state officials, seeking declaratory and injunctive relief, challenging the constitutionality of a statute requiring that potential voters present photo identification prior to voting. This "Act 23" photo ID includes nine acceptable forms of photo identification in order to vote. Generally stated, these include: Wisconsin Department of Transportation (DOT) issued driver's license; DOT issued photo identification card; United States uniformed service identification card; United States passport; United States naturalization certificate issued within two years preceding the election; federally recognized Wisconsin Native American tribe's identification card; Wisconsin university or college student identification card; and a citation or notice of driver's license suspension. The Supreme Court ruled that the legislature did not exceed its authority under Article III of the Wisconsin Constitution when it required electors to present Act 23-acceptable photo identification. Requiring a potential voter to identify themselves as a qualified elector through the use of Act 23-acceptable photo identification (1) does not impose an elector qualification in addition to those set out in Article III, Section 1 of the Wisconsin Constitution; (2) comes within the legislature’s authority to enact laws providing for the registration of electors under Article III, Section 2 because Act 23-acceptable photo identification is the mode by which election officials verify that a potential voter is the elector listed on the registration list; and (3) is a reasonable regulation that could improve and modernize election procedures, safeguard voter confidence in the outcome of elections, and deter voter fraud.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiffs, the League of Women Voters of Wisconsin Education Network, Inc., brought action against state officials, seeking declaratory and injunctive relief, challenging the constitutionality of a statute requiring that potential voters present photo identification prior to voting. This "Act 23" photo ID includes nine acceptable forms of photo identification in order to vote. Generally stated, these include: Wisconsin Department of Transportation (DOT) issued driver's license; DOT issued photo identification card; United States uniformed service identification card; United States passport; United States naturalization certificate issued within two years preceding the election; federally recognized Wisconsin Native American tribe's identification card; Wisconsin university or college student identification card; and a citation or notice of driver's license suspension. The Supreme Court ruled that the legislature did not exceed its authority under Article III of the Wisconsin Constitution when it required electors to present Act 23-acceptable photo identification. Requiring a potential voter to identify themselves as a qualified elector through the use of Act 23-acceptable photo identification (1) does not impose an elector qualification in addition to those set out in Article III, Section 1 of the Wisconsin Constitution; (2) comes within the legislature’s authority to enact laws providing for the registration of electors under Article III, Section 2 because Act 23-acceptable photo identification is the mode by which election officials verify that a potential voter is the elector listed on the registration list; and (3) is a reasonable regulation that could improve and modernize election procedures, safeguard voter confidence in the outcome of elections, and deter voter fraud.
Link to Opinion
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League of Women Voters v. Commonwealth, 178 A.3d 737 (Pa. 2018)
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Pennsylvania | 2018 | Democracy & Voting, Redistricting/Gerrymandering |
State:
Pennsylvania
Year:
2018
Topics:
Democracy & Voting, Redistricting/Gerrymandering
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe League of Women Voters of Pennsylvania sued the Commonwealth challenging the 2011 Congressional plan, as drawn by the state's General Assembly, as an unconstitutional partisan gerrymander under the state constitution. The Supreme Court found the congressional maps unconstitutional in that they deprived voters of the right to a free and fair election by unnecessarily splitting municipalities and subordinating traditional redistricting criteria to create partisan gain. The Supreme Court ordered the General Assembly to redraw the maps, which were subsequently rejected by then-Governor Tom Wolf. New maps were eventually redrawn by the Supreme Court for the 2018 elections.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The League of Women Voters of Pennsylvania sued the Commonwealth challenging the 2011 Congressional plan, as drawn by the state's General Assembly, as an unconstitutional partisan gerrymander under the state constitution. The Supreme Court found the congressional maps unconstitutional in that they deprived voters of the right to a free and fair election by unnecessarily splitting municipalities and subordinating traditional redistricting criteria to create partisan gain. The Supreme Court ordered the General Assembly to redraw the maps, which were subsequently rejected by then-Governor Tom Wolf. New maps were eventually redrawn by the Supreme Court for the 2018 elections.
Link to Opinion
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Lee v. State, 258 So. 3d 1297 (Fla. 2018)
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Florida | 2018 | Criminal Justice |
State:
Florida
Year:
2018
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingLee placed an ad on Craigslist, and an investigator presenting himself as Matt responded. Lee and Matt began communicating. "Matt" informed Lee that he was 14 years old, and Lee asked "Matt" to meet in person. When Lee arrived, he was arrested by law enforcement. Lee was charged and convicted with one count of traveling to meet a minor to engage in sexual conduct, one count of unlawful use of a two-way communications device to facilitate the commission of a felony, and one count of using a computer to facilitate or solicit the sexual conduct of a child. Lee argued that counts two and three violated double jeopardy. The issue in this case is whether, in determining if multiple convictions of solicitation of a minor, unlawful use of a two-way communications device, and traveling after solicitation of a minor are based upon the same conduct for purposes of double jeopardy, the reviewing court should consider only the charging document or the entire evidentiary record. The Supreme Court concluded that the reviewing court should consider the charging document, not the entire evidentiary record. Here, the information in the charging document did not make clear that the State relied on separate conduct to charge the offenses, and as a result, the Supreme Court vacated Lee's convictions of solicitation of a minor and unlawful use of a two-way communications device.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Lee placed an ad on Craigslist, and an investigator presenting himself as Matt responded. Lee and Matt began communicating. "Matt" informed Lee that he was 14 years old, and Lee asked "Matt" to meet in person. When Lee arrived, he was arrested by law enforcement. Lee was charged and convicted with one count of traveling to meet a minor to engage in sexual conduct, one count of unlawful use of a two-way communications device to facilitate the commission of a felony, and one count of using a computer to facilitate or solicit the sexual conduct of a child. Lee argued that counts two and three violated double jeopardy. The issue in this case is whether, in determining if multiple convictions of solicitation of a minor, unlawful use of a two-way communications device, and traveling after solicitation of a minor are based upon the same conduct for purposes of double jeopardy, the reviewing court should consider only the charging document or the entire evidentiary record. The Supreme Court concluded that the reviewing court should consider the charging document, not the entire evidentiary record. Here, the information in the charging document did not make clear that the State relied on separate conduct to charge the offenses, and as a result, the Supreme Court vacated Lee's convictions of solicitation of a minor and unlawful use of a two-way communications device.
Link to Opinion
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Leibsohn v. Hobbs, 517 P.3d 45 (Ariz. 2022)
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Arizona | 2022 | Democracy & Voting |
State:
Arizona
Year:
2022
Topics:
Democracy & Voting
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingLeibsohn and others challenged a substantial number of signatures gathered in support of the Voters' Right to Know Act's placement on the statewide initiative ballot. Plaintiffs claimed that certain circulators paid by the sponsoring committee to gather signatures did not strictly comply with two registration requirements, thereby subjecting the gathered signatures to disqualification. The trial court dismissed the claims and Plaintiffs appealed to the Arizona Supreme Court. The Arizona Supreme Court affirmed the trial court's dismissal. First, contrary to the argument of the Plaintiffs, circulator registration did not require a unit number under the term "residence address." Second, the registration statute requires circulators to submit a new affidavit for each petition they intend to circulate. The circulators did not comply with this requirement and the signatures gathered would typically be disqualified for failure to strictly comply. However, the Secretary of State's (Secretary) procedures for registration did not allow for the submission of multiple affidavits and the circulators were also required to comply with the Secretary's procedures. Therefore, the Court ruled that it would "'unreasonably hinder or restrict' the constitutionally guaranteed right to engage in the initiative process" were they to disqualify the signatures because it was the Secretary's incorrect treatment of only allowing for one circulator affidavit, combined with the fact that the Secretary does not accept paper affidavits, that prevented compliance with 19-118(B). The Court noted that the legislature required the Committee to follow the Secretary's procedures and the Committee did so and that "[d]isqualifying signatures for adhering to the Secretary's registration requirements would be tantamount to blessing a trap laid for unwary sponsoring committees."
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Justice Vote Breakdown
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Summary of Case Context & Holding
Leibsohn and others challenged a substantial number of signatures gathered in support of the Voters' Right to Know Act's placement on the statewide initiative ballot. Plaintiffs claimed that certain circulators paid by the sponsoring committee to gather signatures did not strictly comply with two registration requirements, thereby subjecting the gathered signatures to disqualification. The trial court dismissed the claims and Plaintiffs appealed to the Arizona Supreme Court. The Arizona Supreme Court affirmed the trial court's dismissal. First, contrary to the argument of the Plaintiffs, circulator registration did not require a unit number under the term "residence address." Second, the registration statute requires circulators to submit a new affidavit for each petition they intend to circulate. The circulators did not comply with this requirement and the signatures gathered would typically be disqualified for failure to strictly comply. However, the Secretary of State's (Secretary) procedures for registration did not allow for the submission of multiple affidavits and the circulators were also required to comply with the Secretary's procedures. Therefore, the Court ruled that it would "'unreasonably hinder or restrict' the constitutionally guaranteed right to engage in the initiative process" were they to disqualify the signatures because it was the Secretary's incorrect treatment of only allowing for one circulator affidavit, combined with the fact that the Secretary does not accept paper affidavits, that prevented compliance with 19-118(B). The Court noted that the legislature required the Committee to follow the Secretary's procedures and the Committee did so and that "[d]isqualifying signatures for adhering to the Secretary's registration requirements would be tantamount to blessing a trap laid for unwary sponsoring committees."
Link to Opinion
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Libby v. Eighth Jud. Dist. Ct., 325 P.3d 1276 (Nev. 2014)
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Nevada | 2014 | Health Care, Public Health |
State:
Nevada
Year:
2014
Topics:
Health Care, Public Health
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2005, Libby, an orthopedic surgeon, performed surgery on Margaret Hamilton's left knee. After the surgery, an infection developed in the knee. A year later, Libby performed a second surgery on Hamilton's knee to remove material that was impeding antibiotics in treating the infection. Hamilton's knee would be operated on twice more by other doctors, both times removing further material that tested positive for the infection. A little more than a year after the final surgery, and four years after the second surgery by Libby, Hamilton sued Libby for medical malpractice. Libby filed a motion for summary judgment, arguing that under Nevada law, medical malpractice claims are time-barred three years after treatment. The district court denied the motion, as the infected material that was removed from the knee was not discovered until three years had already passed. On appeal, the Supreme Court considered whether the three-year clock for medical malpractice claims lasts three years after the injurious treatment, or three years after the result of the injurious treatment is discovered. The Court reviewed Californian jurisprudence on the matter and held that the three-year period for medical malpractice claims begins to run once there is an "appreciable manifestation" of a resulting injury. Therefore, the Court held that Hamilton's claim was time-barred, as the statute of limitations began to run once Hamilton understood that her infection persisted despite the second surgery. Further, while Nevada law permits the tolling of the statute of limitations for any period that a health care provider has concealed any act, the Court held that no evidence was presented that would indicate that any "intentional act" was committed by Libby that would permit the tolling of the three-year period.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 2005, Libby, an orthopedic surgeon, performed surgery on Margaret Hamilton's left knee. After the surgery, an infection developed in the knee. A year later, Libby performed a second surgery on Hamilton's knee to remove material that was impeding antibiotics in treating the infection. Hamilton's knee would be operated on twice more by other doctors, both times removing further material that tested positive for the infection. A little more than a year after the final surgery, and four years after the second surgery by Libby, Hamilton sued Libby for medical malpractice. Libby filed a motion for summary judgment, arguing that under Nevada law, medical malpractice claims are time-barred three years after treatment. The district court denied the motion, as the infected material that was removed from the knee was not discovered until three years had already passed. On appeal, the Supreme Court considered whether the three-year clock for medical malpractice claims lasts three years after the injurious treatment, or three years after the result of the injurious treatment is discovered. The Court reviewed Californian jurisprudence on the matter and held that the three-year period for medical malpractice claims begins to run once there is an "appreciable manifestation" of a resulting injury. Therefore, the Court held that Hamilton's claim was time-barred, as the statute of limitations began to run once Hamilton understood that her infection persisted despite the second surgery. Further, while Nevada law permits the tolling of the statute of limitations for any period that a health care provider has concealed any act, the Court held that no evidence was presented that would indicate that any "intentional act" was committed by Libby that would permit the tolling of the three-year period.
Link to Opinion
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Lieupo v. Simon's Trucking, Inc., 286 So. 3d 143 (Fla. 2019)
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Florida | 2019 | Environment, Climate Change/Global Warming/Emissions |
State:
Florida
Year:
2019
Topics:
Environment, Climate Change/Global Warming/Emissions
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingWhile arranging to tow a tractor-trailer owned by Simon's Trucking, Charles Lieupo came into contact with battery acid that had spilled from the tractor-trailer’s cargo and suffered serious bodily injury. Lieupo brought a claim for personal injury damages against Simon's Trucking under Florida’s 1983 Water Quality Assurance Act (1983 Act), which imposes strict liability for damages caused by the discharge of certain pollutants. At trial, Simon’s Trucking argued that “all damages” as used by the 1983 Act (Fla. Stat. § 376.313(3)) did not include personal injuries and that Lieupo could not seek recovery. The trial court disagreed, allowing the case to continue to trial where the jury awarded damages. The appellate court reversed the trial court’s decision, using the definition of “damages” under Florida's 1970 Pollutant Discharge Prevention and Control Act (1970 Act). The Supreme Court reversed the appellate court's decision, holding that the 1970 Act’s definition of “damages” did not apply to actions brought under the 1983 Act, and that, instead, “damages” as used in the 1983 Act should be defined by its plain meaning (plainly, “all damages” includes personal injury damages). Looking at the legislative history, the Court explained that, in 1990 and 1996, the Legislature restricted the 1970 Act's definition by excluding personal injury damages and limiting its applicability to causes of action brought under the 1970 Act. Because Lieupo filed suit under the 1983 Act, the 1970 Act did not apply. The Supreme Court further noted that if the plain meaning of “all damages” is overly broad, that it would be the Legislature's responsibility to address the issue by expanding the statutes to which the limited definition of the 1970 Act applies.
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Justice Vote Breakdown
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Summary of Case Context & Holding
While arranging to tow a tractor-trailer owned by Simon's Trucking, Charles Lieupo came into contact with battery acid that had spilled from the tractor-trailer’s cargo and suffered serious bodily injury. Lieupo brought a claim for personal injury damages against Simon's Trucking under Florida’s 1983 Water Quality Assurance Act (1983 Act), which imposes strict liability for damages caused by the discharge of certain pollutants. At trial, Simon’s Trucking argued that “all damages” as used by the 1983 Act (Fla. Stat. § 376.313(3)) did not include personal injuries and that Lieupo could not seek recovery. The trial court disagreed, allowing the case to continue to trial where the jury awarded damages. The appellate court reversed the trial court’s decision, using the definition of “damages” under Florida's 1970 Pollutant Discharge Prevention and Control Act (1970 Act). The Supreme Court reversed the appellate court's decision, holding that the 1970 Act’s definition of “damages” did not apply to actions brought under the 1983 Act, and that, instead, “damages” as used in the 1983 Act should be defined by its plain meaning (plainly, “all damages” includes personal injury damages). Looking at the legislative history, the Court explained that, in 1990 and 1996, the Legislature restricted the 1970 Act's definition by excluding personal injury damages and limiting its applicability to causes of action brought under the 1970 Act. Because Lieupo filed suit under the 1983 Act, the 1970 Act did not apply. The Supreme Court further noted that if the plain meaning of “all damages” is overly broad, that it would be the Legislature's responsibility to address the issue by expanding the statutes to which the limited definition of the 1970 Act applies.
