State Supreme Court Data Tracker

Summary of Case Context & HoldingDefendant's driving, appearance, and responses to questions gave an officer probable cause to arrest him on a Driving While Intoxicated. The officer asked the Defendant to step out of the car and searched him, discovering a switchblade, after which the Defendant was arrested. In court, the officer said he did not intend to arrest Defendant until he found the switchblade. The Court of Appeals held that, although the officer hypothetically had the authority to search Defendant as a search "incident to a lawful arrest," since the officer said there would not have been an arrest but for the fruits of his search, the search was not "incident" to the arrest and therefore the Court of Appeals suppressed the knife as evidence and dismissed the indictment.

Summary of Case Context & HoldingDefendant, who was a juvenile, was convicted of first-degree murder and two counts of attempted murder with a firearm in a drive-by shooting when he was 16. Defendant was prosecuted as an adult and sentenced to the mandatory minimum sentence of 45 years' imprisonment for first degree murder with a firearm enhancement, and two mandatory minimum sentences of 26 years' imprisonment for attempted murder with a firearm enhancement. Defendant argued on appeal that his sentence was unconstitutional under Miller v. Alabama, 567 U.S. 460 (2012), which prohibited life in prison without the possibility of parole for juvenile offenders and emphasized that a mandatory sentence scheme for juveniles would prevent the consideration of mitigating factors. The Supreme Court vacated Defendant’s sentence as unconstitutional under the Eighth Amendment and held that Defendant was entitled to resentencing under an Illinois statute for juvenile offenders that required the sentencing judge to consider mitigation factors and made firearm enhancements discretionary rather than mandatory.

Summary of Case Context & HoldingA 17-year-old juvenile was indicted on two counts of criminal sexual assault under the requisite Illinois statute. Because he was 17, the relevant provision of the Juvenile Justice Act (JJA) assigning jurisdiction over the case to the juvenile justice courts did not apply to Defendant and he was to be tried as an adult. After he was indicted, the state legislature amended the JJA such that juveniles under 18 years would be tried in the juvenile justice courts. The JJA, as amended, had a savings clause stating that the amendment applied to "violations committed on or after the effective date" of the amending act, i.e., after January 1, 2014 (after Defendant was indicted). The Defendant subsequently argued that the savings clause violated the equal protection clause of the state and federal constitution as applied to him. The district court agreed, and the State appealed directly to the state Supreme Court. On appeal, the Supreme Court reversed. First, the Court noted that the same standards applied in an equal protection challenge under both the Illinois and U.S. constitutions. Because the "legislative classification" making a distinction based on age did not affect a "fundamental right" or "discriminate against a suspect class," rational basis review applied. The Court held that the age-based classification was rationally related to the legislative intent, therefore, the Defendant did not demonstrate a violation of his right to equal protection and should be tried as an adult.

Summary of Case Context & HoldingDefendant, who was charged with first-degree murder and other related offenses, sought to file a successive postconviction petition based on a claim of actual innocence. At trial, Defendant had made a statement describing conversations with others in which he admitted his participation in the shooting of a victim and the burning of the victim's body. In his petition, Defendant submitted affidavits from three individuals regarding, among other events, a recollection of a shooting incident and observations of an alternate suspect. However, because none of the affiants witnessed the murder or the burning of the body, and because neither specific observations of the victim's murder or the burning of the body were addressed in the affidavits, the circuit court held that these affidavits merely conflicted with the trial evidence and were not conclusive enough to probably change the outcome on retrial. The Supreme Court held that to file a successive postconviction petition based on actual innocence, the new evidence does not need to be completely dispositive of petitioner’s innocence, but rather only be of such a conclusive character as to probably change the result upon retrial. Furthermore, the Supreme Court noted the leave-to-file stage focuses not on whether the new evidence is inconsistent with the trial evidence, but rather if it is possible for a trier of fact to accept their veracity. Accordingly, the Supreme Court remanded the case for further proceedings.

Summary of Case Context & HoldingAfter a transgender woman was assaulted with a firearm, prosecutors filed charges against the assailant under the Ethnic Intimidation Act, Michigan’s hate crime law. On appeal, the Michigan Court of Appeals held that transgender people were not protected under this statute. The Michigan Supreme Court ordered the court of appeals to reconsider its ruling in light of recent U.S. Supreme Court precedent, which ultimately led the court of appeals to reverse its decision and hold that crimes against transgender people are covered under Michigan’s hate crime law under the category of gender.

Summary of Case Context & HoldingDefendant, a 17 year old, pled guilty to one count of criminal drug possession and was sentenced to five years of prison and two years of post-release supervision. Defendant appealed, arguing that the sentencing court failed to address whether he could be considered a "Youthful Offender," a determination for 16- to 19-year old in New York which carries benefits such as a vacated conviction and lesser jailtime. The Court of Appeals found that, despite the fact that Defendant did not ask for a Youthful Offender determination, all there must be a Youthful Offender determination in every case where a defendant may be eligible, and that such defendant cannot waive this right via a plea deal.

