State Supreme Court Data Tracker

Summary of Case Context & HoldingNevada passed an amendment to the Nevada Constitution, adding the Minimum Wage Amendment (MWA), which requires employers to pay their employees one of two possible wage rates, depending on whether the employer offers qualifying health benefits. The MWA allows for an exception to both of these requirements if the employer and employees agree to a lower wage in clear and unambiguous terms through collective bargaining. Western Cab Company (Western) began requiring its drivers to pay for fuel directly instead of deducting fuel costs from drivers' paychecks. Former cab drivers for Western filed a complaint against Western alleging, among other things, that when fuel costs are considered, drivers' wages fall below the constitutionally mandated minimum. Western moved to dismiss the complaint, arguing that not only should fuel costs not be considered when calculating the minimum wage, but the MWA itself was invalid because it (1) was preempted by the National Labor Relations Act (NRLA); (2) was preempted by the Employee Retirement Income Security Act of 1974 (ERISA); and (3) was unconstitutionally vague. The Supreme Court held that the MWA is not preempted by the NRLA because the MWA does not usurp the function of the National Labor Relations Board nor does it intrude upon areas that Congress intended to leave open to the free market, as minimum wage laws are within a state's police powers. The MWA is similarly not preempted by ERISA because it neither references nor connects with ERISA for preemption purposes. Further, the MWA is not unconstitutionally vague because an employer is sufficiently on notice of what benefits it must provide to qualify for the lower wage and the MWA does not promote arbitrary or discriminatory enforcement. The Supreme Court held that the MWA is valid and, therefore, denied Western's petition for extraordinary relief to dismiss the complaint made by the former cab drivers. The Court declined to address the issue of the fuel calculation because it depended on facts that needed to be developed at the district court level.

Summary of Case Context & HoldingJo Ann Puente was admitted to the intensive care unit of a hospital following complications with a gastric bypass surgery. While there, her condition worsened significantly, however the attending physician did not review the notes detailing the serious symptoms. As a result, Puente developed Wernicke’s disease, which developed into a debilitating brain disorder. Puente, her minor daughter, and her mother sued the attending physician, his employer (Gonzaba), the hospital, and other care providers. Prior to trial, Puente’s daughter and mother settled their claims with all Defendants except the attending physician, Gonzaba, and another doctor employed by Gonzaba. The daughter and mother then dropped their remaining claims and ceased to be parties prior to trial. Puente settled with certain Defendants for $200,000 and dropped her claims against certain other Defendants that the daughter and mother had settled with. At trial, the only claims tried were against the attending physician, Gonzaba, and the other physician employed by Gonzaba. The jury found the attending physician negligent, and awarded Puente $1 million in past and future earning capacity lost, as well as $13.3 million in future medical expenses. The physician and Gonzaba moved for a settlement credit, arguing that a $3.3 million settlement that Puente’s daughter entered into with the hospital should reduce recovery. The trial court rejected the argument, and instead only credited the $200,000 settlement that Puente had entered into. The trial court denied the motion for periodic payments of the award for future medical expenses, and instead awarded Puente a $14.1 million lump sum. On appeal, the court of appeals largely affirmed the judgment and award, holding that using the settlement credit at $200,000 was proper, and that the Defendants had not presented sufficient evidence to support a periodic payment settlement award. The Defendants appealed to the Supreme Court. The Supreme Court first reviewed the issue of settlement credit. Under Chapter 33 of the Texas Civil Practice and Remedy Code, the damages a claimant may recover must be reduced by “the sum of the dollar amount of all settlements.” Under Chapter 33, any person who seeks to recover damages for the injury of another is considered a claimant. The Court held that Puente’s daughter’s claims were due to an injury that occurred to Puente, and therefore Puente would be considered a claimant with her daughter, and any settlement entered into by the daughter should be credited in full to any award to Puente. The Court next considered whether the trial court abused its discretion in not structuring the payment for future medical expenses as periodic payments, as requested by the Defendants in post-trial motions. Under the Texas Medical Liability Act, a court must comply with any request that future damages for medical care be paid in periodic payments from a defendant physician, defendant health care provider, or a claimant. The Court held that motioning for periodic payments after trial is timely, and that the Defendants provided adequate evidence of long-term financial assurance and a potential structure for the payments such that the trial court could have reasonably crafted a payment plan. If such a plan can be reasonably crafted, the court is required to do so, and the Supreme Court remanded to the trial court for it to finalize a payment plan including an adequate settlement credit.