Link to Opinion
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Lisle v. State, 351 P.3d 725 (Nev. 2015)
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Nevada | 2015 | Criminal Justice, Death Penalty |
State:
Nevada
Year:
2015
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant Kevin James Lisle was convicted and sentenced to death for first-degree murder with a deadly weapon arising from his drive-by-shooting of a victim. Here, Lisle sought postconviction habeas relief from the death penalty. Lisle was unable to demonstrate good cause to excuse his otherwise procedurally barred petition, so he needed to qualify for the actual innocence exception to obtain relief. To do so, Lisle presented new mitigation evidence. As a matter of first impression, the Court considered whether the actual-innocence inquiry should focus on the objective factors that make a defendant eligible for the death penalty or on mitigating evidence. Finding Sawyer v. Whitley, 505 U.S. 333 (1992) persuasive, the Court held that "an actual-innocence inquiry in Nevada must focus on the objective factors that make a defendant eligible for the death penalty," not on mitigating evidence, reasoning that this tailored definition aligned with the statutory scheme for procedural defaults. In dissent, Justices Cherry and Saitta argue that the majority contravenes the plain meaning of the statute in favor of policy concerns in an effort to make post-conviction proceedings "workable." But as the dissent stated, "if to make the death penalty and its attendant post-conviction proceedings 'workable' means that we ignore new evidence that demonstrates that a defendant should not have been sentenced to death, then perhaps the death penalty itself is not workable." Because the dissent found the mitigation was convincing that Lisle was not death-eligible, the dissent would have remanded the case to the district court for an evidentiary hearing on the mitigation evidence.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant Kevin James Lisle was convicted and sentenced to death for first-degree murder with a deadly weapon arising from his drive-by-shooting of a victim. Here, Lisle sought postconviction habeas relief from the death penalty. Lisle was unable to demonstrate good cause to excuse his otherwise procedurally barred petition, so he needed to qualify for the actual innocence exception to obtain relief. To do so, Lisle presented new mitigation evidence. As a matter of first impression, the Court considered whether the actual-innocence inquiry should focus on the objective factors that make a defendant eligible for the death penalty or on mitigating evidence. Finding Sawyer v. Whitley, 505 U.S. 333 (1992) persuasive, the Court held that "an actual-innocence inquiry in Nevada must focus on the objective factors that make a defendant eligible for the death penalty," not on mitigating evidence, reasoning that this tailored definition aligned with the statutory scheme for procedural defaults. In dissent, Justices Cherry and Saitta argue that the majority contravenes the plain meaning of the statute in favor of policy concerns in an effort to make post-conviction proceedings "workable." But as the dissent stated, "if to make the death penalty and its attendant post-conviction proceedings 'workable' means that we ignore new evidence that demonstrates that a defendant should not have been sentenced to death, then perhaps the death penalty itself is not workable." Because the dissent found the mitigation was convincing that Lisle was not death-eligible, the dissent would have remanded the case to the district court for an evidentiary hearing on the mitigation evidence.
Link to Opinion
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Lloyd v. Bailey, 781 S.E.2d 24 (N.C. 2016)
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North Carolina | 2016 | Labor, Employment & Economic Justice |
State:
North Carolina
Year:
2016
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff was a Deputy Sheriff who brought suit against the Sheriff for wrongful termination in violation of public policy, alleging that he was fired because he had not contributed to the Sheriff's campaign for reelection. In return, the Defendant Sheriff denied the allegations and asserted the defense of sovereign immunity. The Supreme Court held the Plaintiff's suit failed for the same reasons as in Young v. Bailey, 781 S.E.2d 277 (N.C. 2016) (holding that a deputy sheriff is not a county employee as such term is defined in NCGS section 153A-99 and therefore is not entitled to the statute's protections).
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiff was a Deputy Sheriff who brought suit against the Sheriff for wrongful termination in violation of public policy, alleging that he was fired because he had not contributed to the Sheriff's campaign for reelection. In return, the Defendant Sheriff denied the allegations and asserted the defense of sovereign immunity. The Supreme Court held the Plaintiff's suit failed for the same reasons as in Young v. Bailey, 781 S.E.2d 277 (N.C. 2016) (holding that a deputy sheriff is not a county employee as such term is defined in NCGS section 153A-99 and therefore is not entitled to the statute's protections).
Link to Opinion
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Loch v. State, 621 S.W.3d 279 (Tex. Crim. App. 2021)
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Texas | 2021 | Immigration, Deportation, Criminal Justice |
State:
Texas
Year:
2021
Topics:
Immigration, Deportation, Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant Vith Loch, a Cambodian national, pled guilty to murder in 2016 at both his pre-trial arraignment and later before a jury, and received a life sentence. The trial court did not specifically admonish Loch before his pleas about the possibility that the plea might result in Loch’s deportation. Instead the court gave only a “perfunctory pre-plea admonishment that included only the range of punishment” Loch faced. Loch appealed on the ground that the trial court violated Texas Code of Criminal Procedure Article 26.13(a)(4), which requires courts to admonish non-citizen defendants that their guilty pleas may “result in deportation, the exclusion from admission to this country, or the denial of naturalization under federal law.” The court of appeals reversed and remanded, finding (1) the trial court erred by failing to include the immigration consequences in the admonishment; and (2) the error was harmful because Loch’s decision to plead guilty would potentially have changed had the trial court admonished him of the possible deportation consequences of his guilty plea. The government appealed, and the Texas Criminal Court of Appeals reversed, finding that there was error, but the error was harmless. The Criminal Court of Appeals reasoned that the failure to admonish was a non-constitutional error subject to harmless error analysis, such that any error not affecting “substantial rights” must be disregarded. The “substantial rights” analysis requires independent examination of the record as a whole to answer the question of whether the Court has “a fair assurance that the defendant's decision to plead guilty would not have changed had the court admonished him.” The “fair assurance” inquiry, in turn, involves “(1) whether an appellant knew the consequences of his plea; (2) the strength of the evidence of an appellant's guilt; and (3) an appellant's citizenship and immigration status.” The Court noted that previous decisions had found harmless error where it could definitively determine whether the defendant would be deported (e.g., if the defendant was a citizen and not deportable, or if the defendant was already “unavoidably deportable” regardless of the plea). Turning to Loch’s case, the Court found there existed a “strong likelihood of Appellant’s removal” before the guilty plea due to (1) several prior convictions, including felonies in both Florida and Texas; and (2) the fact that the federal government had filed a U.S. Immigration and Customs Enforcement (ICE) detainer seeking to remove Loch as early as 2005, and that the detainer existed as late as 2015. Based on the pre-existing strong likelihood of deportation, as well as “the fact that the evidence of guilt in this case was strong,” the Court concluded that even if Loch had been admonished, there was “fair assurance” that the admonishment would not have impacted his decision to plead guilty. Accordingly, the Court reversed the court of appeals’ decision.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant Vith Loch, a Cambodian national, pled guilty to murder in 2016 at both his pre-trial arraignment and later before a jury, and received a life sentence. The trial court did not specifically admonish Loch before his pleas about the possibility that the plea might result in Loch’s deportation. Instead the court gave only a “perfunctory pre-plea admonishment that included only the range of punishment” Loch faced. Loch appealed on the ground that the trial court violated Texas Code of Criminal Procedure Article 26.13(a)(4), which requires courts to admonish non-citizen defendants that their guilty pleas may “result in deportation, the exclusion from admission to this country, or the denial of naturalization under federal law.” The court of appeals reversed and remanded, finding (1) the trial court erred by failing to include the immigration consequences in the admonishment; and (2) the error was harmful because Loch’s decision to plead guilty would potentially have changed had the trial court admonished him of the possible deportation consequences of his guilty plea. The government appealed, and the Texas Criminal Court of Appeals reversed, finding that there was error, but the error was harmless. The Criminal Court of Appeals reasoned that the failure to admonish was a non-constitutional error subject to harmless error analysis, such that any error not affecting “substantial rights” must be disregarded. The “substantial rights” analysis requires independent examination of the record as a whole to answer the question of whether the Court has “a fair assurance that the defendant's decision to plead guilty would not have changed had the court admonished him.” The “fair assurance” inquiry, in turn, involves “(1) whether an appellant knew the consequences of his plea; (2) the strength of the evidence of an appellant's guilt; and (3) an appellant's citizenship and immigration status.” The Court noted that previous decisions had found harmless error where it could definitively determine whether the defendant would be deported (e.g., if the defendant was a citizen and not deportable, or if the defendant was already “unavoidably deportable” regardless of the plea). Turning to Loch’s case, the Court found there existed a “strong likelihood of Appellant’s removal” before the guilty plea due to (1) several prior convictions, including felonies in both Florida and Texas; and (2) the fact that the federal government had filed a U.S. Immigration and Customs Enforcement (ICE) detainer seeking to remove Loch as early as 2005, and that the detainer existed as late as 2015. Based on the pre-existing strong likelihood of deportation, as well as “the fact that the evidence of guilt in this case was strong,” the Court concluded that even if Loch had been admonished, there was “fair assurance” that the admonishment would not have impacted his decision to plead guilty. Accordingly, the Court reversed the court of appeals’ decision.
Link to Opinion
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Lofton v. State, 854 S.E.2d 690 (Ga. 2021)
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Georgia | 2021 | Criminal Justice, Access to Justice |
State:
Georgia
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA jury found the Defendant guilty of malice murder and possession of a firearm in connection with a shooting death. Notably, the trial court denied the Defendant's request to suppress cell phone records to which Defendant challenged on appeal. The Defendant argued that when the detective acquired his cell phone records, including four days of historical cell-site location information (CSLI), a search under the Fourth Amendment occurred, since a cell phone user has a reasonable expectation of privacy in historical CSLI. The Supreme Court disagreed. At the time of Defendant's 2014 trial, there was no applicable precedent in Georgia holding that a request for cell phone records constituted a search under the Fourth Amendment and the U.S. Supreme Court had not yet decided Carpenter v. United States, 585 U.S. 296 (2018), where it held that a warrantless acquisition of CSLI records violated the defendant's Fourth Amendment right against unreasonable searches and seizures, since the tracking of movements via cell-site records encroaches on a person's reasonable expectation of privacy. Without binding precedent, the Supreme Court found that it was objectively reasonable for the officer to rely on the applicable statute at the time and request records for a cell phone number used by a murder suspect, particularly when the request was made less than a day after the murder while the effort to apprehend the suspect was in process. Because the applicable statute authorized the officer's conduct at issue, the Supreme Court found that reversing the lower court's decision would not have any deterring effect against future Carpenter violations and therefore affirmed.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A jury found the Defendant guilty of malice murder and possession of a firearm in connection with a shooting death. Notably, the trial court denied the Defendant's request to suppress cell phone records to which Defendant challenged on appeal. The Defendant argued that when the detective acquired his cell phone records, including four days of historical cell-site location information (CSLI), a search under the Fourth Amendment occurred, since a cell phone user has a reasonable expectation of privacy in historical CSLI. The Supreme Court disagreed. At the time of Defendant's 2014 trial, there was no applicable precedent in Georgia holding that a request for cell phone records constituted a search under the Fourth Amendment and the U.S. Supreme Court had not yet decided Carpenter v. United States, 585 U.S. 296 (2018), where it held that a warrantless acquisition of CSLI records violated the defendant's Fourth Amendment right against unreasonable searches and seizures, since the tracking of movements via cell-site records encroaches on a person's reasonable expectation of privacy. Without binding precedent, the Supreme Court found that it was objectively reasonable for the officer to rely on the applicable statute at the time and request records for a cell phone number used by a murder suspect, particularly when the request was made less than a day after the murder while the effort to apprehend the suspect was in process. Because the applicable statute authorized the officer's conduct at issue, the Supreme Court found that reversing the lower court's decision would not have any deterring effect against future Carpenter violations and therefore affirmed.
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Love v. State, 286 So. 3d 177 (Fla. 2019)
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Florida | 2019 | Criminal Justice, Access to Justice |
State:
Florida
Year:
2019
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingLove shot Thomas Lane as he was about to hit her daughter. Love was charged with one count of attempted second degree murder, and she invoked the Stand Your Ground law (immunity from criminal prosecution and civil action for justifiable use of deadly force upon the reasonable belief that such force is necessary to prevent imminent death or great bodily harm to himself or herself or another). The issue in this case was whether Florida Stautute Section 776.032(4) which effective in June 2017 altered the burden of proof at pretrial immunity hearings under Florida’s Stand Your Ground law, applies to pending cases involving criminal conduct alleged to have been committed prior to the effective date of the statute. The district courts framed this issue as presenting a “retroactivity” question that itself turns on whether section 776.032(4) is procedural or substantive. The Third District Court of Appeal concluded that Section 776.032(4) was “a substantive change in the law and, therefore, does not apply retroactively,” and that article X, section 9 of the Florida Constitution precluded the statute from being applied retroactively. According to the Third District, this lack of retroactivity meant that Section 776.032(4) was inapplicable in the case, even though the Defendant’s immunity hearing took place after the statute went into effect. Reversing the Third District's holding, the Supreme Court ultimately determined that Section 776.032(4) is a procedural change and is not categorically barred by article X, section 9 from applying in pending cases. Specifically, Section 776.032(4) applies to all Stand Your Ground immunity hearings conducted on or after the statute’s effective date. The Supreme Court then explained that applying Section 776.032(4) in a pending case does not entail a retroactive application of the statute. As applied to this case, the pretrial hearing took place after the effective date of Section 776.032(4) and should have been conducted under the new standard.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Love shot Thomas Lane as he was about to hit her daughter. Love was charged with one count of attempted second degree murder, and she invoked the Stand Your Ground law (immunity from criminal prosecution and civil action for justifiable use of deadly force upon the reasonable belief that such force is necessary to prevent imminent death or great bodily harm to himself or herself or another). The issue in this case was whether Florida Stautute Section 776.032(4) which effective in June 2017 altered the burden of proof at pretrial immunity hearings under Florida’s Stand Your Ground law, applies to pending cases involving criminal conduct alleged to have been committed prior to the effective date of the statute. The district courts framed this issue as presenting a “retroactivity” question that itself turns on whether section 776.032(4) is procedural or substantive. The Third District Court of Appeal concluded that Section 776.032(4) was “a substantive change in the law and, therefore, does not apply retroactively,” and that article X, section 9 of the Florida Constitution precluded the statute from being applied retroactively. According to the Third District, this lack of retroactivity meant that Section 776.032(4) was inapplicable in the case, even though the Defendant’s immunity hearing took place after the statute went into effect. Reversing the Third District's holding, the Supreme Court ultimately determined that Section 776.032(4) is a procedural change and is not categorically barred by article X, section 9 from applying in pending cases. Specifically, Section 776.032(4) applies to all Stand Your Ground immunity hearings conducted on or after the statute’s effective date. The Supreme Court then explained that applying Section 776.032(4) in a pending case does not entail a retroactive application of the statute. As applied to this case, the pretrial hearing took place after the effective date of Section 776.032(4) and should have been conducted under the new standard.