Summary of Case Context & HoldingDefendant was arrested in connection with the robbery of a bar and the murder of the bar's owner. He was driven to the police station, put in an interrogation room, and advised of his Miranda rights. He requested a lawyer before and after being advised of his rights. Officers then stopped interrogating him, and he spent approximately 24 hours alone, handcuffed to a wall, while he repeatedly requested to use the phone. Despite his requests, he was not allowed to use the phone. Eventually, Defendant agreed to speak with detectives. After being advised of his Miranda rights, he provided a statement. The trial court denied Defendant's motion to suppress the statement as involuntary. Following a jury trial, Defendant was convicted of first-degree murder, armed robbery, and burglary. Defendant filed a post trial motion challenging the denial of the motion to suppress, which was denied. The appellate court affirmed and found Defendant's statements to be voluntary. The Supreme Court held that Defendant preserved the argument of involuntariness for review because he had raised it in his motion to suppress, post trial motions, and briefs before the appellate court. Further, the factual and legal bases for his argument had not changed. Additionally, the Supreme Court held that the officers had violated the Illinois Criminal Procedure Code by detaining Defendant for 24 hours and preventing him from exercising his invoked right to counsel. Considering the totality of the circumstances, and the incommunicado detention of Defendant for a prolonged period, the Court held that the statements obtained were involuntary and should have been suppressed. However, given the other evidence proffered at trial, the Court held that the error was harmless beyond a reasonable doubt.

Summary of Case Context & HoldingThe Supreme Court considered whether Michigan’s then-new sentencing statute introducing an updated framework for sentencing juveniles convicted of first-degree murder violated the federal Constitution. The Supreme Court held that the framework did not violate the Sixth or Eighth Amendments because the framework does not require a judge to find any particular fact before imposing life without parole. The Supreme Court also affirmed that “[a] judge, not a jury, must determine whether to impose a life-without-parole sentence or a term-of-years sentence.”

Summary of Case Context & HoldingIn trial court, Defendants in three cases were not allowed to cross-examine police officers regarding allegations of prior misconduct by these officers in unrelated federal lawsuits. The Court of Appeals held that there is no categorical prohibition against such cross-examination, and determination as to whether to permit such inquiries for impeachment purposes lies at the discretion of the trial court judge.

Summary of Case Context & HoldingDefendant plead guilty to a reduced charge of attempted carrying of a concealed weapon without a permit (CCW). A Michigan statute allows a court to delay sentencing for 1 year to give the defendant an opportunity to prove eligibility for leniency. The Defendant asked for a sentencing delay to finish college, and the judge scheduled the next hearing for one year and one day after the statutory deadline, so that the court would lose jurisdiction over the case. The prosecution objected, but one year later the court dismissed the case entirely citing lack of jurisdiction. The Supreme Court held that the trial judge demonstrated overt hostility to the prosecution of the case by manipulating the scheduling of sentencing in order to thwart the prosecutor’s charging decision and by entirely dismissing the case. The Supreme Court remanded for sentencing before a different judge.

Summary of Case Context & HoldingDefendant was charged with home invasion and aggravated unlawful restraint, but could not remember the events due to brain damage from a self-inflicted gunshot wound. The State appealed the trial court’s finding that Defendant was not restored to fitness to stand trial, arguing that amnesia was not in and of itself sufficient to support a finding of unfitness. Noting that this issue was one of first impression that the Supreme Court had not previously considered, the Supreme Court looked to People v. Schwartz, 482 N.E.2d 104 (Ill. 1985), in which the court held that the defendant, Schwartz, was able to understand the nature and purpose of the proceeding against him and thus Schwartz’s amnesia regarding events on the day of his offenses did not render him unfit to stand trial. In the present case, the Supreme Court held that that fitness must be judged based on the totality of the circumstances, including factors like the inability to communicate with counsel and the defendant’s mens rea surrounding the incident. The Supreme Court further held that amnesia as to the events surrounding the crime charged does not per se create unfitness for trial. However, regarding the Defendant specifically, the Supreme Court noted that three psychiatric experts concluded that Defendant had no recollection of the events and two of them also concluded that Defendant’s ability to assist in his own defense would be affected by short-term memory impairments. The Supreme Court thus affirmed the appellate court’s judgment that Defendant remained unfit to stand trial because, under the totality of circumstances in this case, such a finding was not against the manifest weight of the evidence.

Summary of Case Context & HoldingDefendant was convicted of second-degree murder and second-degree child abuse following a jury trial. During the trial, the trial judge asked the defense's medical expert multiple questions that demonstrated partiality. Prior to this decision, there were two formulations of the test for whether a trial judge’s conduct pierced the veil of judicial impartiality being applied by lower courts: the “unduly influence” standard and the “may well have . . . quite possibly could have” standard. The Supreme Court took the opportunity in this case to offer more substantive guidance and articulate a singular, clear test. The Supreme Court held that a judge’s conduct pierces the veil of judicial impartiality and violates the constitutional guarantee of a fair trial when, considering the totality of the circumstances, it is reasonably likely that the judge’s conduct improperly influenced the jury by creating the appearance of advocacy or partiality against a party. The Court reversed and remanded the case for a new trial before a different judge.