Summary of Case Context & HoldingWilliam G. Veitch, a Republican candidate for district attorney for the Tenth Judicial Circuit of Alabama, petitioned for a declaratory judgment and a writ of mandamus directing that the names of candidates running for the office of district attorney for the Tenth Judicial Circuit be included on the primary-election ballots used in both divisions (Birmingham and Bessemer) of the Tenth Judicial Circuit. Consistent with the applicable Alabama Act, the practice in primary elections is to include the names of candidates only on ballots used in each district not on both. Appellant, Veitch, and Appellees, J. Scott Vowell, in his capacity as acting Chief Election Official of Jefferson County, and Steve Marshall, in his capacity as Attorney General of the State of Alabama, appeared to have agreed that the Act was ignored in 2016, because the names of Democratic candidates for district attorney for the Tenth Judicial Circuit apparently were included on the ballot used in the primary election in the Bessemer Division (and not just the Birmingham Division). Veitch suggested that the names of Republican candidates in 2016 were not included on that ballot. The parties agreed that, with respect to the general election, the candidates for district attorney are included on the ballots used in both divisions. After entering a temporary restraining order enjoining the printing of ballots, the circuit court set aside the restraining order and dismissed the action. Veitch appealed. The Alabama Supreme Court determined that the statute on jurisdiction in election contests did not deprive the trial court of jurisdiction over an action for a declaratory judgment and a writ of mandamus by a candidate for district attorney for the Tenth Judicial Circuit. The issue in the case was whether Veitch had been denied an alleged right to have his name included on all primary ballots in Jefferson County for what he describes as a “county-wide” office, by virtue of an act that he alleged had been repealed, is unconstitutional, or was unconstitutionally applied. It was undisputed that Veitch properly filed the necessary paperwork to qualify as a candidate, that he was duly certified as a candidate by the Republican Party and the Alabama Secretary of State, and that his name was submitted to the Jefferson County Election Commission for inclusion on the Republican primary ballot. The Court found that the jurisdiction-stripping statute, which strips jurisdiction over "the legality, conduct, or results of any election," is not aimed at challenges such as the one Veitch brought, thus it did not preclude the trial court from jurisdiction. Further, the Court found that the doctrine of laches (an equitable doctrine applied to prevent a party who delayed asserting a claim from asserting the same claim after some change in conditions that make the belated claim unjust) does not apply, as the two-week time period between approval of primary-election ballots and candidate's challenges to them did not constitute the requisite unreasonable delay element. The Court concluded that the jurisdiction-stripping statute did not deprive the trial court of jurisdiction and Veitch was not precluded by the doctrine of laches from bringing his action. The case was reversed and remanded to the circuit court. The Court expressed no opinion on the merits of Veitch's arguments regarding the alleged repeal of the Act, its alleged unconstitutionality, or its alleged unconstitutional application.

Summary of Case Context & HoldingIn 2018, William G. Veitch, a Republican candidate for Jefferson County District Attorney (D.A.) and resident of the Bessemer Cutoff area in Alabama, challenged a 1953 local law (Act No. 138) that prohibited residents of the Bessemer Cutoff from voting in primary elections for the Jefferson County D.A., despite being able to vote in the general election. Veitch filed a legal challenge asserting that Act No. 138 violated the U.S. Constitution. After unsuccessfully seeking relief in the trial court—which dismissed his claims first on jurisdictional grounds and later on the merits—Veitch appealed to the Alabama Supreme Court. The Alabama Supreme Court reversed, holding that the Jefferson County D.A. has statutory authority to prosecute in the Bessemer Cutoff and because voters in that area are subject to the D.A.’s prosecutorial power, they possess an equal interest in the office and must not be excluded from participating in the primary election. The Court reasoned that the denial of primary voting rights imposed a severe restriction on the fundamental right to vote and thus triggered strict scrutiny. The Court further found that Act No. 138 was not narrowly tailored to serve any compelling state interest—specifically rejecting the idea that the state’s interest in dividing political power between court divisions could justify excluding certain voters. The Court also emphasized that primary elections, especially in areas dominated by one political party, can effectively determine officeholders and therefore merit full constitutional protection. Citing the Equal Protection Clause of the Fourteenth Amendment, the Court concluded that the law was unconstitutional, emphasizing that excluding voters from a primary for an official with jurisdiction over them violated principles of representative democracy.