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Lunsford v. Sterilite of Ohio, L.L.C., 165 N.E.3d 245 (Ohio 2020)
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Ohio | 2020 | Labor, Employment & Economic Justice |
State:
Ohio
Year:
2020
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingRespondent Sterilite maintained a workplace substance abuse policy under which Sterilite could require an employee to submit to drug testing when investigating an incident, when under suspicion of drug use, or periodically and randomly. The policy stated that urinalysis would be the method used for the drug test but made no mention of how the urine sample would be collected. Failure to produce a sample, or testing positive, could result in discipline or termination. In 2016, the company began using a "direct observation method" for collecting urine samples, meaning a same-sex monitor from Sterilite's drug test vendor U.S. Healthworks was required to accompany the employee to the restroom and actually visually observe the employee produce the urine sample. Under this new policy, three appellees were selected for random drug tests and a further fourth was selected based on the reasonable-suspicion-of-impairment provision. Each of the Plaintiffs signed a consent form agreeing to "any testing necessary" shortly before testing, though the release did not disclose that Sterilite intended to move to direct observation testing. Employees were only learned about the required observation once they arrived at the restrooms. Two Plaintiffs produced samples, while two others did not and were fired. These four employees sued Sterilite and its vendor U.S. Healthworks for asserting invasion of privacy and wrongful discharge in violation of public policy claims. On privacy, the Plaintiffs assert the common law privacy tort of intrusion on seclusion.
The Supreme Court found for Sterilite because (i) the at-will employment relationship required compliance with Sterilite’s workplace substance abuse policy; (ii) no Fourth Amendment protections, Ohio statutes, or constitutional provisions attach due to Sterilite’s status as a private company; and (iii) the employees willingly consented to the direct observation method, waiving their right to privacy. The Supreme Court found that the employees consented to the direct observation when they were informed at the testing cite and continued with the testing. It rejected the argument that the production of samples was coercive, as Ohio is an at-will state, and the testing procedure was not contrary to law or otherwise discriminatory towards a protected class.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Respondent Sterilite maintained a workplace substance abuse policy under which Sterilite could require an employee to submit to drug testing when investigating an incident, when under suspicion of drug use, or periodically and randomly. The policy stated that urinalysis would be the method used for the drug test but made no mention of how the urine sample would be collected. Failure to produce a sample, or testing positive, could result in discipline or termination. In 2016, the company began using a "direct observation method" for collecting urine samples, meaning a same-sex monitor from Sterilite's drug test vendor U.S. Healthworks was required to accompany the employee to the restroom and actually visually observe the employee produce the urine sample. Under this new policy, three appellees were selected for random drug tests and a further fourth was selected based on the reasonable-suspicion-of-impairment provision. Each of the Plaintiffs signed a consent form agreeing to "any testing necessary" shortly before testing, though the release did not disclose that Sterilite intended to move to direct observation testing. Employees were only learned about the required observation once they arrived at the restrooms. Two Plaintiffs produced samples, while two others did not and were fired. These four employees sued Sterilite and its vendor U.S. Healthworks for asserting invasion of privacy and wrongful discharge in violation of public policy claims. On privacy, the Plaintiffs assert the common law privacy tort of intrusion on seclusion.
The Supreme Court found for Sterilite because (i) the at-will employment relationship required compliance with Sterilite’s workplace substance abuse policy; (ii) no Fourth Amendment protections, Ohio statutes, or constitutional provisions attach due to Sterilite’s status as a private company; and (iii) the employees willingly consented to the direct observation method, waiving their right to privacy. The Supreme Court found that the employees consented to the direct observation when they were informed at the testing cite and continued with the testing. It rejected the argument that the production of samples was coercive, as Ohio is an at-will state, and the testing procedure was not contrary to law or otherwise discriminatory towards a protected class.
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Lutkauskas v. Ricker, 28 N.E.3d 727 (Ill. 2015)
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Illinois | 2015 | Education, Access to Education/Funding |
State:
Illinois
Year:
2015
Topics:
Education, Access to Education/Funding
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiffs were resident taxpayers bringing a derivative action on behalf of the School District against specific officers and employees of the School District as well as members of the Board of Education. Plaintiffs alleged that the Defendants misappropriated funds from the school district's "Working Cash Fund," which was used for school district expenditures. The school board was authorized to use the Working Cash Fund for "any and all school purposes." In April of 2010, the school board passed a resolution abolishing the Working Cash Fund, and Plaintiffs brought suit claiming that the board improperly transferred and unlawfully diverted money out of the Working Cash Fund. As relief, the Plaintiffs sought the removal of the school officials who had control over the funds, monetary relief to make the School District whole, and fines under Illinois law. The circuit court ruled that only the State has the power to seek removal of public employees or fines for violative use of Working Cash Funds, and that a suit brought by private taxpayers on behalf of a school district may only properly seek recovery of funds. The Court held that in order to bring a cause of action for this issue, Plaintiffs must have alleged that the improperly transferred funds were used for an invalid purpose. Further, the improper use of the funds must have resulted in an actual loss to the school district. There was no evidence presented that suggested the funds were improperly used or caused any loss to the school district. Accordingly, the statutory violations asserted were dismissed.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiffs were resident taxpayers bringing a derivative action on behalf of the School District against specific officers and employees of the School District as well as members of the Board of Education. Plaintiffs alleged that the Defendants misappropriated funds from the school district's "Working Cash Fund," which was used for school district expenditures. The school board was authorized to use the Working Cash Fund for "any and all school purposes." In April of 2010, the school board passed a resolution abolishing the Working Cash Fund, and Plaintiffs brought suit claiming that the board improperly transferred and unlawfully diverted money out of the Working Cash Fund. As relief, the Plaintiffs sought the removal of the school officials who had control over the funds, monetary relief to make the School District whole, and fines under Illinois law. The circuit court ruled that only the State has the power to seek removal of public employees or fines for violative use of Working Cash Funds, and that a suit brought by private taxpayers on behalf of a school district may only properly seek recovery of funds. The Court held that in order to bring a cause of action for this issue, Plaintiffs must have alleged that the improperly transferred funds were used for an invalid purpose. Further, the improper use of the funds must have resulted in an actual loss to the school district. There was no evidence presented that suggested the funds were improperly used or caused any loss to the school district. Accordingly, the statutory violations asserted were dismissed.
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M.E. v. T.J., 869 S.E.2d 624 (N.C. 2022)
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North Carolina | 2022 | LGBTQ+ Rights, LGBTQ+ Discrimination |
State:
North Carolina
Year:
2022
Topics:
LGBTQ+ Rights, LGBTQ+ Discrimination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA woman in a same-sex relationship was unable to receive a domestic violence protection order after a former partner became physically and emotionally threatening. North Carolina state law limited these protections only to parties in a dating relationship with "persons of opposite sex." The Supreme Court affirmed the court of appeals' decision, holding the statute, Chapter 50B, as unconstitutional under both the North Carolina Constitution and the Fourteenth Amendment of the U.S. Constitution. The Supreme Court established that LGBTQ+ couples cannot be excluded from receiving domestic violence protections in the state of North Carolina.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A woman in a same-sex relationship was unable to receive a domestic violence protection order after a former partner became physically and emotionally threatening. North Carolina state law limited these protections only to parties in a dating relationship with "persons of opposite sex." The Supreme Court affirmed the court of appeals' decision, holding the statute, Chapter 50B, as unconstitutional under both the North Carolina Constitution and the Fourteenth Amendment of the U.S. Constitution. The Supreme Court established that LGBTQ+ couples cannot be excluded from receiving domestic violence protections in the state of North Carolina.
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M.U. By and Through Kelly U. v. Team Ill. Hockey Club, Inc., 240 N.E.3d 466 (III. 2024)
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Illinois | 2024 | Civil Rights, Disability |
State:
Illinois
Year:
2024
Topics:
Civil Rights, Disability
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA non-profit youth hockey organization leasing a public ice arena removed a team participant due to the participant's depression and anxiety. The minor participant through her parents brought suit against the hockey organization under Section 5-102(A) of the Illinois Human Rights Act (HRA) alleging discrimination against a person with a disability in the full and equal enjoyment of a public accommodation. The hockey organization argued that areas of the public ice arena were not public when leased by the organization. The Illinois Supreme Court held that the youth hocky organization violated the HRA by removing the minor from the team. Specifically, the court determined that (1) the ice arena is a place of public accommodation within the meaning of the HRA (defined as "a gymnasium, health spa, bowling alley, golf course, or other place of exercise or recreation"); (2) the youth hockey organization is a person within the meaning of the HRA (defined as "one or more individuals, partnerships, associations or organizations, labor organizations, labor unions, joint apprenticeship committees, or union labor associations, corporations"); and (3) the language in the HRA does not delineate between portions of a place of public accommodation so that areas of the public ice arena restricted to the youth hockey organization are no less a place of public accommodation than the areas open to the general public. The central thread of the court's opinion was that the plain meaning of the HRA should be applied and that the Defendant cannot interpret or read additional language into the statute to reach a desired result.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A non-profit youth hockey organization leasing a public ice arena removed a team participant due to the participant's depression and anxiety. The minor participant through her parents brought suit against the hockey organization under Section 5-102(A) of the Illinois Human Rights Act (HRA) alleging discrimination against a person with a disability in the full and equal enjoyment of a public accommodation. The hockey organization argued that areas of the public ice arena were not public when leased by the organization. The Illinois Supreme Court held that the youth hocky organization violated the HRA by removing the minor from the team. Specifically, the court determined that (1) the ice arena is a place of public accommodation within the meaning of the HRA (defined as "a gymnasium, health spa, bowling alley, golf course, or other place of exercise or recreation"); (2) the youth hockey organization is a person within the meaning of the HRA (defined as "one or more individuals, partnerships, associations or organizations, labor organizations, labor unions, joint apprenticeship committees, or union labor associations, corporations"); and (3) the language in the HRA does not delineate between portions of a place of public accommodation so that areas of the public ice arena restricted to the youth hockey organization are no less a place of public accommodation than the areas open to the general public. The central thread of the court's opinion was that the plain meaning of the HRA should be applied and that the Defendant cannot interpret or read additional language into the statute to reach a desired result.
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Mack v. Williams, 522 P.3d 434 (Nev. 2022)
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Nevada | 2022 | Criminal Justice, Police Misconduct |
State:
Nevada
Year:
2022
Topics:
Criminal Justice, Police Misconduct
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingMack attempted to visit an inmate at the High Desert State Prison. Before allowing her to visit the inmate or telling her she would not be allowed to visit the inmate, two officers conducted a strip search. In response, Mack filed a civil rights action against the Nevada Department of Corrections asserting violations of her state and federal rights. Specifically, she alleged that the strip search violated her right to procedural due process and right against unreasonable searches and seizures under the Nevada Constitution. In moving for summary judgment, the state argued that there was no private right of action under the Nevada Constitution. This question was then certified to the Nevada Supreme Court. The Court held that a private right of action for money damages exists to vindicate violations of search-and-seizure rights under the Nevada Constitution, but a qualified immunity defense does not apply to such an action. In reaching this holding, the Court reasoned that the prohibitory provisions in the Constitution are self-executing and need no further legislation to put them in force. Since Article 1, Section 18 of the Nevada Constitution reads “[t]he right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures,” it prohibits the state from acting in certain ways (i.e., acting unreasonably) and thus is a self-executing provision in the Nevada Constitution. After the Supreme Court answered the certified question of whether Article 1, Section 18 of the Nevada Constitution created a private right of action, the Court remanded to the trial court below to consider the merits of the claim.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Mack attempted to visit an inmate at the High Desert State Prison. Before allowing her to visit the inmate or telling her she would not be allowed to visit the inmate, two officers conducted a strip search. In response, Mack filed a civil rights action against the Nevada Department of Corrections asserting violations of her state and federal rights. Specifically, she alleged that the strip search violated her right to procedural due process and right against unreasonable searches and seizures under the Nevada Constitution. In moving for summary judgment, the state argued that there was no private right of action under the Nevada Constitution. This question was then certified to the Nevada Supreme Court. The Court held that a private right of action for money damages exists to vindicate violations of search-and-seizure rights under the Nevada Constitution, but a qualified immunity defense does not apply to such an action. In reaching this holding, the Court reasoned that the prohibitory provisions in the Constitution are self-executing and need no further legislation to put them in force. Since Article 1, Section 18 of the Nevada Constitution reads “[t]he right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures,” it prohibits the state from acting in certain ways (i.e., acting unreasonably) and thus is a self-executing provision in the Nevada Constitution. After the Supreme Court answered the certified question of whether Article 1, Section 18 of the Nevada Constitution created a private right of action, the Court remanded to the trial court below to consider the merits of the claim.
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Macomb Cnty. v. AFSCME Council 25, 833 N.W.2d 225 (Mich. 2013)
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Michigan | 2013 | Labor, Employment & Economic Justice, Collective Bargaining |
State:
Michigan
Year:
2013
Topics:
Labor, Employment & Economic Justice, Collective Bargaining
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiffs brought an unfair labor practice complaint against Macomb County after the county changed the actuarial table for calculating pension benefits without engaging in bargaining as required by the Public Employment Relations Act. The Supreme Court ruled in favor of the county because the amendment of the actuarial table is not a term or condition of employment which necessitates bargaining and therefore failure to do so does not constitute an unfair labor practice. The Supreme Court also ruled that the grievance process created by the parties in the collective bargaining agreement is the appropriate forum for this dispute.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiffs brought an unfair labor practice complaint against Macomb County after the county changed the actuarial table for calculating pension benefits without engaging in bargaining as required by the Public Employment Relations Act. The Supreme Court ruled in favor of the county because the amendment of the actuarial table is not a term or condition of employment which necessitates bargaining and therefore failure to do so does not constitute an unfair labor practice. The Supreme Court also ruled that the grievance process created by the parties in the collective bargaining agreement is the appropriate forum for this dispute.
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Magic Petroleum Corp. v. Exxon Mobil Corp., 95 A.3d 175 (N.J. 2014)
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New Jersey | 2014 | Environment, Pollution/Contamination |
State:
New Jersey
Year:
2014
Topics:
Environment, Pollution/Contamination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe issue on appeal was whether a property owner's claims for contribution under the New Jersey Spill Compensation and Control Act (Spill Act) must be deferred under the doctrine of primary jurisdiction until after the conclusion of the New Jersey Department of Environmental Protection (DEP) mediation enforcement actions or whether a property owner may proceed against responsible parties to recover sums expended to remediate the site before the DEP concludes its involvement in the site. This case involved two separate legal actions. First, the DEP sued Magic Petroleum (Magic) for expenses incurred during the cleanup of hazardous material whereby Magic bore the entire cost pursuant to the DEP's determination that Magic was the discharger. Magic then sought contribution from Exxon Mobil Corporation, the owner of the neighboring land, to contribute to the cost of the cleanup. The trial court dismissed Magic's case because it reasoned that under the doctrine of primary jurisdiction, the contribution claim could only be filed following complete remediation of the site.