Summary of Case Context & HoldingDefendant, who was convicted of possession of a stolen motor vehicle, was sentenced to six years in prison as a Class X offender under Section 5-4.5-95(b) of the Unified Code of Corrections, which provided for mandatory sentencing of defendants over 21 with two predicate felony offenses. Defendant argued on appeal that Class X sentencing should not apply because he was 17 at the time of the first offense in 2013, and in 2014, an amendment to the Juvenile Court Act raised the age for exclusive juvenile court jurisdiction from 16 to 17. Applying plain error review to the forfeited claim (because Defendant raised it for the first time in a post sentencing motion), the Supreme Court held that conflicting appellate court decisions before the statutory amendment suggested that the legislature intended to resolve such ambiguity. The Supreme Court thus held the offense underlying Defendant’s conviction as a 17 year old was not a qualifying offense, and affirmed the appellate court’s judgment vacating the Class X sentence and remanding for resentencing.

Summary of Case Context & HoldingAfter the U.S. Supreme Court decisions in Miller v. Alabama, 567 US 460 (2012) and Montgomery v. Louisiana, 577 US 190 (2016), a defendant in Michigan appealed his plea deal stemming from murders committed when he was a juvenile. The Court found that the textual differences between the 8th amendment (“cruel and unusual punishment”) and the Michigan Constitution’s ban on (“cruel or unusual punishment”) meant that Michigan provided slightly broader protections than the U.S. Constitution. As such, the Supreme Court held that a life sentence with the possibility of parole for a defendant who committed second-degree murder while a juvenile constitutes cruel or unusual punishment because it effectively denies a meaningful opportunity for release.

Summary of Case Context & HoldingDefendant, a noncitizen, faced several charges after attacking the mother of his children. The defendant argued that the Sixth Amendment entitled him to a jury trial given that these offenses carried the risk of deportation. The lower appeals court denied this motion and he was convicted for said deportable offenses. The Court of Appeals reversed this decision, in the first case of its kind under its jurisdiction, finding that the Sixth Amendment does indeed entitle a defendant to the right to a jury trial if indicted under deportable offenses.

Summary of Case Context & HoldingDefendant was charged with open murder and mutilation of a dead body. After his arrest, he was taken to jail and read his Miranda rights. The Defendant invoked his right to counsel and questioning ceased. The next day, while speaking with a jail psychologist, the Defendant stated that he wanted to “get something off of his chest.” The jail administrator contacted the police and prosecutor. The prosecutor apparently informed the court of Defendant’s request for an attorney, and the court sent an attorney to the jail. After the attorney and the police officers arrived at the jail, the jail administrator took the police officers to speak with Defendant and asked the attorney to wait in the jail lobby while the officers determined Defendant’s intentions. Defendant was again read his Miranda rights, which he waived without again requesting an attorney and without being made aware of the attorney’s presence at the jail. He made incriminating statements concerning his involvement in the murder. The trial court suppressed the incriminating statements made by the Defendant. The Supreme Court held that “[o]nce it is determined that a suspect’s decision not to rely on his rights was uncoerced, that he at all times knew he could stand mute and request a lawyer, and that he was aware of the State’s intention to use his statements to secure a conviction, the analysis is complete and the waiver is valid as a matter of law.” The Supreme Court reversed the trial court's suppression of incriminating statements made by Defendant during custodial interrogation and remanded to the trial court.

Summary of Case Context & HoldingThe Court found that both the 8th amendment (“cruel and unusual punishment”) and the Michigan Constitution’s ban on “cruel or unusual punishment” create a presumption that life in prison without the possibility of parole is a disproportionate sentence for those who commit relevant crimes as a juvenile. Due to this determination, the Court imposed a burden on the prosecution to overcome this presumption with clear and convincing evidence. Here, the juvenile defendant convicted of felony murder as an aider and abettor, had their case remanded for resentencing under this new framework.

Summary of Case Context & Holding17-year old Defendant pled guilty to a designated class E felony sex offense, was designated a Youthful Offender, and sentenced to 10 years' probation. Class E felonies are subject to the same sentences for Youthful Offenders as others convicted of such felonies. At the time of enactment of the relevant Youthful Offenders statute, all class E felonies were subject to only 5 years probation. The statute was later updated so that designated class E felonies were subject to 10 years probation. The Defendant argued that, since the legislature did not specifically update the Youthful Offenders statute to also reflect a maximum 10 years' probation for designated class E felonies, the legislature intended for the Youthful Offenders maximum for such felonies to remain 5 years' probation. The Court of Appeals disagreed, holding that since this claim is unproven, they must rely only on text of the Youthful Offenders statute, which refers back to the amended statute, by which 10 years' probation is allowable.

Summary of Case Context & HoldingSeventeen-year-old Defendant Storm Lang was charged with four felony counts of sexual abuse, and two misdemeanor counts of sexual abuse stemming from his sexual assault of three children ages 5, 7 and 12 years old. During the sentencing proceeding, the court of appeals decided the Youthful Offender adjudication was inappropriate and reminded Lang that he had waived his right to appeal when he had accepted his plea bargain. Lang challenged both the waiver and the denial of Youthful Offender status arguing that both were invalid and unenforceable. The Court of Appeals decided that Lang was entitled to relief because the trial court mischaracterized the appellate rights waived as encompassing not only an absolute bar to the taking of a direct appeal but also all post-conviction relief separate from the direct appeal and thus, it could not be said that their appeal waivers were knowingly and voluntarily made. However, the Court of Appeals concluded that the remainder of the waiver was valid and enforceable, foreclosing review of the Youthful Offender determination.