Summary of Case Context & HoldingDefendant, who was a 17 years old juvenile at the time of the crimes, committed robbery, rape, and murder as part of gang activity. The Supreme Court held that Defendant's sentence of life without parole (LWOP) had to be vacated, because the trial court did not make any sort of determination on the record that 17-year old Defendant was irreparably corrupt or permanently incorrigible. The Supreme Court explained that the U.S. Supreme Court has applied its “evolving standards of decency” theory of the Eighth Amendment to promulgate ever-increasing constitutional restrictions on the states' authority to impose criminal sentences on juvenile offenders. The Supreme Court stated that in Miller v. Alabama, 567 U.S. 460 (2012), the U.S. Supreme Court did not purport to prohibit LWOP sentences for juvenile murderers, so long as sentencing courts properly exercise discretion in imposing such sentences, and if the sentencing court did not follow the process correctly, this would result in a juvenile's LWOP sentence being not void but voidable. The U.S. Supreme Court made it clear that LWOP sentences may be constitutionally imposed only on the worst-of-the-worst juvenile murderers, much like the death penalty may be imposed only on the worst-of-the-worst adult murderers.

Summary of Case Context & HoldingPlaintiff, an OB-GYN, filed a lawsuit against Evanston Northwestern Healthcare, seeking civil damages arising from the hospital's decision not to reappoint him because he had performed unnecessary surgeries. The hospital argued it was immune from liability under Section 10.2 of the Licensing Act (210 ILCS 85/10.2) and under the federal Health Care Quality Improvement Act of 1986. The trial court granted summary judgment to Evanston Northwestern Healthcare because it was immune under Section 10.2 of the Licensing Act, and the appellate court affirmed the decision, finding that Plaintiff must prove some kind of physical harm to safety to avail himself of the "willful and wanton conduct" exception to immunity. The Supreme Court affirmed. Reviewing the statutory language, the Supreme Court found that the purpose of Section 10.2 of the Licensing Act was to encourage peer review and self-policing by the medical profession to promote the State interest in improving health care quality. Because the statute clarified that "willful and wanton conduct" referred to actions that show "actual or deliberate intention to harm or that, if not intentional, shows an utter indifference to or conscious disregard for a person's own safety and the safety of others," the Court found the contemplated harm encompassed physical harm, not reputational or economic harm. The Court held that Section 10.2 applied to cases like Plaintiff's where a hospital took action for quality control purposes, but Plaintiff failed to allege well-pleaded facts showing he was disciplined for sham purposes.

Summary of Case Context & HoldingTree planters employed by Moore Landscapes (Moore) brought an action against Moore for violating the Illinois Prevailing Wage Act (Act). The Act requires that public work laborers be paid based on the defined prevailing wage rate in their county. The planters alleged that Moore violated section 11 of the Act by paying them $18 per hour, rather than the county's prevailing wage rate of $41.20 per hour. The Tree planters’ employment contract with Moore did not specify that the planters would be paid the prevailing rate. The Supreme Court held that when an employment agreement does not account for the prevailing wage rate, the agreement will be construed narrowly, such that employees will not be entitled to the prevailing wage rate and the Act will not apply. Ultimately, the Act was amended in 2024 after this case because the case revealed a loophole which allowed employers to avoid paying their employees the prevailing wage rate. Now, regardless of whether an agreement specifies the prevailing wage rate, a laborer can bring an action against an employer for not paying the rate.

Summary of Case Context & HoldingThe U.S. Bureau of Land Management (BLM) filed water rights claims to reservoirs and a pothole. Objectors appealed the water court's recommendation of summary judgment. The Objectors argued that BLM was not qualified to appropriate water for sale or distribution to others because it was not a "public service corporation." The Objectors relied on Bailey v. Tintinger, 122 P. 575, 577 (Mont. 1912) stating that case established a rule that only "public service corporations" can appropriate water for use by third parties and because BLM is not such an entity, it cannot perfect its claims to appropriate water. The Supreme Court held the Objectors misconstrued Bailey and there is no such rule. Bailey expressly recognized the right of the BLM to proceed under Montana law to appropriate water to sell, rent or otherwise dispose of to others. The Supreme Court further held that charging money for water is not a requirement of perfecting a water right for sale, rental or disposal to others. The majority also highlighted that storage of water is considered "beneficial use" as expressly provided by the Montana Constitution. Mont. Const. art. IX, § 3(2).