In holding that remediation need not conclude to seek contribution under the Spill Act, the court reasoned that (1) the legislature established a private right of action in contribution and focused on the courts as the venue to allocate liability percentages for such recourse while the DEP continued to apply its expertise in the remediation; and (2) the doctrine of primary jurisdiction does not apply because DEP and the courts share concurrent jurisdiction over recovery of cleanup costs because private parties are required to turn to the courts to seek contribution from other entities that caused the contamination on the land in the form of percentage liability (which final determination of costs would be dictated by the remediation process overseen by DEP).
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Justice Vote Breakdown
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Summary of Case Context & Holding
The issue on appeal was whether a property owner's claims for contribution under the New Jersey Spill Compensation and Control Act (Spill Act) must be deferred under the doctrine of primary jurisdiction until after the conclusion of the New Jersey Department of Environmental Protection (DEP) mediation enforcement actions or whether a property owner may proceed against responsible parties to recover sums expended to remediate the site before the DEP concludes its involvement in the site. This case involved two separate legal actions. First, the DEP sued Magic Petroleum (Magic) for expenses incurred during the cleanup of hazardous material whereby Magic bore the entire cost pursuant to the DEP's determination that Magic was the discharger. Magic then sought contribution from Exxon Mobil Corporation, the owner of the neighboring land, to contribute to the cost of the cleanup. The trial court dismissed Magic's case because it reasoned that under the doctrine of primary jurisdiction, the contribution claim could only be filed following complete remediation of the site.
In holding that remediation need not conclude to seek contribution under the Spill Act, the court reasoned that (1) the legislature established a private right of action in contribution and focused on the courts as the venue to allocate liability percentages for such recourse while the DEP continued to apply its expertise in the remediation; and (2) the doctrine of primary jurisdiction does not apply because DEP and the courts share concurrent jurisdiction over recovery of cleanup costs because private parties are required to turn to the courts to seek contribution from other entities that caused the contamination on the land in the form of percentage liability (which final determination of costs would be dictated by the remediation process overseen by DEP).
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Mahler v. Nev. Emp. Sec. Div., No. 63842, 2015 WL 3368876 (Nev. May 21, 2015) (unpublished disposition)
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Nevada | 2015 | Labor, Employment & Economic Justice |
State:
Nevada
Year:
2015
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingJohn Mahler was employed as a security guard with Guardsmark. Upon termination of his employment, he sought unemployment benefits. Guardsmark reported to Nevada Employment Security Division (ESD) that Mahler's termination was based on two incidences that violated company polices: (1) making an unsolicited personal telephone call to a client representative asking her on a date; and (2) sitting in a chair that was personal property brought to a work site, removing his shoes, and reading a book while on duty. The ESD denied Mahler's request for unemployment benefits, finding that he had been discharged for misconduct connected to his work. The appeals referee reversed, concluding that Mahler had made an error in judgment but since there was no adverse effect to Guardsmark, disqualifying misconduct had not been established. The Board of Review (Board), however, found that disqualifying misconduct had been established and, therefore, reversed the appeals referee's decision and directed Mahler to repay the benefits received. On judicial review, the district court denied Mahler's petition in part, affirming the Board's decision to deny benefits based on disqualifying misconduct, but granted the petition as to the Board's directive that Mahler repay an unspecified amount of benefits received. The Supreme Court affirmed the district court's order finding that the Board's decision to deny unemployment benefits based on disqualifying misconduct was not arbitrary or capricious or an error of law based on evidence that Mahler did in fact violate Guardsmark's policies. Mahler did not challenge the district court's order regarding repayment of overpaid benefits so the Supreme Court did not address that issue.
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Justice Vote Breakdown
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Summary of Case Context & Holding
John Mahler was employed as a security guard with Guardsmark. Upon termination of his employment, he sought unemployment benefits. Guardsmark reported to Nevada Employment Security Division (ESD) that Mahler's termination was based on two incidences that violated company polices: (1) making an unsolicited personal telephone call to a client representative asking her on a date; and (2) sitting in a chair that was personal property brought to a work site, removing his shoes, and reading a book while on duty. The ESD denied Mahler's request for unemployment benefits, finding that he had been discharged for misconduct connected to his work. The appeals referee reversed, concluding that Mahler had made an error in judgment but since there was no adverse effect to Guardsmark, disqualifying misconduct had not been established. The Board of Review (Board), however, found that disqualifying misconduct had been established and, therefore, reversed the appeals referee's decision and directed Mahler to repay the benefits received. On judicial review, the district court denied Mahler's petition in part, affirming the Board's decision to deny benefits based on disqualifying misconduct, but granted the petition as to the Board's directive that Mahler repay an unspecified amount of benefits received. The Supreme Court affirmed the district court's order finding that the Board's decision to deny unemployment benefits based on disqualifying misconduct was not arbitrary or capricious or an error of law based on evidence that Mahler did in fact violate Guardsmark's policies. Mahler did not challenge the district court's order regarding repayment of overpaid benefits so the Supreme Court did not address that issue.
Link to Opinion
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Mahoning Educ. Ass'n of Dev. Disabilities v. State Emp. Relations Bd., 998 N.E.2d 1124 (Ohio 2013)
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Ohio | 2013 | Labor, Employment & Economic Justice, Collective Bargaining |
State:
Ohio
Year:
2013
Topics:
Labor, Employment & Economic Justice, Collective Bargaining
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDuring contract negotiations, employer municipal MCBDD held a board meeting in a county-owned building. Union representatives conducted an informational picket outside the building before the meeting, though the union did not notify MCBDD or the State Employee Relations Board (SERB) of plans to picket prior to the event. MCBDD filed an unfair-labor-practice complaint with SERB, alleging the union had violated the 10-day advance notice requirement of R.C. 4117.11(B)(8). SERB agreed, finding that the union had committed an unfair labor practice by failing to give the required notice before picketing. The union appealed in court, arguing that the statute is unconstitutional because it is a content-based restriction on the union’s right to free speech. The court of appeals found the statute unconstitutional.
The Supreme Court upheld the judgment of the appeals court, but on statutory interpretation rather than constitutional grounds. The Court found neither the plain language nor the legislative history applied to informational picketing. The Supreme Court held that 10-day notice is only required when picketing is planned in conjunction with a "a work stoppage, a strike, or other ‘concerted refusal to work.’" One concurring opinion did address the direct constitutionality of the requirement, and found it was an unconstitutional prior restraint.
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Justice Vote Breakdown
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Summary of Case Context & Holding
During contract negotiations, employer municipal MCBDD held a board meeting in a county-owned building. Union representatives conducted an informational picket outside the building before the meeting, though the union did not notify MCBDD or the State Employee Relations Board (SERB) of plans to picket prior to the event. MCBDD filed an unfair-labor-practice complaint with SERB, alleging the union had violated the 10-day advance notice requirement of R.C. 4117.11(B)(8). SERB agreed, finding that the union had committed an unfair labor practice by failing to give the required notice before picketing. The union appealed in court, arguing that the statute is unconstitutional because it is a content-based restriction on the union’s right to free speech. The court of appeals found the statute unconstitutional.
The Supreme Court upheld the judgment of the appeals court, but on statutory interpretation rather than constitutional grounds. The Court found neither the plain language nor the legislative history applied to informational picketing. The Supreme Court held that 10-day notice is only required when picketing is planned in conjunction with a "a work stoppage, a strike, or other ‘concerted refusal to work.’" One concurring opinion did address the direct constitutionality of the requirement, and found it was an unconstitutional prior restraint.
Link to Opinion
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Manitowoc Co., Inc. v. Lanning, 906 N.W.2d 130 (Wis. 2018)
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Wisconsin | 2018 | Labor, Employment & Economic Justice |
State:
Wisconsin
Year:
2018
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingManitowoc Co., Inc. brought an action against former employee John Lanning alleging that Lanning violated a non-solicitation-of-employees provision within an employee agreement. The Supreme Court held that non-solicitation agreements are a "restraint of trade" governed by Wis. Stat § 103.465 and must be "reasonably necessary for the protection of the employer" in order to be enforceable. That is, they must be bound by reasonable restraints on time and geography. Following Manitowoc, non-solicitation agreements are "restraint[s] of trade," that must meet the same reasonableness requirements as a covenant not to compete to be enforceable.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Manitowoc Co., Inc. brought an action against former employee John Lanning alleging that Lanning violated a non-solicitation-of-employees provision within an employee agreement. The Supreme Court held that non-solicitation agreements are a "restraint of trade" governed by Wis. Stat § 103.465 and must be "reasonably necessary for the protection of the employer" in order to be enforceable. That is, they must be bound by reasonable restraints on time and geography. Following Manitowoc, non-solicitation agreements are "restraint[s] of trade," that must meet the same reasonableness requirements as a covenant not to compete to be enforceable.
Link to Opinion
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Maples v. State, 968 N.W.2d 446 (Mich. 2021)
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Michigan | 2021 | Criminal Justice, Access to Justice |
State:
Michigan
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThis case allowed the Supreme Court to determine what constitutes “new evidence” under the Michigan Wrongful Imprisonment Compensation Act (WICA), which requires “new evidence” that proves innocence to receive remedial compensation. Here, Defendant’s two exonerating witnesses were unable to testify on his behalf at his original trial and controversy arose out of whether these same witnesses could be considered “new evidence” if they testified years later to his innocence. Through a plain text analysis, the Supreme Court held that “new evidence” encompasses all “evidence that was not presented to the trier of fact when it initially convicted the plaintiff.” The Supreme Court found this interpretation gave the best effect to the WICA’s remedial purpose. Thus, the witnesses here constituted “new evidence" and the case was remanded to allow the Defendant to potentially recover under WICA.
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Justice Vote Breakdown
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Summary of Case Context & Holding
This case allowed the Supreme Court to determine what constitutes “new evidence” under the Michigan Wrongful Imprisonment Compensation Act (WICA), which requires “new evidence” that proves innocence to receive remedial compensation. Here, Defendant’s two exonerating witnesses were unable to testify on his behalf at his original trial and controversy arose out of whether these same witnesses could be considered “new evidence” if they testified years later to his innocence. Through a plain text analysis, the Supreme Court held that “new evidence” encompasses all “evidence that was not presented to the trier of fact when it initially convicted the plaintiff.” The Supreme Court found this interpretation gave the best effect to the WICA’s remedial purpose. Thus, the witnesses here constituted “new evidence" and the case was remanded to allow the Defendant to potentially recover under WICA.
Link to Opinion
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Marble v. State, 355 P.3d 742 (Mont. 2015)
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Montana | 2015 | Criminal Justice, Access to Justice, Juvenile Justice |
State:
Montana
Year:
2015
Topics:
Criminal Justice, Access to Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2002, Defendant was convicted of sexual intercourse without consent. The victim, then 13 years old, testified at Defendant’s trial that Defendant (then 17 years old) had forcibly engaged in anal intercourse with him in the shower at the Missoula County Detention Center where both boys were temporary inmates for juvenile offenses. In 2009, Defendant contacted the Montana Innocence Project after he heard rumors that the victim, who was serving time for statutory rape, had been telling other inmates that Defendant never sodomized him. The Innocence Project interviewed the victim and the victim provided a written recantation in July 2010. Based on the recantation, Defendant filed a postconviction relief (PCR) petition seeking, among other things, a new trial. The district court ordered that the victim be deposed. Contrary to the written statement, at both his deposition and subsequent hearing, the victim testified that the rape did occur as he had originally claimed in 2002 and that he had recanted because he thought the Innocence Project might help him with his own legal trouble if he cooperated. The petition was denied at the district court and Defendant appealed. In the interim, the victim had an encounter with the police which resulted in a 21-hour standoff and the victim’s suicide. The Court held that a district court presented with a PCR petition based upon newly discovered evidence should utilize the test set forth in 46-21-102, MCA—it shall determine whether the "newly discovered evidence . . ., if proved and viewed in light of the evidence as a whole would establish that the petitioner did not engage in the criminal conduct" for which he or she was convicted. The Court concluded that the district court erred in tying a PCR case to the factor five of the Clark test, which permits a defendant to "prevail on a motion for a new trial grounded on newly discovered evidence" where the evidence indicates "that a new trial has a reasonable probability of resulting in a different outcome." State v. Clark, 197 P.3d 977, 980, 982 (Mont. 2008). Because in a PCR case petitioner is presumed guilty following the entry of a judgment of conviction, his burden when seeking PCR based upon newly discovered evidence should be greater than that imposed upon a petitioner seeking a new trial. The Court noted that the fifth factor of the Clark test is inconsistent with the standard set forth in §46-21-102(2), MCA, and undercuts the wide discretion available to a district court considering a PCR petition. As a result, the Court overruled Crosby v. State, 139 P.3d 832 (Mont. 2006), DuBray v. State, 182 P.3d 753 (Mont. 2008), and State v. Tyler, 204 P.3d 685 (Mont. 2009), cases in which the Court applied the fifth factor of the Clark test to a petition for PCR that is based upon newly discovered evidence. The Court reversed and remanded for consideration Defendant's petition under the MCA standard for PCR petitions.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 2002, Defendant was convicted of sexual intercourse without consent. The victim, then 13 years old, testified at Defendant’s trial that Defendant (then 17 years old) had forcibly engaged in anal intercourse with him in the shower at the Missoula County Detention Center where both boys were temporary inmates for juvenile offenses. In 2009, Defendant contacted the Montana Innocence Project after he heard rumors that the victim, who was serving time for statutory rape, had been telling other inmates that Defendant never sodomized him. The Innocence Project interviewed the victim and the victim provided a written recantation in July 2010. Based on the recantation, Defendant filed a postconviction relief (PCR) petition seeking, among other things, a new trial. The district court ordered that the victim be deposed. Contrary to the written statement, at both his deposition and subsequent hearing, the victim testified that the rape did occur as he had originally claimed in 2002 and that he had recanted because he thought the Innocence Project might help him with his own legal trouble if he cooperated. The petition was denied at the district court and Defendant appealed. In the interim, the victim had an encounter with the police which resulted in a 21-hour standoff and the victim’s suicide. The Court held that a district court presented with a PCR petition based upon newly discovered evidence should utilize the test set forth in 46-21-102, MCA—it shall determine whether the "newly discovered evidence . . ., if proved and viewed in light of the evidence as a whole would establish that the petitioner did not engage in the criminal conduct" for which he or she was convicted. The Court concluded that the district court erred in tying a PCR case to the factor five of the Clark test, which permits a defendant to "prevail on a motion for a new trial grounded on newly discovered evidence" where the evidence indicates "that a new trial has a reasonable probability of resulting in a different outcome." State v. Clark, 197 P.3d 977, 980, 982 (Mont. 2008). Because in a PCR case petitioner is presumed guilty following the entry of a judgment of conviction, his burden when seeking PCR based upon newly discovered evidence should be greater than that imposed upon a petitioner seeking a new trial. The Court noted that the fifth factor of the Clark test is inconsistent with the standard set forth in §46-21-102(2), MCA, and undercuts the wide discretion available to a district court considering a PCR petition. As a result, the Court overruled Crosby v. State, 139 P.3d 832 (Mont. 2006), DuBray v. State, 182 P.3d 753 (Mont. 2008), and State v. Tyler, 204 P.3d 685 (Mont. 2009), cases in which the Court applied the fifth factor of the Clark test to a petition for PCR that is based upon newly discovered evidence. The Court reversed and remanded for consideration Defendant's petition under the MCA standard for PCR petitions.