Summary of Case Context & HoldingDefendant was convicted of depraved indifference murder of his infant son based on both the video tape of a 9.5 hour investigation during which police falsely represented that his wife had accused him of the murder, that she would be the target of the investigation if he did not take responsibility, and that his confession would help to save his son's life, who had already died in the hospital. Defendant moved to suppress this interrogation and was denied. The Court of Appeals overturned this denial, reversed the conviction, and directed a new trial, finding that the Defendant's statements were not demonstrably voluntary, as any parent would confess to a crime if they believed it would save their child's life.

Summary of Case Context & HoldingThe Supreme Court addressed what experts may testify to in cases where child sexual abuse is alleged. The Supreme Court extended three of their prior precedents to hold that experts may not testify to the complaint's veracity because it improperly interferes with the role of the jury. Specifically, the Supreme Court held an expert may not testify that children overwhelmingly do not lie when reporting sexual abuse. Further, the Supreme Court held that experts may not testify that a child has been assaulted or abused without physical evidence corroborating the child's account. In both cases here, the Supreme Court remanded for new trials excluding this type of testimony from experts.

Summary of Case Context & HoldingDefendant, a caregiver to a physically disabled ten-year old girl, pled guilty to a charge of reckless endangerment arising out a severe skin injury requiring skin grafts that the girl received while in the Defendant's care. Following a civil jury unanimously concluding that the Defendant was not at fault, as well as further evidence coming to light indicating the same, the Defendant moved to vacate the judgement on a claim of "actual innocence." Focusing on matters of law rather than matters of fact, the court of appeals refused to allow her to vacate her guilty plea, finding that the relevant statute does not entitle a defendant who has entered in a guilty plea to move to vacate a conviction, regardless of actual innocence, unless the claim is based on DNA evidence.

Summary of Case Context & HoldingAfter Defendant struck and killed a pedestrian, her family contacted a lawyer who instructed law enforcement not to question or test his client. Defendant consented to a breathalyzer test at the same time, without being informed of the attorney's communication. Based on prior case law, the Court of Appeals reaffirms that suspected drunk drivers have time-limited rights to seek legal assistance before chemical testing, and this right cannot be waived prior to the police making the accused aware that a lawyer has made contact on the accused's behalf, regardless of whether the accused requested this lawyer.

Summary of Case Context & HoldingDefendant pled guilty to first degree murder after officers allegedly coerced a confession from him through the use of physical abuse and false information. After an article was published investigating police coercion of witnesses in Chicago, the State moved to vacate Defendant's conviction and grant him a new trial. Defendant then filed a verified petition for a certificate of innocence. The trial court denied his petition. The appellate court affirmed, stating that a defendant who pleads guilty is one who "cause[d] or [brought] about his or her conviction" and is therefore barred from obtaining a certificate of innocence under the statute. The Supreme Court reversed and found that the statute did not preclude a defendant from obtaining a certificate just because he had pled guilty. The Court held that the appellate court erred in interpreting the statute to categorically bar certificates for those who have pled guilty because there was no language in the statute that called for that interpretation. Further, as relevant here, the statute required Defendant show he did not voluntarily cause or bring about the conviction. Defendant made that showing by presenting unrebutted evidence of police coercion and physical abuse, but the trial court improperly looked into the underlying record and made its own credibility determinations. There was considerable evidence that his confession was involuntary, therefore, he was entitled to a certificate of innocence.

Summary of Case Context & HoldingIn 2014, Defendant, was charged with committing various crimes against a 10-year-old child and pleaded guilty to sexual abuse in the first degree. Defendant was initially placed on interim probation. Due to Defendant's subsequent arrest on other charges stemming from conduct occurring after his plea, Defendant's probation was revoked and he was sentenced to a three-year term of imprisonment. The Court of Appeals held that the Appellate Division had authority to reverse a county court order that designated Defendant a level three sex offender under the Sex Offender Registration Act, based on a risk factor point assessment. In the absence of an erroneous ruling or any applicable statutory or other jurisdictional limitation on the Appellate Division’s authority, the Court of Appeals declined to restrain the Appellate Division from remitting the county order.

Summary of Case Context & Holding16-year old Defendant was charged with second degree murder for shooting a teenaged bystander during an argument, and spent six years in prison before pleading guilty. During this time, the prosecution sought cooperation against the Defendant by his Co-Defendant through various means, then faced administrative delays in beginning the trial. The Court of Appeals held that, despite the absence of bad faith for these delays on behalf of the government, the Defendant's imprisonment for such a long time violated his right to a speedy trial, and dismissed his indictment.