Summary of Case Context & HoldingAppeal by the City of Fort Peck (Fort Peck or City) to the Montana Supreme Court in which the City argued that the water court erred in reducing its water entitlement to 171 acre-feet per year (AFY) and also that the water court violated its due process rights in making this determination. The City's population peaked in 1934, supporting more than 10,000 people, but it has since declined to 251 people. The City claimed a municipal water right for 1,500 AFY. During a recent claim examination, the DNRC recommended that the water court reduce the City's entitlement to 206 AFY. Fort Peck contended that its entitlement should be 773 AFY to meet its historical beneficial use and anticipated future needs. The state contended that the City had abandoned any entitlement that exceeds its historical beneficial use. Section 85-2-227 of the Montana Code establishes a presumption of nonabandonment for municipal water rights. Fort Peck qualified for this presumption by satisfying the statutory criteria. To prove the City had abandoned a portion of its right, the state had the burden of rebutting and overcoming the presumption by presenting evidence of the City's low historical water use and continued population decline. The water court found no credible data that indicated the City's population would exceed 1,200 people, which was the City's basis for requesting 550 AFY in addition to its historical use of 223 AFY. The water court found credible a population estimation of 384 people in forty years and applied average consumption rates to arrive at a revised claim of 171 AFY for the City. In its appeal, Fort Peck argued that this volume determination was an error because the water court's basis for the volume was the City's current use rather than its historical use. The court rejected this argument, citing case law to assert that the water court cannot grant a volume that is greater than the beneficial use that the evidence established. Therefore, the court accepted the water court's determination that Fort Peck had abandoned the portion of its original water right to 1,500 AFY that was above 171 AFY. The Supreme Court found that Fort Peck had adequate notice and an opportunity to present evidence before the water court entered its final order because the City was able to participate in every step of the process that resulted in the water court's order, including presenting testimony and exhibits, and objecting at trial. The Supreme Court affirmed the water court's conclusions.

Summary of Case Context & HoldingA city commission decided to administer a benefits plan according to a statutorily-required cost study. This decision effectively altered a bargained-for term of the agreement between the city and the labor union regarding cost-of-living adjustments (COLA). Retired police officers and the labor union sought judicial review, and the trial court found that information the city provided to actuary was contrary to plan’s plain language, resulting in an incomplete and inaccurate cost study. The Supreme Court held that the city commission could not properly impose a unilateral change to provisions of police retirement plan regarding COLA terms based on an inaccurate and incomplete cost study.

Summary of Case Context & HoldingThe United Food & Commercial Workers Union, Local 1473 brought suit against Hormel Food Corps. alleging that the employer failed to pay employees for time spent taking on and taking off the required clothing (which is called "donning and doffing"). The Supreme Court held that "donning and doffing" was covered by Wis. Admin Code § DWD 272.12. This regulation provides that the workday for which employees must be compensated includes activities that are indispensable to the performance of the job—including putting on certain clothes. As a result, the Supreme Court ruled that defendant was required to compensate its employees for the time spent "donning and doffing."

Summary of Case Context & HoldingMaricopa Integrated Health System (MIHS) and Aurora Behavioral Health Care (Aurora) operate acute inpatient psychiatric hospitals. MIHS and Aurora entered into Facility Participation Agreements (Agreements) with Respondent United Behavioral Health, Inc. (UBH), a Medicare Advantage (MA) Organization that issues and administers various types of health insurance plans, including Medicare Advantage plans and Employee Retirement Income Security Act (ERISA)-regulated plans. MA, also known as Medicare Part C, 42 U.S.C. §§ 1395w-21 et seq., permits enrollees to obtain Medicare-covered healthcare services from private healthcare organizations and their third-party contractors. ERISA regulates health plans offered by private employers to employees. MIHS and Aurora (collectively as Providers) and UBH had a dispute as to whether certain extended inpatient care was medically necessary. Providers demanded arbitration pursuant to arbitration provisions in the Agreements, which are governed by the Federal Arbitration Act (FAA). UBH filed separate lawsuits against MIHS and Aurora to stay the arbitration proceedings and determine arbitrability. In the case against Aurora, the trial court stayed the arbitration proceedings, ruling that the dispute concerned coverage and must be resolved through Medicare and ERISA administrative procedures. The court of appeals held that the administrative appeals process provided under the Medicare Act overrode the arbitration clause provided by the Agreements. The Arizona Supreme Court affirmed and held that the administrative appeals process provided under the Medicare Act preempts arbitration agreement with respect to Medicare-related coverage disputes between private healthcare administrators and providers, even though arbitration would otherwise be required by the parties' contracts and the FAA.

Summary of Case Context & HoldingUnions brought suit against the local Civil Service Commission, which had compelled union-eligible civil service employees to make involuntary financial contributions to subsidize the Commission's work (which included negotiating rates of pay, conditions of employment and grievance procedures). The Supreme Court found in favor of the unions, reasoning that this method of requiring civil servants to fund the Commission's administrative operations exceeded the Commission's authority under the Michigan Constitution. The Constitution explicitly provided for funding from the Legislature in proportion to the size of the civil service population and therefore the Commission lacked the power to compel funding from another source.