Link to Opinion
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Marcellus Shale Coal. v. Dep't of Env't Prot., 292 A.3d 921 (Pa. 2023).
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Pennsylvania | 2023 | Environment, Conservation Efforts/Green Initiatives, Actions Against Government |
State:
Pennsylvania
Year:
2023
Topics:
Environment, Conservation Efforts/Green Initiatives, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe case involved a challenge to the Pennsylvania Department of Environmental Protection's (DEP) oil and gas regulations, which protect privately owned "public resources," like playgrounds, recreation areas, and other environmentally sensitive areas. The Supreme Court held that the DEP had the authority to regulate these areas under the Environmental Rights Amendment of the Pennsylvania's Constitution.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The case involved a challenge to the Pennsylvania Department of Environmental Protection's (DEP) oil and gas regulations, which protect privately owned "public resources," like playgrounds, recreation areas, and other environmentally sensitive areas. The Supreme Court held that the DEP had the authority to regulate these areas under the Environmental Rights Amendment of the Pennsylvania's Constitution.
Link to Opinion
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Marsillo v. Dunnick, 683 S.W.3d 387 (Tex. 2024)
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Texas | 2024 | Health Care |
State:
Texas
Year:
2024
Topics:
Health Care
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingUnder the Texas Medical Liability Act, a plaintiff cannot recover for injuries sustained during the provision of emergency medical care in a hospital emergency department without providing proof that the physician acted with “willful and wanton negligence.” Raynee Dunnick, a thirteen-year-old, was bitten by a rattlesnake and was promptly taken to a hospital to receive care within the hour. The staff at the hospital immediately began implementing the facility’s Snakebite Treatment Guidelines, which provided for a strict system to determine when a patient should be treated with antivenom. The antivenom used by the hospital was effective if administered within six hours of the snakebite, but had a record of serious, long-term medical complications for patients. As a result, the Snakebite Treatment Guidelines called for a systematic approach to analyze whether, and when, a patient should be treated with the antivenom. Patients are assigned numerical scores for different categories of symptoms, and the antivenom is administered only when the sum of those scores crosses a threshold. Working under the guidelines, the hospital staff waited over four hours until they began administering the antivenom to Dunnick. During that time, Dunnick had experienced severe symptoms of a snake bite and did not leave the hospital until two days later. Dunnick and her parents sued the attending physician, Marsillo, for negligence, claiming that her failure to immediately administer antivenom upon Dunnick’s arrival at the hospital was negligence resulting in Dunnick’s pain, suffering, impairment, and disfigurement. The trial court granted a motion made by Marsillo for no-evidence summary judgment, which was later reversed by the court of appeals. On appeal, the Supreme Court considered whether the evidence presented by Dunnick met the “willful and wanton” standard required for negligence claims brought for emergency medical care provided in a hospital emergency department. Although the Legislature did not define “willful and wanton negligence,” the Court reviewed precedent caselaw from the courts of appeal, as well as typical legal definitions, and held that willful and wanton negligence could be considered some level of negligence above gross negligence. As a result, the Court reviewed the evidence presented by Dunnick to see whether it at least crossed the threshold of gross negligence. The only evidence presented by Dunnick to support her claims of negligence was an expert affidavit, in which a toxicologist noted the extreme time-sensitivity of treating a venomous wound and the need to immediately administer antivenom. The Court noted that this affidavit had not addressed why following the Treatment Guidelines posed an extreme risk of harm to Dunnick, nor did it address the serious dangers of the side effects related to the antivenom. As a result, the Court held that Dunnick had not presented sufficient evidence to suggest that Marsillo had shown indifference to Dunnick’s health by complying with the Treatment Guidelines, and that the trial court was correct in granting summary judgment to Marsillo.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Under the Texas Medical Liability Act, a plaintiff cannot recover for injuries sustained during the provision of emergency medical care in a hospital emergency department without providing proof that the physician acted with “willful and wanton negligence.” Raynee Dunnick, a thirteen-year-old, was bitten by a rattlesnake and was promptly taken to a hospital to receive care within the hour. The staff at the hospital immediately began implementing the facility’s Snakebite Treatment Guidelines, which provided for a strict system to determine when a patient should be treated with antivenom. The antivenom used by the hospital was effective if administered within six hours of the snakebite, but had a record of serious, long-term medical complications for patients. As a result, the Snakebite Treatment Guidelines called for a systematic approach to analyze whether, and when, a patient should be treated with the antivenom. Patients are assigned numerical scores for different categories of symptoms, and the antivenom is administered only when the sum of those scores crosses a threshold. Working under the guidelines, the hospital staff waited over four hours until they began administering the antivenom to Dunnick. During that time, Dunnick had experienced severe symptoms of a snake bite and did not leave the hospital until two days later. Dunnick and her parents sued the attending physician, Marsillo, for negligence, claiming that her failure to immediately administer antivenom upon Dunnick’s arrival at the hospital was negligence resulting in Dunnick’s pain, suffering, impairment, and disfigurement. The trial court granted a motion made by Marsillo for no-evidence summary judgment, which was later reversed by the court of appeals. On appeal, the Supreme Court considered whether the evidence presented by Dunnick met the “willful and wanton” standard required for negligence claims brought for emergency medical care provided in a hospital emergency department. Although the Legislature did not define “willful and wanton negligence,” the Court reviewed precedent caselaw from the courts of appeal, as well as typical legal definitions, and held that willful and wanton negligence could be considered some level of negligence above gross negligence. As a result, the Court reviewed the evidence presented by Dunnick to see whether it at least crossed the threshold of gross negligence. The only evidence presented by Dunnick to support her claims of negligence was an expert affidavit, in which a toxicologist noted the extreme time-sensitivity of treating a venomous wound and the need to immediately administer antivenom. The Court noted that this affidavit had not addressed why following the Treatment Guidelines posed an extreme risk of harm to Dunnick, nor did it address the serious dangers of the side effects related to the antivenom. As a result, the Court held that Dunnick had not presented sufficient evidence to suggest that Marsillo had shown indifference to Dunnick’s health by complying with the Treatment Guidelines, and that the trial court was correct in granting summary judgment to Marsillo.
Link to Opinion
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Martel v. HG Staffing, LLC, 519 P.3d 25 (Nev. 2022)
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Nevada | 2022 | Labor, Employment & Economic Justice, Collective Bargaining |
State:
Nevada
Year:
2022
Topics:
Labor, Employment & Economic Justice, Collective Bargaining
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingFour employees filed a putative class action alleging that their employer failed to pay them for the work they completed in violation of (1) NRS 608.016 (requiring an employer to pay wages for each hour worked); (2) the Minimum Wage Amendment (MWA) of Nevada's Constitution (requiring employers to pay employees a minimum hourly wage); (3) NRS 608.018 (requiring an employer to pay overtime wages); and (4) NRS 608.020 through NRS 608.050 (requiring an employer to timely pay a former employee their earned wages). The Supreme Court held that the employees' claims under NRS 608.016, NRS 608.018, and NRS 608.020 through NRS 608.050 were correctly dismissed because the statutes were interpretated as having a 2-year statute of limitations and such 2-year statute of limitations period had expired. The Supreme Court also affirmed that the district court's summary judgment order correctly concluded that (1) the collective bargaining agreement (CBA) between the employer and employees was valid; (2) claims under NRS 608.040 could not be used to recover time-barred wages under other statutes; and (3) an employer that is a party to a CBA is exempt from the overtime scheme imposed under NRS 608.018, so long as the CBA provides overtime in a different manner than the statute.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Four employees filed a putative class action alleging that their employer failed to pay them for the work they completed in violation of (1) NRS 608.016 (requiring an employer to pay wages for each hour worked); (2) the Minimum Wage Amendment (MWA) of Nevada's Constitution (requiring employers to pay employees a minimum hourly wage); (3) NRS 608.018 (requiring an employer to pay overtime wages); and (4) NRS 608.020 through NRS 608.050 (requiring an employer to timely pay a former employee their earned wages). The Supreme Court held that the employees' claims under NRS 608.016, NRS 608.018, and NRS 608.020 through NRS 608.050 were correctly dismissed because the statutes were interpretated as having a 2-year statute of limitations and such 2-year statute of limitations period had expired. The Supreme Court also affirmed that the district court's summary judgment order correctly concluded that (1) the collective bargaining agreement (CBA) between the employer and employees was valid; (2) claims under NRS 608.040 could not be used to recover time-barred wages under other statutes; and (3) an employer that is a party to a CBA is exempt from the overtime scheme imposed under NRS 608.018, so long as the CBA provides overtime in a different manner than the statute.
Link to Opinion
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Matter of Mays v. Sam's Inc., 448 P.3d 1096 (Mont. 2019)
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Montana | 2019 | Labor, Employment & Economic Justice |
State:
Montana
Year:
2019
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThis case involves a wage dispute between an employee who claimed she was incorrectly classified as an independent contractor and thus owed minimum wages. The lower court affirmed the Montana Department of Labor and Industry's (DLI) finding that the Plaintiff was indeed misclassified as an independent contractor, and held for the employer on the issue of whether the employee was actually employed during a one-year period of time when the employee was attending school and working in another state. The employee appealed on this issue. The Supreme Court held that DLI's Independent Contractor Central Unit (ICCU)'s factual findings on the employee's employment status and period only control with regards to employee status, and not employment period. The Supreme Court then found in favor of employer-Defendant that the employee-Plaintiff was not an employee during the disputed one-year period as the Supreme Court agreed with the lower court that the employee's employment had lapsed during the period that she was in another state and working for another employer.
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Justice Vote Breakdown
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Summary of Case Context & Holding
This case involves a wage dispute between an employee who claimed she was incorrectly classified as an independent contractor and thus owed minimum wages. The lower court affirmed the Montana Department of Labor and Industry's (DLI) finding that the Plaintiff was indeed misclassified as an independent contractor, and held for the employer on the issue of whether the employee was actually employed during a one-year period of time when the employee was attending school and working in another state. The employee appealed on this issue. The Supreme Court held that DLI's Independent Contractor Central Unit (ICCU)'s factual findings on the employee's employment status and period only control with regards to employee status, and not employment period. The Supreme Court then found in favor of employer-Defendant that the employee-Plaintiff was not an employee during the disputed one-year period as the Supreme Court agreed with the lower court that the employee's employment had lapsed during the period that she was in another state and working for another employer.
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Matthews v. Chi. Transit Auth., 51 N.E.3d 753 (Ill. 2016)
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Illinois | 2016 | Labor, Employment, & Economic Justice, Collective Bargaining |
State:
Illinois
Year:
2016
Topics:
Labor, Employment, & Economic Justice, Collective Bargaining
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingTwo classes of employees, including existing employees of the Chicago Transit Authority (CTA) and retirees, filed suit against the CTA for breach of contract and promissory estoppel in response to changes made to their 2004 Collective Bargaining Agreement (CBA). The changes made to the CBA resulted in the City contributing less money to CTA’s pension fund. The change was due to financial issues the city was facing. The Supreme Court noted that retirees who retired before the new CBA took effect experienced significant increases in healthcare costs. These retirees had a vested right to the healthcare benefits outlined in the previous CBA. However, the existing employees had no such right given their ongoing employment. Accordingly, the Court held that the claims for violation of the CBA brought by the retirees could move forward. However, claims for violation of the CBA brought by current employees were dismissed.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Two classes of employees, including existing employees of the Chicago Transit Authority (CTA) and retirees, filed suit against the CTA for breach of contract and promissory estoppel in response to changes made to their 2004 Collective Bargaining Agreement (CBA). The changes made to the CBA resulted in the City contributing less money to CTA’s pension fund. The change was due to financial issues the city was facing. The Supreme Court noted that retirees who retired before the new CBA took effect experienced significant increases in healthcare costs. These retirees had a vested right to the healthcare benefits outlined in the previous CBA. However, the existing employees had no such right given their ongoing employment. Accordingly, the Court held that the claims for violation of the CBA brought by the retirees could move forward. However, claims for violation of the CBA brought by current employees were dismissed.
Link to Opinion
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Mays v. Governor of Mich., 954 N.W.2d 139 (Mich. 2020)
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Michigan | 2020 | Environment, Pollution/Contamination, Water Rights, Actions Against Government |
State:
Michigan
Year:
2020
Topics:
Environment, Pollution/Contamination, Water Rights, Actions Against Government
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingWater users and property owners in Flint, Michigan brought a putative class action, claiming state-created danger, violation of their due-process right to bodily integrity, denial of fair and just treatment under the state's constitution, and unconstitutional taking via inverse condemnation, against state and city officials for their role in switching the city's water supply and failing to take corrective action, which resulted in Legionella bacteria and toxic levels of iron and lead. The Supreme Court held that the Plaintiffs sufficiently alleged a claim of inverse condemnation because, accepting the allegations as true, the complaint established that the defendants’ actions were a substantial cause of the decline in the Plaintiffs’ property value, that defendants took affirmative actions directed at the Plaintiffs’ property, and that the Plaintiffs suffered a unique or special injury different in kind, not simply in degree, from the harm suffered by all persons similarly situated. By equal division, the Supreme Court affirmed the court of appeals' decision that a genuine issue of material fact precluded summary disposition on the basis of governmental immunity, the Plaintiffs pled a recognizable due-process claim for violation of right to bodily integrity, and the damages remedy was not precluded as possible remedy for the due-process claim.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Water users and property owners in Flint, Michigan brought a putative class action, claiming state-created danger, violation of their due-process right to bodily integrity, denial of fair and just treatment under the state's constitution, and unconstitutional taking via inverse condemnation, against state and city officials for their role in switching the city's water supply and failing to take corrective action, which resulted in Legionella bacteria and toxic levels of iron and lead. The Supreme Court held that the Plaintiffs sufficiently alleged a claim of inverse condemnation because, accepting the allegations as true, the complaint established that the defendants’ actions were a substantial cause of the decline in the Plaintiffs’ property value, that defendants took affirmative actions directed at the Plaintiffs’ property, and that the Plaintiffs suffered a unique or special injury different in kind, not simply in degree, from the harm suffered by all persons similarly situated. By equal division, the Supreme Court affirmed the court of appeals' decision that a genuine issue of material fact precluded summary disposition on the basis of governmental immunity, the Plaintiffs pled a recognizable due-process claim for violation of right to bodily integrity, and the damages remedy was not precluded as possible remedy for the due-process claim.