Summary of Case Context & HoldingDefendant, who was convicted of first degree murder and attempted armed robbery as a juvenile, sought leave to file a successive postconviction petition pursuant to the Post Conviction Hearing Act (725 ILCS 5/122-1) challenging his sentence for murder after his initial pro se postconviction petition was summarily dismissed. Defendant alleged that his de facto life sentence violated the Eighth Amendment because the sentencing court had not first made a finding of permanent incorrigibility or specifically addressed the attendant characteristics of youth discussed in Miller v. Alabama, 567 U.S. 460 (2012). The Supreme Court explained that both statutory and case law in Illinois contemplate the filing of only one postconviction petition, unless fundamental fairness requires otherwise under the “cause and prejudice” or “fundamental miscarriage of justice” exceptions. The Supreme Court further noted that Defendant had been sentenced under a sentencing scheme that granted the sentencing court the discretion to consider Defendant’s youth and attendant circumstances and to impose less than a de facto life sentence, and that the sentencing court had reviewed an “extensive” presentence investigation report. First, the Supreme Court held that Defendant’s discretionary life sentence comported with the Eighth Amendment without the sentencing court first making a finding of permanent incorrigibility, overruling People v. Holman, 91 N.E.3d 849 (Ill. 2017). Noting that it had to follow frameworks adopted by the U.S. Supreme Court, the Supreme Court agreed with the State that Holman did not accurately reflect Eighth Amendment law following Jones v. Mississippi, 593 U.S. 98 (2021), in which the U.S. Supreme Court found that a separate factual finding of permanent incorrigibility was not required to impose a discretionary life sentence without the possibility of parole on a minor. Second, the Supreme Court held that Defendant’s failure in his initial postconviction petition to raise the Eighth Amendment challenge to the sentence did not prejudice him, as Defendant received the constitutionally required procedure under Miller when the sentencing court reviewed the entire 200-page presentence investigation report, thus barring a successive petition raising an Eighth Amendment claim.

Summary of Case Context & HoldingDefendant was convicted of armed robbery with a firearm following a jury trial where he represented himself. Prior to trial, Defendant informed the court of his desire to proceed pro se, and represented that he had completed two years of college and had experience with the criminal justice system. The trial court allowed the Defendant to proceed pro se, but incorrectly admonished him that he was eligible for a maximum sentence of 60 years rather than 75 years in prison. On appeal, Defendant argued that he was entitled to a new trial because the trial court had failed to properly admonish him under Rule 401(a) (Illinois’ rule governing the waiver of counsel) by informing him that he was eligible for a 60-year extended-term sentence rather than the correct 75-year maximum sentence. The Supreme Court held that (1) the trial court had substantially complied with Rule 401(a) despite misstating the sentencing range, as it was correct in all other respects and provided Defendant with a copy of the charging instrument; (2) the Defendant’s waiver of counsel was made freely, knowingly, and intelligently, in part because the record showed he had previously represented himself on appeal in a felony and reiterated his desire to proceed pro se for a speedy trial multiple times; and (3) that there was no basis to conclude the Defendant was prejudiced by the incorrect admonishment.

Summary of Case Context & HoldingA local Native American church placed religious significance on a 20-by-30-foot site along the San Antonio River. Church members hold religious ceremonies at this location throughout the year, with particular reverence for the surrounding cypress trees and the cormorant birds that nest nearby. Historical evidence indicates that similar spiritual practices have taken place in this area for thousands of years. The sacred area has been located within a municipal park overseen by the City of San Antonio for more than 125 years. Following certain issues with the park, including bird excrement and fallen trees, San Antonio voters approved a bond package for park improvements. The City used the funds to propose an improvement plan that included removing the existing trees and deterring birds from nesting nearby. While the plan was still under consideration, the City temporarily blocked access to the area after a large tree branch fell nearby. A member of the church sued the City, and a federal district court granted immediate relief, requiring the City to remove the tree branch and reopen the sacred area. The Plaintiff further asserted that the City’s improvement plan would destroy the sacred area by eliminating trees and deterring cormorants from nesting, both of which were necessary components of the church’s religious services. In addition to federal and certain state claims, the Plaintiff also argued that the proposed plan violated his rights under the recently implemented Article I § 6-a of the Texas Constitution, which forbids the government from enacting any rule that prohibits or limits religious services. After the district court denied the Plaintiff’s request for a temporary restraining order, the Fifth Circuit Court of Appeals affirmed the decision. Following Plaintiff’s request for rehearing, the Circuit certified the following question to the Texas Supreme Court: whether Article I § 6-a imposed a categorical bar on any limitation of religious services. After reviewing the history of the amendment and similar provisions, the Court held that both the text of the clause and the legislative history of the 2021 amendment suggested that the clause was intended to create a categorical bar, when applicable. The Court then went beyond the certified question to consider whether Article I § 6-a was intended to be so broad as to prevent government actions taken to maintain and preserve public property. The Court answered the expanded question by concluding that the scope of the clause was not unlimited and that certain guardrails must exist. Upon further review of the legislative history and the amendment’s language, the Court determined that the clause was not intended to apply to all government actions broadly, but only to those specifically aimed at affecting religious services. As a result, the preservation and maintenance of public lands did not fall within the scope of Article I § 6-a, and the clause did not apply to the City’s proposed park improvement plan.