Summary of Case Context & HoldingThis case involves the review of an arbitrator's award denying Petitioner's funds pursuant to the New Jersey Spill Compensation and Control Act (Act), which creates a means by which the state can "provide monies for a swift and sure response to environmental contamination from the discharge of petroleum products and other hazardous substances." (cleaned up). In order to resolve disputes over denied fund monies, the Act uses arbitrators and flexible procedures to allow claimants the opportunity to demonstrate the denial was arbitrary and capricious action. The Petitioner's claim was denied and he filed an appeal, but two years elapsed between the appeal request and the commencement of the appeal. In addition, on appeal, the arbitrator rejected the use of additional scientific material resulting in an allegedly flawed decision that Petitioner contended is based on misconceptions by the arbitrator about the evidence on the record. The Supreme Court reversed and remanded for a new arbitration proceeding due to concerns regarding the substantive reasoning of the arbitrator's decision and the procedural fairness considerations, which, the Supreme Court noted, undermined confidence in the outcome of the arbitration enough to persuade the Supreme Court, in the interest of fairness, to require a new arbitration be conducted.

Summary of Case Context & HoldingPlaintiff landowners (Landowners) brought an action against the Defendants, Maine Township, the City of Park Ridge (Park Ridge) and the Metropolitan Water Reclamation District of Greater Chicago (District) (collectively Defendants) for breach of various duties they claimed were owed to them with respect to a stormwater drainage system located near their properties. In particular, the Landowners alleged that Defendants had committed a “taking”—under the Illinois Constitution—of their real and personal property as a result of flood damage they said was caused by the approval by Defendants of plans for what was an inadequate drainage system, the Prairie Creek Stormwater System (PCSS), and failure to take “corrective measures to remedy and/or protect the plaintiffs against the foreseeable dangerous conditions existing on its PCSS properties posed by excess stormwater." The Illinois Supreme Court rejected the Landowners arguments, finding that the trial court properly dismissed the takings claim. The Illinois Supreme Court found that property loss is compensable as a “taking” when the government intends to invade a protected property interest, or the invasion was the direct or foreseeable result of authorized government action, but here the Landowners had failed to allege that the water flowing onto their property causing the flood damage was the intended or foreseeable result of authorized government actions by Defendants.

Summary of Case Context & HoldingTwin Creeks claimed historic rights of appropriation for portions of the property at issue that previous owners irrigated intermittently since 1904. The Petrolia Irrigation District (PID) objected to claims for irrigation that Twin Creeks' predecessors had filed, and Twin Creeks brought suit to challenge PID's objections. Twin Creeks purchased the property and its water rights in 2015 after it had changed hands multiple times. The family who owned the property during the 1950s neglected to irrigate the land in any way. The first of the two statements of claim for direct flow irrigation, the 102 claim, began when the original owner filed a notice of appropriation in 1904. One owner in the chain of title had not used the water right for nearly twenty years. PID asserted that this period of non-use rendered the original right abandoned. Because of this, PID urged the court to assign a new 1971 priority date. The Supreme Court decided that the water court had correctly determined the first claim to be an abandoned water right. Abandonment requires intent to abandon as well as nonuse. Eyewitness testimony from those who lived on the property during the era of alleged abandonment confirmed that for twenty-three years, the owners had not irrigated the property. Twin Creeks provided no evidence to the contrary. Therefore, the new 1971 priority date was correct for Twin Creeks. The Court also concluded that resumption of irrigation after abandonment is a new appropriation with a new priority date, rather than a permissible change to a small portion of the original right that was not abandoned. This meant the resumption of irrigation could not rely on the original priority date, but instead is treated as a new appropriation with a junior priority date. Multiple appropriators can claim water rights from the same source, and the first in time has the best right.