Link to Opinion
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Mays v. Governor of Michigan, 954 N.W.2d 139 (Mich. 2020)
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Michigan | 2020 | Health Care, Public Health |
State:
Michigan
Year:
2020
Topics:
Health Care, Public Health
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn June 2014, residents of Flint, Michigan started reporting illness incidences from drinking their tap water. These water users and property owners brought a putative class action against the State and former city emergency managers for their role in switching the City of Flint's water supply allegedly resulting in contamination from Legionella bacteria and toxic levels of iron and lead. Plaintiffs claimed inverse condemnation (an ask for just compensation for their damaged property) and a violation of their right to bodily integrity under state constitution's due process clause, among other claims. The Supreme Court affirmed the court of appeals with regard to the Plaintiffs' inverse-condemnation claim but they affirmed on all other claims, including injury to bodily integrity, by equal division.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In June 2014, residents of Flint, Michigan started reporting illness incidences from drinking their tap water. These water users and property owners brought a putative class action against the State and former city emergency managers for their role in switching the City of Flint's water supply allegedly resulting in contamination from Legionella bacteria and toxic levels of iron and lead. Plaintiffs claimed inverse condemnation (an ask for just compensation for their damaged property) and a violation of their right to bodily integrity under state constitution's due process clause, among other claims. The Supreme Court affirmed the court of appeals with regard to the Plaintiffs' inverse-condemnation claim but they affirmed on all other claims, including injury to bodily integrity, by equal division.
Link to Opinion
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MB Fin. Bank, N.A. v. Brophy, 226 N.E.3d 1257 (Ill. 2023)
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Illinois | 2023 | Housing, Government Actions |
State:
Illinois
Year:
2023
Topics:
Housing, Government Actions
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff, owners of an apartment-complex (Owners), which had been acquired, by eminent domain, by the City of Joliet (City), brought a declaratory judgment action against the county treasurer seeking refund of property taxes paid between the date the city filed its condemnation complaint and the date it acquired Owners’ property. Because the City's acquisition of the property was effective retroactive to the date the City filed its condemnation complaint, Plaintiffs argued that they were owed a refund of taxes paid during that period. Relying on City of Chicago v. McCausland, 41 N.E.2d 745 (Ill. 1942), the lower court agreed. The Illinois Supreme Court, however, reversed, finding that McCausland was no longer good law and, instead that the Illinois Supreme Court had more recently held that “a taking in Illinois occurs on the date the government deposits the compensation award to the property owner and acquires the title and right to possess the property” not the date the condemnation action is filed. Accordingly, the Illinois Supreme Court determined that the city's title to the property did not vest retroactively to the date of the filing of the condemnation petition and thus did not relieve Owners from property tax liability for the period between the date of filing the condemnation complaint and the date of payment of compensation.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiff, owners of an apartment-complex (Owners), which had been acquired, by eminent domain, by the City of Joliet (City), brought a declaratory judgment action against the county treasurer seeking refund of property taxes paid between the date the city filed its condemnation complaint and the date it acquired Owners’ property. Because the City's acquisition of the property was effective retroactive to the date the City filed its condemnation complaint, Plaintiffs argued that they were owed a refund of taxes paid during that period. Relying on City of Chicago v. McCausland, 41 N.E.2d 745 (Ill. 1942), the lower court agreed. The Illinois Supreme Court, however, reversed, finding that McCausland was no longer good law and, instead that the Illinois Supreme Court had more recently held that “a taking in Illinois occurs on the date the government deposits the compensation award to the property owner and acquires the title and right to possess the property” not the date the condemnation action is filed. Accordingly, the Illinois Supreme Court determined that the city's title to the property did not vest retroactively to the date of the filing of the condemnation petition and thus did not relieve Owners from property tax liability for the period between the date of filing the condemnation complaint and the date of payment of compensation.
Link to Opinion
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McAdams v. Marquette Univ., 914 N.W.2d 708 (Wis. 2018)
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Wisconsin | 2018 | LGBTQ+ Rights, Education |
State:
Wisconsin
Year:
2018
Topics:
LGBTQ+ Rights, Education
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff, McAdams, a professor at Marquette University, was suspended without pay for using his personal blog to criticize another professors course lectures, in which she told students that "gay rights" were not up for discussion in her course. McAdams sued the University and lost, appealing to the Wisconsin Supreme Court. The Supreme Court held that his Marquette University employment contract requiring internal disciplinary actions/arbitration did not preclude court action such that McAdams could bypass arbitration. The Supreme Court further held that the school's disciplinary procedures were not equivalent to arbitration, and that plaintiff's blog post was protected by the doctrine of academic freedom (i.e., it was not actionable speech) such that Plaintiff's suspension for criticizing the other professor via his blogpost was improper.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiff, McAdams, a professor at Marquette University, was suspended without pay for using his personal blog to criticize another professors course lectures, in which she told students that "gay rights" were not up for discussion in her course. McAdams sued the University and lost, appealing to the Wisconsin Supreme Court. The Supreme Court held that his Marquette University employment contract requiring internal disciplinary actions/arbitration did not preclude court action such that McAdams could bypass arbitration. The Supreme Court further held that the school's disciplinary procedures were not equivalent to arbitration, and that plaintiff's blog post was protected by the doctrine of academic freedom (i.e., it was not actionable speech) such that Plaintiff's suspension for criticizing the other professor via his blogpost was improper.
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McAllister v. Ill. Workers Comp. Comm'n, 181 N.E.3d 656, (Ill. 2020)
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Illinois | 2020 | Labor, Employment, & Economic Justice |
State:
Illinois
Year:
2020
Topics:
Labor, Employment, & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingMcAllister injured his knee while working as a sous chef for a restaurant. The injury occurred when he stood up from a kneeling position while organizing the restaurant’s walk-in cooler. He previously had surgery on the injured knee, and had received workers' compensation benefits for that past injury. An arbitrator awarded him workers' compensation benefits for the new knee injury, but the Illinois Worker's Compensation Commission reversed, finding that the new injury did not "arise out of [his] employment." The Supreme Court disagreed, explaining that the acts leading to the new injury were risks inherent to McAllister's employment, as they were actions that could reasonably be expected in fulfilling his job duties. Specifically, McAllister was responsible for arranging the walk-in cooler; therefore, injuries from risks associated with those tasks, such as a knee injury caused by standing up from a kneeling position were compensable.
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Justice Vote Breakdown
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Summary of Case Context & Holding
McAllister injured his knee while working as a sous chef for a restaurant. The injury occurred when he stood up from a kneeling position while organizing the restaurant’s walk-in cooler. He previously had surgery on the injured knee, and had received workers' compensation benefits for that past injury. An arbitrator awarded him workers' compensation benefits for the new knee injury, but the Illinois Worker's Compensation Commission reversed, finding that the new injury did not "arise out of [his] employment." The Supreme Court disagreed, explaining that the acts leading to the new injury were risks inherent to McAllister's employment, as they were actions that could reasonably be expected in fulfilling his job duties. Specifically, McAllister was responsible for arranging the walk-in cooler; therefore, injuries from risks associated with those tasks, such as a knee injury caused by standing up from a kneeling position were compensable.
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McBee v. Team Indus., Inc., 925 N.W.2d 222 (Minn. 2019)
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Minnesota | 2019 | Labor, Employment & Economic Justice, Disability Rights, Employment Discrimination |
State:
Minnesota
Year:
2019
Topics:
Labor, Employment & Economic Justice, Disability Rights, Employment Discrimination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingMcBee, former employee at an aluminum die-casting plant operated by respondent Team Industries (Team), brought claims against the employer for employment discrimination and workers' compensation retaliation. McBee had brought suit against Team under the Minnesota Human Rights Act (MHRA) claiming that Team failed to engage in an "interactive process" to determine reasonable accommodations for her disability before Team ended her employment. Team argued that no interactive process is required under the MHRA. Regardless, McBee could not perform the essential functions of her position and continuing McBee's employment posed a serious threat to her health. The district court granted summary judgment for Team, and the court of appeals affirmed. The Supreme Court held that, unlike the federal Americans with Disabilities Act, the Minnesota Human Rights Act (MHRA) does not require employers to engage in an interactive process before deciding whether to accommodate an employee who claims to have a disability. Specifically, the Supreme Court affirming in part, held that while the MHRA does not require an employer to engage in an interactive process to determine an appropriate reasonable accommodation, genuine factual disputes regarding the essential functions of McBee's employment and Team's serious-threat defense disputing the alleged serious threat to the health or safety of McBee as a result of continued employment in light of her disability precluded summary judgment, and remanded to the districted court for trial.
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Justice Vote Breakdown
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Summary of Case Context & Holding
McBee, former employee at an aluminum die-casting plant operated by respondent Team Industries (Team), brought claims against the employer for employment discrimination and workers' compensation retaliation. McBee had brought suit against Team under the Minnesota Human Rights Act (MHRA) claiming that Team failed to engage in an "interactive process" to determine reasonable accommodations for her disability before Team ended her employment. Team argued that no interactive process is required under the MHRA. Regardless, McBee could not perform the essential functions of her position and continuing McBee's employment posed a serious threat to her health. The district court granted summary judgment for Team, and the court of appeals affirmed. The Supreme Court held that, unlike the federal Americans with Disabilities Act, the Minnesota Human Rights Act (MHRA) does not require employers to engage in an interactive process before deciding whether to accommodate an employee who claims to have a disability. Specifically, the Supreme Court affirming in part, held that while the MHRA does not require an employer to engage in an interactive process to determine an appropriate reasonable accommodation, genuine factual disputes regarding the essential functions of McBee's employment and Team's serious-threat defense disputing the alleged serious threat to the health or safety of McBee as a result of continued employment in light of her disability precluded summary judgment, and remanded to the districted court for trial.
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McCarty v. State, 371 P.3d 1002 (Nev. 2016)
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Nevada | 2016 | Criminal Justice, Death Penalty, Access to Justice |
State:
Nevada
Year:
2016
Topics:
Criminal Justice, Death Penalty, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant Jason Duval McCarty was convicted of multiple felonies related to the kidnapping and murder of two women. McCarty was sentenced to death for each murder. McCarty appealed on the grounds that (1) the State violated his Sixth Amendment right to counsel by failing to provide McCarty counsel during his post attachment interrogations and (2) the State engaged in discriminatory jury selection by using its peremptory strikes to remove two African-American prospective jurors. The Court held that McCarty was not entitled to relief on his Sixth Amendment challenge because he had effectively waived his Sixth Amendment right to counsel in response to a Miranda warning. However, the Court found the district court clearly erred in denying McCarty's jury selection challenge under Batson v. Kentucky, 476 U.S. 79 (1986). The State claimed it struck the juror because she worked at a strip club and because the State prosecuted her brother thirteen years prior, who may have committed a violent crime. The Court found the State's explanation was more likely than not pretextual, given that the State only conducted a background check on the challenged prospective juror. Accordingly, the Court reversed the conviction.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant Jason Duval McCarty was convicted of multiple felonies related to the kidnapping and murder of two women. McCarty was sentenced to death for each murder. McCarty appealed on the grounds that (1) the State violated his Sixth Amendment right to counsel by failing to provide McCarty counsel during his post attachment interrogations and (2) the State engaged in discriminatory jury selection by using its peremptory strikes to remove two African-American prospective jurors. The Court held that McCarty was not entitled to relief on his Sixth Amendment challenge because he had effectively waived his Sixth Amendment right to counsel in response to a Miranda warning. However, the Court found the district court clearly erred in denying McCarty's jury selection challenge under Batson v. Kentucky, 476 U.S. 79 (1986). The State claimed it struck the juror because she worked at a strip club and because the State prosecuted her brother thirteen years prior, who may have committed a violent crime. The Court found the State's explanation was more likely than not pretextual, given that the State only conducted a background check on the challenged prospective juror. Accordingly, the Court reversed the conviction.
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McDonald v. Ponderosa Enters., Inc., 352 P.3d 14 (Mont. 2015)
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Montana | 2015 | Labor, Employment & Economic Justice |
State:
Montana
Year:
2015
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff was an independent contractor working on construction for the Defendant framing company. Plaintiff was injured while working on a third-party construction site and sued both the construction company that hired him as an independent contractor and the Defendant-framing company where the work was being done. The lower court found for the Defendants, finding that the Montana Occupational Safety and Health Act's (MOSHA) duty of care imposed on employers did not apply as the Plaintiff was not an employee at the time of injury. Mont. Code Ann. § 50-71-201. The Plaintiff appealed on the issue of whether MOSHA imposes a duty of safety on the employer of an independent contractor. The Supreme Court held that it did not because under the definition of employee as incorporated in MOSHA and under the court's precedents, independent contractors are distinct from employees and, therefore, no specific duty of safety runs to them from employers under MOSHA. The Supreme Court also held that the "loaned servant doctrine," whereby an employer temporarily borrows and exercises control over another's employee, which might have imposed a duty of care if a Defendant-employer had hired the Plaintiff as an employee to work on the other Defendant's worksite, was not applicable as Plaintiff's status as an independent contractor precluded him from being loaned as an employee.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiff was an independent contractor working on construction for the Defendant framing company. Plaintiff was injured while working on a third-party construction site and sued both the construction company that hired him as an independent contractor and the Defendant-framing company where the work was being done. The lower court found for the Defendants, finding that the Montana Occupational Safety and Health Act's (MOSHA) duty of care imposed on employers did not apply as the Plaintiff was not an employee at the time of injury. Mont. Code Ann. § 50-71-201. The Plaintiff appealed on the issue of whether MOSHA imposes a duty of safety on the employer of an independent contractor. The Supreme Court held that it did not because under the definition of employee as incorporated in MOSHA and under the court's precedents, independent contractors are distinct from employees and, therefore, no specific duty of safety runs to them from employers under MOSHA. The Supreme Court also held that the "loaned servant doctrine," whereby an employer temporarily borrows and exercises control over another's employee, which might have imposed a duty of care if a Defendant-employer had hired the Plaintiff as an employee to work on the other Defendant's worksite, was not applicable as Plaintiff's status as an independent contractor precluded him from being loaned as an employee.
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McDonald v. Symphony Bronzeville Park, LLC, 193 N.E.3d 1253 (Ill. 2022)
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Illinois | 2022 | Labor, Employment, & Economic Justice |
State:
Illinois
Year:
2022
Topics:
Labor, Employment, & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingEmployee sued her former employer for violation of the 2008 Biometric Privacy Act (BIPA) and Workers Compensation Act. The employer collected employees’ fingerprints for timekeeping logins. The employee claimed she never signed a release, received no notice, did not get additional information about how long her employer would keep the biometric data, and was not informed of the purpose of the biometric data collection. The employer argued that the employee could not bring a Workers Compensation claim for the collection of her biometric data because the Workers Compensation Act only allows employees to bring claims for actual injuries, and the collection of biometric information did not actually injure the employee. The Supreme Court held that the appropriate remedy for employees seeking relief for BIPA violations are liquidated damages when the employee has not suffered actual damages. This clarification between liquidated damages and actual damages creates a distinction between the damages covered under the Worker's Compensation Act.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Employee sued her former employer for violation of the 2008 Biometric Privacy Act (BIPA) and Workers Compensation Act. The employer collected employees’ fingerprints for timekeeping logins. The employee claimed she never signed a release, received no notice, did not get additional information about how long her employer would keep the biometric data, and was not informed of the purpose of the biometric data collection. The employer argued that the employee could not bring a Workers Compensation claim for the collection of her biometric data because the Workers Compensation Act only allows employees to bring claims for actual injuries, and the collection of biometric information did not actually injure the employee. The Supreme Court held that the appropriate remedy for employees seeking relief for BIPA violations are liquidated damages when the employee has not suffered actual damages. This clarification between liquidated damages and actual damages creates a distinction between the damages covered under the Worker's Compensation Act.