Summary of Case Context & HoldingIn this case, the Florida Supreme Court determined the constitutionality of Florida's new death penalty law following the U.S. Supreme Court's decision in Hurst v. Florida, 577 U.S. 92 (2016). In Hurst, the U.S. Supreme Court determined that part of Florida's sentencing scheme was unconstitutional, so the Florida legislature enacted a new law requiring that in death penalty cases, a unanimous jury, not the judge, must find all aggravating factors, and at least 10 jurors must recommend the death penalty. The Florida Supreme Court determined that this law was also unconstitutional because it did not require a unanimous jury to recommend a death sentence as mandated in Hurst, and as required under Florida's constitution. Subsequently, the Supreme Court held that while the death penalty was still valid in Florida, the law requiring only 10 jurors to recommend the death sentence was unconstitutional, and thus invalid. Later in 2020, this decision was partly abrogated by Santiago-Gonzalez v. State, 301 So. 3d 157 (Fla. 2020), where the Supreme Court held that the weight and sufficiency of aggravating factors outweighing mitigation circumstances in death penalty cases is not an element that need to be determined by the jury beyond a reasonable doubt.

Summary of Case Context & HoldingA school reform commission (SRC) for a financially distressed district sought to cancel a collective bargaining agreement (CBA) between the district and a teacher’s union. The statute authorizing the SRC forbid the cancellation of “teachers’ contracts.” The Supreme Court held that CBAs are “teachers’ contracts” and therefore excepted from the SRC’s cancellation powers.

Summary of Case Context & HoldingAn insurance company sought reimbursement from a resident for a landlord's claim for property damage sustained in a fire that originated in a tenant-owned clothes dryer. The tenant failed to remit payment, and the insurance company sued the tenant for negligence and breach of contract for noncompliance with the reimbursement provision in her lease. A jury failed to find the tenant negligent in causing the fire, but held that the tenant was contractually liable for the loss under the terms of her lease. The trial court subsequently granted the tenant's motion for judgment notwithstanding the verdict rendering a take nothing judgment. The court of appeals affirmed determining that the lease provision was void and unenforceable. On appeal, the Court considered whether public policy embodied in the Texas Property Code precluded enforcement of a residential-lease provision imposing liability on a tenant for property losses resulting from “any other cause not due to [the landlord's] negligence or fault.” The Court affirmed in part and reversed in part holding: (1) there were circumstances where the disputed lease provision could be enforced without contravening the Property Code and was therefore not per se void as against public policy; and (2) the record did not conclusively establish the factual predicate necessary to preclude its enforcement as the jury merely failed to find that the tenant's negligence caused the fire, but did not make affirmative findings on causation or a positive finding that the tenant was not at fault and did not cause the damage. The Court remanded for consideration of the tenant's remaining defenses to enforcement.

Summary of Case Context & HoldingHarry Franklin Phillips murdered Bjorn Thomas Svenson in 1982, and his conviction and death sentence for that crime became final in 1998. A postconviction court in 2006 fully adjudicated and denied Phillips's claim that he is intellectually disabled and, under the rule of Atkins v. Virginia, 536 U.S. 304 (2002), constitutionally ineligible for the death penalty. The Supreme Court affirmed the denial of Phillips's intellectual disability claim in 2008. Phillips sought yet another determination of his intellectual disability, relying in part on the Supreme Court's decision in Walls v. State, 213 So. 3d 340 (Fla. 2016), where the Florida Supreme Court held that the United States Supreme Court's decision in Hall v. Florida, 572 U.S. 701 (2014), is retroactive to cases where there has already been a finding that the defendant is not intellectually disabled. Contrary to its prior decision in Walls, the Supreme Court held that Hall does not apply retroactively and affirmed the circuit court's order denying Phillips's successive motion for postconviction relief. In reaching this conclusion, the Supreme Court determined that it had clearly erred in its prior analysis of whether Hall warranted retroactive application in accordance with the standards set out in Witt v. State, 387 So. 2d 922 (Fla. 1980). The Court focused on the "fundamental significance" prong of the Witt analysis regarding whether a change in the law applies retroactively and determined that Hall does not place beyond the authority of the State the power to regulate certain conduct or impose certain penalties. Instead, Hall merely more precisely defined the procedure that is to be followed in certain cases to determine whether a person facing the death penalty is intellectually disabled. Hall’s limited procedural rule did nothing more than provide certain defendants—those with IQ scores within the test's margin of error—with the opportunity to present additional evidence of intellectual disability. Thus, Hall does not constitute "a development of fundamental significance that places beyond the State of Florida the power to impose a certain sentence."