Summary of Case Context & HoldingVictor Leija, a window washer, died in a workplace accident, and his widow and children received workers’ compensation benefits from his employer’s insurance carrier, Twin City Fire Insurance. The Plaintiffs, the Leija family, filed a third-party negligence claim against the City of Glendale and others, ultimately settling for $1.6 million. Twin City sought to enforce its lien on the settlement proceeds to recover the workers’ compensation benefits it had paid, per § 23-1023(A), which states that although an employer is generally immune from tort liability when an employee accepts compensation under the Act, the employee may bring a tort claim against a third party when the employee was “injured or killed . . . by the negligence or wrong” of the third person. When an employee brings such a third-party claim, the Act vests the employer’s insurance carrier with a lien on any recovery (less reasonable and necessary expenses) that the employee collects from the third party to the extent of the compensation benefits paid by the insurance carrier. Consistent with its pre-settlement position, Twin City sought to fully enforce its lien under § 23-1023(D) against all the settlement proceeds on account of past and future workers’ compensation benefits. The Plaintiffs requested that the superior court set a trial to establish the employer’s proportionate fault and the resulting amount of Twin City’s lien. The superior court ruled in Twin City’s favor, reasoning that “a separate action after compromise of the third-party claim is not the appropriate vehicle to allocate fault” to a non-party employer. The court of appeals reversed, holding that “when a worker settles a claim against a third party for less than the limits of the third party’s insurance, the worker may obtain a judicial determination of whether the carrier’s lien should be reduced to account for the employer’s comparative fault.” The Arizona Supreme Court granted review and reversed the decision of the appeals court, holding that a claimant who settles all of his or her third-party claims may not obtain a post-settlement trial to determine the percentage of employer fault solely to reduce or extinguish the insurance carrier’s lien. The Court explained that neither the statutes nor prior decisions, especially Aitken v. Industrial Commission of Arizona, 904 P.2d 456 (Ariz. 1995), which expressly limits the application of the equitable apportionment rule to situations where a claimant’s total damages are “fixed by verdict” in the third-party action, authorize a post-settlement trial process. The Court also observed that allowing a post-settlement trial, as the appeals court did, would potentially transform the incentive structure of the system and encourage gamesmanship on the part of claimants by incentivizing them to maximize a third-party defendant's fault so as to maximize the amount of the claimant's settlement, and then, at the post-settlement trial, incentivize the claimant to maximize the fault attributable to the employer in order to reduce or extinguish the insurance carrier's lien on the settlement proceeds.

Summary of Case Context & HoldingThe Georgia Environmental Protection Division sought review of an administrative law judge's reversal of vegetative buffer variance previously granted to Grady County for construction of a fishing lake. The Supreme Court held that the state Erosion and Sedimentation Act's buffer requirement applied only to state waters that had wrested vegetation. The Supreme Court said that by adding the phrase "as measured horizontally from the point where vegetation has been wrested," the legislature expressly defined how the buffer was established, and, since the legislature offered no other method for the buffer to be established but for measuring it horizontally from the point of wrested vegetation, the buffer necessarily could not be applied to state waters that were adjacent to banks without wrested vegetation.

Summary of Case Context & HoldingA city clerk refused to accept for filing a petition for referendum on the ground that the petition did not have a sufficient number of qualifying signatures. Members of a Committee of Petitioners brought suit to have the challenged ordinance put on the ballot pursuant to the state's Faulkner Act (citizens in municipalities under the Faulkner Act possess the right to referendum). The Petitioners also brought suit under the New Jersey Civil Rights Act, which would entitle them to an award of attorney's fees if they prevailed. The Supreme Court held that the city clerk violated the right of referendum guaranteed by the Faulkner Act and that the violation of that right deprived the Committee members of the right as protected by the state's Civil Rights Act. Initially, the Petitioners failed to submit the required number of signatures needed to support the referendum. The Petitioners supplemented the initial filing to include the requisite number of signatures and the Supreme Court held that the Faulkner Act does not give the clerk discretion to prevent the filing based on facial insufficiency. In order to demonstrate whether the Faulkner Act confers a substantive right under the state Civil Right's Act, Plaintiffs must establish that (1) the referendum statutes were intended to confer a benefit on plaintiffs as a representative class of voters of Hoboken; (2) the statutory right to challenge an ordinance and place it before the voting public is not so vague that enforcement would strain judicial competence; and (3) the Faulkner Act unambiguously imposes a binding obligation on Hoboken. The Supreme Court held that Plaintiffs met this test and accordingly were also entitled to relief under the state's Civil Rights Act.

Summary of Case Context & HoldingIn May 2022, a Special Grand Jury was empaneled in Georgia to investigate whether former President Trump and others interfered in the 2020 election in Georgia. After months of evidence gathering, the Special Grand Jury produced a report and made recommendations of charges which subsequently led to 18 indictments. Following the indictments, President Trump filed an original petition for writ of mandamus with the Supreme Court seeking "(1) to compel Judge McBurney to quash the Special Purpose Grand Jury's report and to bar use of its contents in any future proceedings, whether civil or criminal; (2) to prohibit District Attorney Willis from introducing to a regular grand jury any evidence obtained via the Special Purpose Grand Jury; and (3) to compel the District Attorney Willis's disqualification as a 'party representative' in any proceeding involving [President Trump]." President Trump argued that the Special Purpose Grand Jury scheme was "vague" and violated his due process rights for a number of reasons including that District Attorney Willis "'has signaled' her intent to use the Special Purpose Grand Jury's report and the unlawful evidence obtained . . . to secure from a regular grand jury criminal indictments" and because he would "suffer irremediable reputational harm" if he had to defend an indictment "which he contends would be based on unlawful evidence" while seeking the presidency in 2024. In rejecting President Trump's writ, the Supreme Court said that it "exercise[s] its original jurisdiction only in extremely rare situations [and] a petitioner cannot invoke this Court's original jurisdiction as a way to circumvent the ordinary channels for obtaining . . . relief." And, in this case, the Supreme Court said President Trump failed to show that he was "prevented fair access to the ordinary channels."