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McElrath v. State, 839 S.E.2d 573 (Ga. 2020)
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Georgia | 2020 | Criminal Justice |
State:
Georgia
Year:
2020
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA jury found Defendant guilty but mentally ill of the felony murder and aggravated assault of his adoptive mother. Defendant was also found not guilty of the malice murder of one victim by reason of insanity. Defendant appealed, arguing that the jury’s verdicts were repugnant and that his conviction for felony murder had to be reversed or vacated. "Repugnant verdicts" occur when, in order to find the defendant not guilty on one count and guilty on another, the jury must make affirmative findings shown on the record that cannot logically or legally exist at the same time. Defendant also appealed the trial court’s separate order that, upon his discharge from evaluation at a state mental health facility, he should be placed in the custody of the Department of Corrections. Under the specific facts of this case, the Supreme Court held that jury's verdicts, which found Defendant not guilty by reason of insanity of malice murder, while finding him guilty but mentally ill of felony murder based on his aggravated assault of the same victim, were not just inconsistent but repugnant, and both had to be set aside, thus overruling Blevins v. State and disapproving Shepherd v. State. In Blevins v. State,808 S.Ed.2d 740 (Ga. Ct. App. 2017), the court held that a defendant may no longer attack as inconsistent a verdict of guilty on one count and not guilty on another because courts should not speculate on why a jury convicted on one offense and not another. In Shepherd v. State, 626 S.E.2d 96 (Ga. 2006), defendant was found not guilty by reason of insanity for malice murder, and guilty but mentally ill of felony murder predicated on aggravated assault, felony murder predicated on possession of a firearm by a convicted felon, aggravated assault, possession of a firearm by a convicted felon, and possession of a firearm during the commission of a crime. The Supreme Court vacated both verdicts and remanded Defendant’s case for a new trial. The Supreme Court also vacated the trial court’s order placing Defendant in the Department of Corrections' custody pursuant to the vacated verdicts.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A jury found Defendant guilty but mentally ill of the felony murder and aggravated assault of his adoptive mother. Defendant was also found not guilty of the malice murder of one victim by reason of insanity. Defendant appealed, arguing that the jury’s verdicts were repugnant and that his conviction for felony murder had to be reversed or vacated. "Repugnant verdicts" occur when, in order to find the defendant not guilty on one count and guilty on another, the jury must make affirmative findings shown on the record that cannot logically or legally exist at the same time. Defendant also appealed the trial court’s separate order that, upon his discharge from evaluation at a state mental health facility, he should be placed in the custody of the Department of Corrections. Under the specific facts of this case, the Supreme Court held that jury's verdicts, which found Defendant not guilty by reason of insanity of malice murder, while finding him guilty but mentally ill of felony murder based on his aggravated assault of the same victim, were not just inconsistent but repugnant, and both had to be set aside, thus overruling Blevins v. State and disapproving Shepherd v. State. In Blevins v. State,808 S.Ed.2d 740 (Ga. Ct. App. 2017), the court held that a defendant may no longer attack as inconsistent a verdict of guilty on one count and not guilty on another because courts should not speculate on why a jury convicted on one offense and not another. In Shepherd v. State, 626 S.E.2d 96 (Ga. 2006), defendant was found not guilty by reason of insanity for malice murder, and guilty but mentally ill of felony murder predicated on aggravated assault, felony murder predicated on possession of a firearm by a convicted felon, aggravated assault, possession of a firearm by a convicted felon, and possession of a firearm during the commission of a crime. The Supreme Court vacated both verdicts and remanded Defendant’s case for a new trial. The Supreme Court also vacated the trial court’s order placing Defendant in the Department of Corrections' custody pursuant to the vacated verdicts.
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McHenry Twp. v. Cnty. of McHenry, 201 N.E.3d 550 (Ill. 2022)
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Illinois | 2022 | Democracy & Voting, Voting Rights |
State:
Illinois
Year:
2022
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn the March 2020 primary election, the voters in McHenry Township (Township) rejected a proposition to dissolve the Township. A few months later, the Township's board of trustees adopted a resolution to place a nearly identical proposition on the November 2020 general election ballot. The town clerk refused to place the proposition on the ballot, notifying the Township that the proposition violated the statutory prohibition against "the same proposition" appearing on the ballot more than once within 23 months. The Township filed a compliant for a writ of mandamus or mandatory injunctive relief to compel Defendant (McHenry County) to place the referendum proposition on the November 2020 ballot. The circuit court, citing the March 2020 ballot, dismissed the complaint with prejudice. The appellate court reversed the dismissal, holding that, regardless of whether the proposition could properly appear on the November 2020 ballot, the clerk lacked the statutory authority to make that determination and was obligated the perform the ministerial act of placing the proposition on the ballot. While the Township no longer wishes to pursue dissolution, the Supreme Court nonetheless affirmed the appellate court's judgment because a county clerk is authorized to give notice that a proposition may not be placed on the ballot only when the question is prohibited by the limitations of Section 28-1, which prescribes procedures for initiating, submitting, and printing public questions to referendum and limits the number of public questions that may be submitted to referendum and at which elections they may appear on the ballot. In this case, the reason given for rejecting the proposition was set forth in section 28-7 which addresses that a referendum may not be held more than once in any 23-month period on the same proposition. Because the county clerk invoked the incorrect authority to prohibit the dissolution, the appellate court's judgment is affirmed and the circuit court's judgment is reversed.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In the March 2020 primary election, the voters in McHenry Township (Township) rejected a proposition to dissolve the Township. A few months later, the Township's board of trustees adopted a resolution to place a nearly identical proposition on the November 2020 general election ballot. The town clerk refused to place the proposition on the ballot, notifying the Township that the proposition violated the statutory prohibition against "the same proposition" appearing on the ballot more than once within 23 months. The Township filed a compliant for a writ of mandamus or mandatory injunctive relief to compel Defendant (McHenry County) to place the referendum proposition on the November 2020 ballot. The circuit court, citing the March 2020 ballot, dismissed the complaint with prejudice. The appellate court reversed the dismissal, holding that, regardless of whether the proposition could properly appear on the November 2020 ballot, the clerk lacked the statutory authority to make that determination and was obligated the perform the ministerial act of placing the proposition on the ballot. While the Township no longer wishes to pursue dissolution, the Supreme Court nonetheless affirmed the appellate court's judgment because a county clerk is authorized to give notice that a proposition may not be placed on the ballot only when the question is prohibited by the limitations of Section 28-1, which prescribes procedures for initiating, submitting, and printing public questions to referendum and limits the number of public questions that may be submitted to referendum and at which elections they may appear on the ballot. In this case, the reason given for rejecting the proposition was set forth in section 28-7 which addresses that a referendum may not be held more than once in any 23-month period on the same proposition. Because the county clerk invoked the incorrect authority to prohibit the dissolution, the appellate court's judgment is affirmed and the circuit court's judgment is reversed.
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McIver v. State, 875 S.E.2d 810 (Ga. 2022)
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Georgia | 2022 | Criminal Justice, Access to Justice |
State:
Georgia
Year:
2022
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA jury found Defendant guilty of felony murder and other crimes stemming from the shooting death of his wife. On appeal, Defendant contended that the trial court erred in refusing his request to charge the jury on the lesser grade of the two forms of involuntary manslaughter recognized by the State. At trial, it was alleged that Defendant allegedly fell sleep with a gun on his lap in the back seat of a vehicle, and the gun later inadvertently discharged and killed his wife. In Georgia, involuntary manslaughter can be committed in two ways: (1) causing the death of another without intent to do so through the commission of an unlawful act, a felony; or (2) through the commission of a lawful act in an unlawful manner that is "likely to cause death or great bodily harm," which is a misdemeanor. At trial, the jury was never instructed on (2) but the trial court maintained that the lesser charge was neither supported by the record nor existing precedent. The Supreme Court decided whether the trial court erred in its refusal of the Defendant’s request for the lesser grade of involuntary manslaughter. Clarifying the distinction, the Supreme Court held that "unlawful manner” under the involuntary manslaughter statute denotes a state of mind of criminal negligence, which is a mental state more culpable than civil negligence but less culpable than the mens rea required for the crime of "reckless conduct." Through the procedural history and statutory analysis, the Supreme Court concluded that the Georgia General Assembly's intent was to preserve a distinction between criminal negligence—the mens rea elements of the misdemeanor grade of involuntary manslaughter—and the statutory offense of "reckless conduct." As to the instant case, the trial court refused the request for the jury instruction on misdemeanor involuntary manslaughter because of existing precedent, stating that "any defendant who handles a gun with fatal results, even if unintentional, 'has necessarily committed the misdemeanor of reckless conduct.'" The Supreme Court held that the trial court erred when it ruled, as a matter of law, that a jury can never be instructed on unlawful manner involuntary manslaughter in a shooting death case. Even when there is only slight evidence that a defendant caused the death of another person through the commission of a lawful act but in a criminally negligent manner, a charge on the lower grade offense is warranted. Because such evidence was presented at trial and the instruction was refused, the Supreme Court held that the trial court's refusal constituted harmful error that contributed to the verdict.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A jury found Defendant guilty of felony murder and other crimes stemming from the shooting death of his wife. On appeal, Defendant contended that the trial court erred in refusing his request to charge the jury on the lesser grade of the two forms of involuntary manslaughter recognized by the State. At trial, it was alleged that Defendant allegedly fell sleep with a gun on his lap in the back seat of a vehicle, and the gun later inadvertently discharged and killed his wife. In Georgia, involuntary manslaughter can be committed in two ways: (1) causing the death of another without intent to do so through the commission of an unlawful act, a felony; or (2) through the commission of a lawful act in an unlawful manner that is "likely to cause death or great bodily harm," which is a misdemeanor. At trial, the jury was never instructed on (2) but the trial court maintained that the lesser charge was neither supported by the record nor existing precedent. The Supreme Court decided whether the trial court erred in its refusal of the Defendant’s request for the lesser grade of involuntary manslaughter. Clarifying the distinction, the Supreme Court held that "unlawful manner” under the involuntary manslaughter statute denotes a state of mind of criminal negligence, which is a mental state more culpable than civil negligence but less culpable than the mens rea required for the crime of "reckless conduct." Through the procedural history and statutory analysis, the Supreme Court concluded that the Georgia General Assembly's intent was to preserve a distinction between criminal negligence—the mens rea elements of the misdemeanor grade of involuntary manslaughter—and the statutory offense of "reckless conduct." As to the instant case, the trial court refused the request for the jury instruction on misdemeanor involuntary manslaughter because of existing precedent, stating that "any defendant who handles a gun with fatal results, even if unintentional, 'has necessarily committed the misdemeanor of reckless conduct.'" The Supreme Court held that the trial court erred when it ruled, as a matter of law, that a jury can never be instructed on unlawful manner involuntary manslaughter in a shooting death case. Even when there is only slight evidence that a defendant caused the death of another person through the commission of a lawful act but in a criminally negligent manner, a charge on the lower grade offense is warranted. Because such evidence was presented at trial and the instruction was refused, the Supreme Court held that the trial court's refusal constituted harmful error that contributed to the verdict.
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McKenna v. Soto, 481 P.3d 695 (Ariz. 2021)
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Arizona | 2021 | Democracy & Voting |
State:
Arizona
Year:
2021
Topics:
Democracy & Voting
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingJavier Soto sought placement on the primary ballot as a candidate for the Democratic Party's nomination for Arizona House of Representatives from Legislative District 3. Patrick McKenna, a qualified elector, challenged 204 of Soto's signatures and claimed that Soto had not obtained a sufficient number for inclusion on the ballot per ARS 16-322(A)(3). The Arizona Supreme Court affirmed the trial court's ruling that Soto had complied with ARS 16-351(A) and obtained a sufficient number of signatures to be placed on the ballot. The Supreme Court noted that "[t]typically, a nomination petition need only substantially comply with the statutory requirements; strict compliance is not necessary 'absent a clear statement that the legislature intended a particular form requirement to be indispensable'" and held that signatures which included a day and month but no year substantially complied with the statute's requirement for a "date of signing" because a review of the information contained in the petition sheet (other signatures that had the year and the date of the Secretary of State's revision of the form) revealed the validity of the questioned signatures. The Court also held that signatures which included a street address but not the signer's municipality, state, or zip code substantially complied with the requirement for an "actual residence address" because the information provided was sufficient to locate the signers' voter registration records. Accordingly, the Court found that the trial court had not erred in ruling that Soto had obtained the required number of signatures to be placed on the primary ballot.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Javier Soto sought placement on the primary ballot as a candidate for the Democratic Party's nomination for Arizona House of Representatives from Legislative District 3. Patrick McKenna, a qualified elector, challenged 204 of Soto's signatures and claimed that Soto had not obtained a sufficient number for inclusion on the ballot per ARS 16-322(A)(3). The Arizona Supreme Court affirmed the trial court's ruling that Soto had complied with ARS 16-351(A) and obtained a sufficient number of signatures to be placed on the ballot. The Supreme Court noted that "[t]typically, a nomination petition need only substantially comply with the statutory requirements; strict compliance is not necessary 'absent a clear statement that the legislature intended a particular form requirement to be indispensable'" and held that signatures which included a day and month but no year substantially complied with the statute's requirement for a "date of signing" because a review of the information contained in the petition sheet (other signatures that had the year and the date of the Secretary of State's revision of the form) revealed the validity of the questioned signatures. The Court also held that signatures which included a street address but not the signer's municipality, state, or zip code substantially complied with the requirement for an "actual residence address" because the information provided was sufficient to locate the signers' voter registration records. Accordingly, the Court found that the trial court had not erred in ruling that Soto had obtained the required number of signatures to be placed on the primary ballot.
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McLaughlin v. Bailey, 781 S.E.2d 23 (N.C. 2016)
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North Carolina | 2016 | Labor, Employment & Economic Justice |
State:
North Carolina
Year:
2016
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiffs were a deputy sheriff and a detention counselor at the county jail who brought suit against the Sheriff for wrongful termination in violation of public policy, alleging they were fired for failing to support the Sheriff's reelection campaign and for their political beliefs. The Supreme Court held the Plaintiffs' suit failed for the same reasons as in Young v. Bailey, 781 S.E.2d 277 (N.C. 2016) (holding that a deputy sheriff is not a county employee as such term is defined in NCGS section 153A-99 and therefore is not entitled to the statute's protections). Additionally, for the detention counselor, who was a non-deputy employee of the Sheriff, the court held the Defendant had sufficient job-related reasons for the counselor's termination.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiffs were a deputy sheriff and a detention counselor at the county jail who brought suit against the Sheriff for wrongful termination in violation of public policy, alleging they were fired for failing to support the Sheriff's reelection campaign and for their political beliefs. The Supreme Court held the Plaintiffs' suit failed for the same reasons as in Young v. Bailey, 781 S.E.2d 277 (N.C. 2016) (holding that a deputy sheriff is not a county employee as such term is defined in NCGS section 153A-99 and therefore is not entitled to the statute's protections). Additionally, for the detention counselor, who was a non-deputy employee of the Sheriff, the court held the Defendant had sufficient job-related reasons for the counselor's termination.