Summary of Case Context & HoldingIn 2007, Public Act 94-1111 was enacted into law, adding a new provision to the code which governed the Teachers' Retirement System (TRS). The provision allowed an officer or employee of a statewide teachers' union to establish service credit in the TRS for his or her union work prior to becoming certified as a teacher. The individual had to meet a few requirements in order to obtain this benefit. Plaintiff worked as a lobbyist for the Illinois Federation of Teachers from 1997 until his retirement in 2012. In 2006, Plaintiff obtained a substitute teaching certificate and worked for one day as a substitute teacher, qualifying him for the union benefits. Thereafter, Plaintiff contributed significant amounts to the union service. In 2011, the Chicago Tribune published an article which identified the Plaintiff by name and discussed the 2007 law which had allowed him to receive TRS benefits. In 2012, the 2007 TRS amendment was repealed, resulting in the TRS eliminating the service credits Plaintiff had received for his union service and issuing a refund of his contributions. Plaintiff sued the TRS, arguing that the repeal of the 2007 amendment violated the Illinois Constitution's Pension Protection Clause, claiming that the legislation was intentionally enacted with a date cutoff that would affect him. The trial court ruled in favor of the Defendants, determining both that the Plaintiff lacked standing to sue regarding the repeal of the 2007 amendment and that the provision in the original 2007 amendment that limited benefits based on a certain eligibility-cutoff date was special legislation; therefore, its 2012 repeal was valid. On direct appeal, the Supreme Court first held that the 2007 amendment was not special legislation merely because it included an eligibility cutoff date, and that there are numerous rational reasons why a legislature may choose to use such a cutoff date. Further, because the 2007 amendment was not special legislation, its repeal was not necessarily valid. The Supreme Court held that the legislature had put forward no legal justification for the reduction or elimination of pension benefits that the Plaintiff was awarded pursuant to the 2007 amendment. As a result, the 2012 repeal implicated the Illinois Constitution's Pension Protection Clause, which specifies that once a person becomes a member of a public retirement system or pension, subsequent changes that would diminish those benefits can not be applied to that person. Justice Theis wrote a dissent noting that the conditions the 2007 amendment were implemented under suggested that it was constructed and timed in such a way to allow for certain teacher organization employees to pass the deadline. As a result, in Theis's view, this was special legislation and its repeal should have been considered valid.

Summary of Case Context & HoldingIn December 2013, two Houston taxpayers filed a lawsuit in state court against the City of Houston (City) and then-Mayor Annise Parker challenging the City's provision of benefits to same-sex spouses of City employees who were legally married in another jurisdiction. Prior to the U.S. Supreme Court's ruling in United States. v. Windsor, 570 U.S. 744 (2013) (declaring that federal denial of same-sex marriages, Section 3 of the Defense of Marriage Act (DOMA), violated the Due Process Clause of the Fifth Amendment), the City amended its charter and the State amended the Texas Family Code and Texas Constitution to preserve the traditional view of marriage. Plaintiffs argued that authorizing expenditures for same-sex spousal benefits violated Texas' and the City's own DOMAs, because Windsor only addressed the federal DOMA. Plaintiffs sought unspecified actual damages and both temporary and permanent injunctions prohibiting the City from providing benefits to same-sex employees married outside of Texas. The Mayor and City filed pleas to the jurisdiction asserting governmental immunity. The trial court denied the pleas and granted the Plaintiffs' request for a temporary injunction, and the Mayor filed an interlocutory appeal to the Supreme Court challenging denial of the pleas and the grant of the temporary injunction. The landmark U.S. Supreme Court case of Obergefell v. Hodges, 576 U.S. 644 (2015) held that state DOMAs violate the Due Process and Equal Protection Clauses of the Fourteenth Amendment, and concluded that states cannot exclude same-sex couples from civil marriage or refuse to recognize a lawful same-sex marriage performed in another State on the grounds of its same-sex character. Following this ruling, the Mayor filed a brief in the court of appeals, arguing that Obergefell required reversal of the injunction. However, Plaintiffs argued that Obergefell's holding did not require that States pay taxpayer-funded benefits for same-sex relationships. The court of appeals reversed the trial court's temporary injunction and remanded the case to the trial court for proceedings consistent with Obergefell and De Leon v. Abbott, 791 F.3d 619 (5th Cir. 2015), which held certain provisions of the Texas Constitution and Texas Family Code denying same-sex couples the right to marry unconstitutional and enjoined the State from enforcing them. The Supreme Court granted Plaintiffs' petition for review, reversed the court of appeals' judgment, vacated the trial court's temporary injunction and remanded to the trial court. First, the Supreme Court held that De Leon does not bind the trial court in this case, and the court of appeals should not have instructed the trial court to conduct proceedings "consistent with" this federal case, though the trial court could still consider this persuasive case in resolving Plaintiffs' claims. Second, it held that the court of appeals' reversal of the temporary injunction did not preclude Plaintiffs from seeking the same or similar relief on remand. Even though Texas appellate courts hold that dissolution of a temporary injunction bars a second application for such relief, exceptions apply where the second request is based on changed circumstances not known by the applicant during the first application. The Supreme Court reasoned that Obergefell constituted such a "changed circumstance" that Plaintiffs were not precluded from seeking similar or the same relief on remand. Third, the Supreme Court did not express any opinion as to whether Plaintiffs had standing to seek a claw-back injunction for the tax dollars the City already expended on benefits for same-sex spouses, because Plaintiffs never requested an injunction and the trial court never granted one. However, it held that Plaintiffs could seek such an injunction or any other relief on remand. Fourth, the Supreme Court declined to adopt Plaintiffs' instruction that the trial court construe Obergefell narrowly on remand. The Supreme Court reasoned that Obergefell did not hold states must provide publicly funded benefits to married persons, but declined to instruct the trial court how to construe Obergefell on remand because neither party had a full and fair opportunity to litigate their positions yet, since the Supreme Court was dealing with an interlocutory appeal from the trial court's orders granting a temporary injunction.