Summary of Case Context & HoldingOn December 9, 2020, President Trump filed an emergency petition for writ of certiorari with the Supreme Court asking it to review a decision entered by a judge in the Fulton County Superior Court, which held that President Trump's case challenging Georgia election results would proceed "in the normal course." President Trump's initial petition, which was filed in the superior court on December 4, sought permanent and preliminary injunctive relief and asserted a number of claims with respect to the 2020 election results in Georgia including allegations of voting irregularities, violations of Georgia law related to absentee ballots, and other allegations of misconduct and fraud. On December 12, the Supreme Court held that, even though it has subject matter jurisdiction over "election contests," it was dismissing President Trump's emergency petition for lack of jurisdiction because (1) the superior court's December 9 order was not a final judgment and "petitioners were required to follow interlocutory appeal procedures . . . to obtain review" (which they did not); (2) petitioners' challenge to the superior court judge's authority to preside over the case does not provide basis for invoking the Supreme Court's jurisdiction because no order was entered on the challenge to her authority; and (3) petitioners did not show sufficient reasons to warrant invoking the Supreme Court's original jurisdiction.

Summary of Case Context & HoldingAfter losing the Wisconsin's electoral college votes, the Trump Campaign sought to invalidate the ballots—either directly or through a drawdown—of more than 220,000 Wisconsin voters in two different counties. Four different categories of absentee ballots were at issue: (1) ballots cast by voters who claimed indefinitely confined status since March 25, 2020; (2) in-person absentee ballots; (3) ballots which were certified using “improperly added” witness information; and (4) ballots collected at “Democracy in the Park.” The Supreme Court ruled that the Trump campaign’s challenges were meritless or barred. For category 1, the indefinitely confined status voters, the Supreme Court ruled that because the claims were made blanketly across the absentee voter class without regard to whether any individual voter was in fact indefinitely confined, they have no basis in reason or law and are wholly without merit. The other three categories all failed because of the doctrine of laches. This doctrine is used when a Plaintiff delays in asserting its rights, and, because of this delay, is no longer entitled to bring an equitable claim. Because here there was unreasonable delay in bringing this claim, Defendant did not have an awareness that Plaintiff would bring the claim, and the delay would prejudice Defendant, the Supreme Court exercised its discretion and barred the claims for the remaining three categories because of laches.

Summary of Case Context & HoldingThe Supreme Court considered whether an error pursuant to Hurst v. Florida, 577 U.S. 92 (2016) (requiring that a jury find each fact necessary to impose a sentence of death) can be harmless if the jury verdict is unanimous. Truehill, a Hurricane Katrina survivor, was convicted of a series of thefts, assaults, and one murder. He was sentenced to death by a unanimous jury. Truehill argued that he is entitled to relief pursuant to Hurst because the jury in his case was repeatedly instructed regarding the non-binding nature of its verdict, and, despite the unanimous jury recommendation a Hurst v. Florida error is structural and therefore not capable of harmless error review. In Hurst, on remand from the United States Supreme Court, the Florida Supreme Court determined that these errors are not structural and are therefore subject to harmless error review. Based on the Florida Supreme Court's holding in Hurst, requiring that the jury unanimously find all facts necessary to impose a sentence of death and unanimously recommend death, the Florida Supreme Court found that there is no question whether there was a Hurst error in Truehill’s penalty phase, where the jury issued only an advisory recommendation of death, without more specific findings. The Florida Supreme Court ultimately concluded that the State can sustain its burden of demonstrating that any Hurst error was harmless beyond a reasonable doubt. Here, the jury unanimously found all of the necessary facts for the imposition of death by virtue of its unanimous recommendation. The Florida Supreme Court reasoned that although the jury was informed that it was not required to recommend death unanimously, and despite the mitigation presented, the jury still unanimously recommended that Truehill be sentenced to death. The unanimous recommendation by the jury is precisely what was determined in Hurst to be constitutionally necessary to impose a sentence of death. As a result, the Florida Supreme Court held that Truehill is not entitled to relief.