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McLaughlin v. Jones, 401 P.3d 492 (Ariz. 2017)
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Arizona | 2017 | LGBTQ+ Rights, LGBTQ+ Discrimination, Civil Rights |
State:
Arizona
Year:
2017
Topics:
LGBTQ+ Rights, LGBTQ+ Discrimination, Civil Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff Kimberly McLaughlin and Suzan McLaughlin were a legally married same-sex couple in California. The couple decided to conceive a child through artificial insemination and, after a failed attempt to become pregnant by Suzan, Kimberly underwent the process and became pregnant. During the pregnancy, the couple moved to Arizona and entered into a joint parenting agreement that declared Suzan as a "co-parent" to the child, which included shared custody, regular visitation, and child support. Furthermore, the couple executed wills that also declared Suzan as an equal parent. Eventually, the couple's relationship deteriorated, Kimberly moved out of their home, and cut off Suzan's contact with their child. Subsequently, Suzan initiated a lawsuit challenging the constitutionality of Arizona's refusal to recognize lawful same-sex marriages performed in other states under A.R.S. Section 12-1841, which precluded her from benefiting from the presumption of paternity. The trial court held that based on Obergefell v. Hodges, 576 U.S. 644 (2015), not having Suzan as a presumptive parent under A.R.S. Section 25-814(A)(1) would violate her Fourteenth Amendment rights as the presumption of paternity applies to a similarly situated man in an opposite-sex marriage. The trial court further held that Kimberly could not rebut Suzan's presumptive parentage under A.R.S. 25-814(C). On appeal, the appellate court similarly held that A.R.S. Section 25-814(A) applies to same-sex spouses which, therefore, made Suzan a presumptive parent and that Kimberly was equitably estopped from rebutting Suzan's presumption of parentage under A.R.S. Section 25-814(C). On a further appeal, the Arizona Supreme Court affirmed the lower courts' decisions and held that because the marital paternity presumption encompasses more than just rights and responsibilities for biologically related fathers, the Arizona law denied same-sex couples the same benefit of the presumption in violation of the Fourteenth Amendment's Due Process and Equal Protection Clauses. Furthermore, the Court extended the marital paternity presumption to same-sex spouses, rather than nullifying the statute altogether, reasoning that doing so would align with the Supreme Court's holding in Obergefell and would better promote strong family units with financial and emotional support by two parents, which was the primary purpose of the marital paternity presumption under Arizona law. The Supreme Court also noted that excluding Suzan from the marital paternity presumption would result in the exclusion of same-sex couples from civil marriage on the same terms and conditions as opposite-sex couples.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiff Kimberly McLaughlin and Suzan McLaughlin were a legally married same-sex couple in California. The couple decided to conceive a child through artificial insemination and, after a failed attempt to become pregnant by Suzan, Kimberly underwent the process and became pregnant. During the pregnancy, the couple moved to Arizona and entered into a joint parenting agreement that declared Suzan as a "co-parent" to the child, which included shared custody, regular visitation, and child support. Furthermore, the couple executed wills that also declared Suzan as an equal parent. Eventually, the couple's relationship deteriorated, Kimberly moved out of their home, and cut off Suzan's contact with their child. Subsequently, Suzan initiated a lawsuit challenging the constitutionality of Arizona's refusal to recognize lawful same-sex marriages performed in other states under A.R.S. Section 12-1841, which precluded her from benefiting from the presumption of paternity. The trial court held that based on Obergefell v. Hodges, 576 U.S. 644 (2015), not having Suzan as a presumptive parent under A.R.S. Section 25-814(A)(1) would violate her Fourteenth Amendment rights as the presumption of paternity applies to a similarly situated man in an opposite-sex marriage. The trial court further held that Kimberly could not rebut Suzan's presumptive parentage under A.R.S. 25-814(C). On appeal, the appellate court similarly held that A.R.S. Section 25-814(A) applies to same-sex spouses which, therefore, made Suzan a presumptive parent and that Kimberly was equitably estopped from rebutting Suzan's presumption of parentage under A.R.S. Section 25-814(C). On a further appeal, the Arizona Supreme Court affirmed the lower courts' decisions and held that because the marital paternity presumption encompasses more than just rights and responsibilities for biologically related fathers, the Arizona law denied same-sex couples the same benefit of the presumption in violation of the Fourteenth Amendment's Due Process and Equal Protection Clauses. Furthermore, the Court extended the marital paternity presumption to same-sex spouses, rather than nullifying the statute altogether, reasoning that doing so would align with the Supreme Court's holding in Obergefell and would better promote strong family units with financial and emotional support by two parents, which was the primary purpose of the marital paternity presumption under Arizona law. The Supreme Court also noted that excluding Suzan from the marital paternity presumption would result in the exclusion of same-sex couples from civil marriage on the same terms and conditions as opposite-sex couples.
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McLinko v. Dep't of State, 279 A.3d 539 (Pa. 2022)
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Pennsylvania | 2022 | Democracy & Voting, Voting Rights |
State:
Pennsylvania
Year:
2022
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingMember of the Bradford County Board of Elections sued the Pennsylvania Department of State and the Acting Secretary of the Commonwealth challenging mail-in voting as a violation of the state constitution. The Supreme Court upheld universal mail-in voting as constitutional, based on a review of state Supreme Court precedent, the recorded history of the state constitution and amendments, and a decades long established practice of allowing absentee voting.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Member of the Bradford County Board of Elections sued the Pennsylvania Department of State and the Acting Secretary of the Commonwealth challenging mail-in voting as a violation of the state constitution. The Supreme Court upheld universal mail-in voting as constitutional, based on a review of state Supreme Court precedent, the recorded history of the state constitution and amendments, and a decades long established practice of allowing absentee voting.
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McNaughton v. Charleston Charter Sch. for Math & Sci., Inc., 768 S.E.2d 389 (S.C. 2015)
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South Carolina | 2015 | Education, Labor, Employment & Economic Justice |
State:
South Carolina
Year:
2015
Topics:
Education, Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn August 2010, Cynthia McNaughton was hired by the Charleston Charter School for Math and Science as an art teacher under a contract contingent on "funding and enrollment." As a teacher, McNaughton received positive feedback from students, parents, and the principal, but on December 1, 2010, the principal informed McNaughton that her employment had been terminated. The school planned to use McNaughton's salary to hire a new math teacher following poor student performance on a recent math achievement test. The school rejected McNaughton's attempts to file a grievance under the stated procedures. McNaughton filed a complaint alleging various claims under contract and tort law. At trial, the jury returned a verdict in favor of McNaughton for $20,623 in actual damages. The verdict also awarded McNaughton $74,112 in special damages for health insurance costs, the home foreclosure McNaughton suffered following her termination, and future "career damages" that she suffered when her termination interrupted and effectively prevented her from completing the state educational licensing program. Although the school moved for a judgment notwithstanding the verdict, the circuit court denied the motion and later ruled in favor of McNaughton on her motion for attorneys' fees. The school appealed, and the Supreme Court considered (1) whether the circuit court should have granted the school's various motions for a directed verdict and judgment notwithstanding the verdict; (2) whether the circuit court erred in allowing the award of special damages; and (3) whether the circuit court erred in awarding attorneys' fees. First, the Court considered the school's argument that, because the employment contract was contingent on "funding and enrollment," the principal's reallotment of funding allowed for the contract to be terminated, as no funding remained to pay McNaughton's salary. The Court disagreed, finding that evidence presented indicated that funding remained available to accommodate McNaughton's salary and that regular practice suggested the principal could have sought further funding from the board. Second, the Court explained that the circuit court has "considerable discretion" in its determination of damages, and held that McNaughton was entitled to recover any loss she actually suffered due to the school's breach of her contract, and further held that McNaughton's presentation of her financial hardship supported the jury's damages awards. Finally, the Court held that the circuit court's award of attorneys' fees was permitted under South Carolina's provision of attorneys' fees under cases involving state action. Justice Pleicones wrote a separate partial dissent against the special damages and attorneys' fees awarded, arguing that the school had not received adequate notice of any special circumstances suggesting such damages could follow their breach, and that the school acted with "substantial justification" in pursuing its defense against McNaughton.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In August 2010, Cynthia McNaughton was hired by the Charleston Charter School for Math and Science as an art teacher under a contract contingent on "funding and enrollment." As a teacher, McNaughton received positive feedback from students, parents, and the principal, but on December 1, 2010, the principal informed McNaughton that her employment had been terminated. The school planned to use McNaughton's salary to hire a new math teacher following poor student performance on a recent math achievement test. The school rejected McNaughton's attempts to file a grievance under the stated procedures. McNaughton filed a complaint alleging various claims under contract and tort law. At trial, the jury returned a verdict in favor of McNaughton for $20,623 in actual damages. The verdict also awarded McNaughton $74,112 in special damages for health insurance costs, the home foreclosure McNaughton suffered following her termination, and future "career damages" that she suffered when her termination interrupted and effectively prevented her from completing the state educational licensing program. Although the school moved for a judgment notwithstanding the verdict, the circuit court denied the motion and later ruled in favor of McNaughton on her motion for attorneys' fees. The school appealed, and the Supreme Court considered (1) whether the circuit court should have granted the school's various motions for a directed verdict and judgment notwithstanding the verdict; (2) whether the circuit court erred in allowing the award of special damages; and (3) whether the circuit court erred in awarding attorneys' fees. First, the Court considered the school's argument that, because the employment contract was contingent on "funding and enrollment," the principal's reallotment of funding allowed for the contract to be terminated, as no funding remained to pay McNaughton's salary. The Court disagreed, finding that evidence presented indicated that funding remained available to accommodate McNaughton's salary and that regular practice suggested the principal could have sought further funding from the board. Second, the Court explained that the circuit court has "considerable discretion" in its determination of damages, and held that McNaughton was entitled to recover any loss she actually suffered due to the school's breach of her contract, and further held that McNaughton's presentation of her financial hardship supported the jury's damages awards. Finally, the Court held that the circuit court's award of attorneys' fees was permitted under South Carolina's provision of attorneys' fees under cases involving state action. Justice Pleicones wrote a separate partial dissent against the special damages and attorneys' fees awarded, arguing that the school had not received adequate notice of any special circumstances suggesting such damages could follow their breach, and that the school acted with "substantial justification" in pursuing its defense against McNaughton.
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McQueer v. Perfect Fence Co., 917 N.W.2d 584 (Mich. 2018)
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Michigan | 2018 | Labor, Employment & Economic Justice, Disability Rights |
State:
Michigan
Year:
2018
Topics:
Labor, Employment & Economic Justice, Disability Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAfter being injured on the job, Plaintiff-employee brought claims against Defendant-employer for failing to procure workers' compensation coverage for him and attempting to evade civil liability under the Worker's Disability Compensation Act (WDCA). The section of the WDCA at issue is intended to prevent an employer from escaping workers' compensation liability by contracting with uninsured contractors to do work that is part of the employer's trade, business, or occupation. This section of the WDCA only applies if the "contractor engages persons to work other than persons who would not be considered employees," and here it is undisputed that the Plaintiff was a direct employee of the Defendant. The Supreme Court ruled that Plaintiff could not seek a civil remedy because the employment relationship was not of the kind protected by the WDCA.
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Justice Vote Breakdown
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Summary of Case Context & Holding
After being injured on the job, Plaintiff-employee brought claims against Defendant-employer for failing to procure workers' compensation coverage for him and attempting to evade civil liability under the Worker's Disability Compensation Act (WDCA). The section of the WDCA at issue is intended to prevent an employer from escaping workers' compensation liability by contracting with uninsured contractors to do work that is part of the employer's trade, business, or occupation. This section of the WDCA only applies if the "contractor engages persons to work other than persons who would not be considered employees," and here it is undisputed that the Plaintiff was a direct employee of the Defendant. The Supreme Court ruled that Plaintiff could not seek a civil remedy because the employment relationship was not of the kind protected by the WDCA.
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MDC Rests. v. Eighth Jud. Dist. Ct., 419 P.3d 148 (Nev. 2018)
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Nevada | 2018 | Health Care, Health Care Access/Funding, Labor, Employment & Economic Justice |
State:
Nevada
Year:
2018
Topics:
Health Care, Health Care Access/Funding, Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2016, the Supreme Court of Nevada heard consolidated cases from throughout the state concerning the Minimum Wage Amendment (MWA) to the Nevada Constitution. This was such a consolidated case, which the Supreme Court remanded following its 2016 decision. The MWA implemented a tiered approach to a minimum wage, which, as the Nevada Supreme Court interpreted it in its 2016 ruling, permitted employers to pay a lower-tiered minimum wage if they offered health benefits. Upon remand, the district court granted summary judgment to the employees as the insurance provided by MDC did not comply with requirements for health insurance under Nevada law. MDC appealed the summary judgment and further requested that the Supreme Court either refer the employees to the Nevada Labor Commissioner to determine any wage complaints, or direct the district court to evaluate the insurance plans under alternative Nevada statutes. The Court held that because the case presented a legal question of statutory interpretation and required no agency expertise, it would be improper to direct the employees to the Nevada Labor Commissioner. The Court further held that the district court had improperly applied Nevada Revised Statutes (NRS) Chapters 608, 689A, and 689B, which mandate substantive requirements for health insurance. Instead, after considering the purpose, meaning, and text of the MWA, the Court determined that an employer may pay the reduced minimum wage if they can demonstrate that the benefit offered provides "a value greater than or equal to the wage of an additional dollar per hour" and that such benefit was provided to the employee and their Defendants for premiums equal to or less than 10 percent of the employee's gross taxable income.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 2016, the Supreme Court of Nevada heard consolidated cases from throughout the state concerning the Minimum Wage Amendment (MWA) to the Nevada Constitution. This was such a consolidated case, which the Supreme Court remanded following its 2016 decision. The MWA implemented a tiered approach to a minimum wage, which, as the Nevada Supreme Court interpreted it in its 2016 ruling, permitted employers to pay a lower-tiered minimum wage if they offered health benefits. Upon remand, the district court granted summary judgment to the employees as the insurance provided by MDC did not comply with requirements for health insurance under Nevada law. MDC appealed the summary judgment and further requested that the Supreme Court either refer the employees to the Nevada Labor Commissioner to determine any wage complaints, or direct the district court to evaluate the insurance plans under alternative Nevada statutes. The Court held that because the case presented a legal question of statutory interpretation and required no agency expertise, it would be improper to direct the employees to the Nevada Labor Commissioner. The Court further held that the district court had improperly applied Nevada Revised Statutes (NRS) Chapters 608, 689A, and 689B, which mandate substantive requirements for health insurance. Instead, after considering the purpose, meaning, and text of the MWA, the Court determined that an employer may pay the reduced minimum wage if they can demonstrate that the benefit offered provides "a value greater than or equal to the wage of an additional dollar per hour" and that such benefit was provided to the employee and their Defendants for premiums equal to or less than 10 percent of the employee's gross taxable income.
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