Summary of Case Context & HoldingThe legislature amended the Constitution to limit the authority of the district and county to budget for desegregation compliance expenses for school districts. The Court held that the State did not need to pay the school district's desegregation expenses because the legislature's amendment removed the district and county's authority to budget for desegregation expenses using primary property taxes, which were being used for reimbursement, and instead created a new classification of secondary property tax (ad valorem taxes) for budgetary purposes. Desegregation expenses were not included because only primary property taxes were used for reimbursement purposes, rather than the ad valorem taxes that did not encompass desegregation expenses. Accordingly, the Court affirmed the opinion of the court of appeals that the State did not need to pay the school district's desegregation expenses.

Summary of Case Context & HoldingPlaintiff suffered work-related injuries after falling over a ladder at work. Defendant-employer then filed Forms 60 (Employer's Admission of Employee's Right to Compensation) and 61 (the official form used by insurance companies to deny workers' compensation claims) with the Industrial Commission (an agency of the state of North Carolina that administers among other things the state's Workers’ Compensation Act), describing some of the Plaintiff's injuries as compensable and denying the compensability of others, arguing the Plaintiff's current disability was unrelated to the original injury at work. The Commission found that because the employer had admitted compensability for some injuries, it created a rebuttable presumption that Plaintiff's other injuries were causally related to the original accident and injury. The court of appeals affirmed the Commission's decision and award of ongoing disability benefits. The Supreme Court reversed and remanded the case for further proceedings before the Industrial Commission, finding the presumption may not apply to Plaintiff's claim and it was unclear if the Industrial Commission found Plaintiff's further injuries causally related to the original accident independent of the application of the presumption.

Summary of Case Context & HoldingEmployees brought a class action against an employer, Jones Dairy Farm, for unpaid wages accrued during time spent "donning and doffing" (defined as time spent putting on and taking off any required clothing). Jones Dairy Farm argued that this time was not compensable because the collective bargaining agreement did not provide for compensation for this time. The Supreme Court held that the "donning and doffing" time was integral to the job and, therefore, under Wis. Admin. Code DWD § 272.12(2)(e), could not be modified or eliminated through collective bargaining.

Summary of Case Context & HoldingThe Plaintiff, a former University of Montana employee, alleged that his employer unlawfully disclosed confidential information from his personnel file and refused to renew his employment contract. The employer claimed that the employee was terminated because of prohibited use of employer resources. The Supreme Court held that Plaintiff's private personnel records—and any associated privacy claims arising from their improper release—stem only from the employment relationship, and are thus governed by the employment contract under contract law rather than the right to privacy guaranteed under the Montana Constitution, or the duty of ordinary care required under Montana law. Mont. Const. art. II, § 10; Mont. Code Ann. § 27-1-701. The Supreme Court affirmed the lower court's dismissal of the privacy and negligence claims, but reversed its holding that the statute of limitations for the employee's defamation and tort claims had run, and remanded for consideration of those issues.

Summary of Case Context & HoldingFollowing the U.S. Supreme Court's decision in Dobbs v. Jackson Women's Health Organization, 597 U.S. 215 (2022) which overturned Roe v. Wade, 410 U.S. 113 (1973) and reverted abortion related laws to the individual states, Arizona had multiple laws related to abortion that were suddenly in conflict. At issue were two state statutes addressing abortion rights. The more recent law, enacted in 2022, three months before Dobbs, banned abortion after 15 weeks. The older law was an 1864 pre-statehood near total abortion ban that was never formally repealed. The federal decision in Roe had made the 1864 law a non-issue that the state never repealed. However, once Roe was overturned at the federal level by the Supreme Court, it was unclear if the 1864 law was still good law or how the 1864 law would interact with the 2022 law. Initially, the state supreme court held that the statute restricting elective abortion to 15 weeks (the 2022 law) did not repeal the 1864 ban on elective abortion. On April 9, 2024, the state supreme court ruled that the 1864 law could be enforced and would take effect 14 days later. The Supreme Court held that the 2022 law did not create a right to an abortion because the 1864 law was still good law. This result meant that abortion in Arizona was illegal except when “necessary to save” the life of the pregnant individual, but without exception for rape or incest and a sentence of 2-5 years in prison for assisting in an illegal abortion. The state Attorney General (AG) filed a motion for reconsideration which was denied by the state Supreme Court. The AG also filed a motion requesting that the Court wait to issue its mandate on when the total ban would go into effect for 90 days. The delay would allow the state AG time to potentially file a petition for a writ of certiorari to the U.S. Supreme Court. On April 24, the state house voted to repeal the 1864 law followed by the Senate on May 1. The governor signed the bill into law on May 2 repealing the 1864 ban. Subsequently, in May, Planned Parenthood filed a motion (joined by the state AG) requesting that the state court wait to issue its mandate enforcing the abortion ban until the repeal of the 1864 law went into effect. The repeal of the 1864 law was slated to happen 90 days after the legislative session ended. On May 13th, Arizona’s Supreme Court granted the motion to delay enforcement of the 1864 abortion ban. The delay of enforcement of the 1864 abortion ban was to last until September 26, 2024 while the repeal of the same 1864 abortion ban by the governor took effect on September 14, 2024. Subsequently, on November 5, 2024, Election Day, Arizonians passed 2024 Arizona Proposition 139 which enacted a right to abortion into the Constitution of Arizona up until fetal viability.

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

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

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

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

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

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

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

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

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

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