Summary of Case Context & HoldingThe Court was asked to decide a case concerning whether the Florida Constitution allowed a Florida judge and the governor to time a judge’s resignation with the expiration of their term and have the governor appoint their successor, rather than have their successor chosen by a popular election. The Court issued a two-sentence decision declining to exercise jurisdiction over the appeal. Justice Lewis dissented, arguing that the Florida Constitution demands that the people choose trial court judges, and that judges timing their resignation were improperly circumventing the Constitution. Justice Quince dissented, arguing that the Court had jurisdiction and that the “gamesmanship on display” in this case would “undermine the voter’s respect for the courts.” Justice Quince proposed a holding that a “vacancy” is created at the time a judge decides to resign, regardless of when the Governor accepts the resignation. Justice Pariente also dissented, fully concurring with Justice Quince’s opinion, endorsing its solution, and reiterating the concerns of a lower court judge that the decision could allow individual judges’ to “manipulate the election process to suit their own political or philosophical objectives.”

Summary of Case Context & HoldingA carpet seller sued a competing company under the Consumer Fraud Act (CFA) and Deceptive Trade Practices Act (DTPA). The Plaintiff claimed that the Defendants sold carpet cleaner containing phosphorus in violation of the Illinois Regulation of Phosphorus in Detergents Act as well as the Illinois Pollution Control Board (PCB) regulations. Plaintiff argued that the Defendant was intentionally misleading their consumers into buying illegal goods, which would violate the CFA and DTPA. The Plaintiff could not sue under the environmental statutes because they did not include a private right of action. The State of Illinois had not brought charges against the Defendant for violating these laws. Therefore, the Court was asked to consider whether the Plaintiff's claims met the standard for suit under the CFA and DTPA. Under the CFA, the Court held that the Plaintiff was not a consumer of the allegedly illegal goods, which is a requirement to bring suit. Under the DTPA, the Court held the Plaintiff had not exhausted his administrative remedies. He should have gone to the PCB prior to bringing suit. Therefore, all claims were dismissed.

Summary of Case Context & HoldingThe Town of Lake Village, a general-law municipality, brought suit against the owner of a subdivision lot located in the town's extraterritorial jurisdiction (ETJ), seeking to stop construction of a home on the lot until the owner obtained the proper permits. At issue was whether a Type A general-law municipality has authority to enforce its building codes and building-permit requirements within its ETJ, and the Court held that it does not. Specifically, the Court looked to the plain language of applicable law and found that it did not expressly authorize general-law municipalities to enforce its building codes and building-permit requirements within their ETJs. Instead, the Court found that a general-law municipality only “possess[es] those powers and privileges that the State expressly confers upon [it],” and that it cannot exercise its powers outside its corporate limits, unless given authority to do so by the legislature.

Summary of Case Context & HoldingIn April 2015, Kevin Tomlinson threatened to ruin the reputation of two fellow real estate brokers unless they paid him. The police subsequently arrested Tomlinson and the State charged him with two counts of extortion under Section 836.05. Over Tomlinson's request that the jury be instructed on actual malice, the trial court instructed the jury on legal malice, specifically that "maliciously" meant "intentionally and without any lawful justification." The jury found Tomlinson guilty on both counts of extortion. On appeal to the Third District, Tomlinson argued that the trial court erred by denying his request to instruct the jury on actual malice. The Third District disagreed, finding that "[t]he extortionist need not hate" the complainant, and" '[t]aking the text of Section 836.05 as a whole, and considering its context and the discernable purposes of the legislature,' . . . the statutory term 'maliciously' means legal malice." Agreeing with the Third District's conclusion the Supreme Court held that Section 836.05 requires the State to prove that the defendant made a threat "intentionally and without a lawful justification" disagreeing with the Fifth District's decision in Calamia v. State, 125 So.3d 1007 (Fla. 5th DCA 2013) (concluding that in accordance with Carricarte v. State, 384 So.2d 1261 (Fla. 1980), "maliciously" in Section 836.05, Florida Statutes (2009), requires proof that the defendant acted with ill will, hatred, spite, or an evil intent).

Summary of Case Context & HoldingThe Supreme Court held that the Ohio General Assembly has constitutional authority to adjust local school funding retrospectively and to retroactively immunize the State Board of Education from liability for any legal claim of reimbursement by a school district for a reduction of school funding. The Supreme Court ruled that doing so did not violate the Retroactivity Clause of the Ohio Constitution, which prohibits the General Assembly from passing any law that is made to affect acts or rights occurring before it went into effect because the Retroactivity Clause does not apply to political subdivisions. The Supreme Court reached this conclusion based on an analysis of constitutional history and comparison to other states that treat political subdivisions similarly.

Summary of Case Context & HoldingPlaintiff reported alleged misconduct engaged in by the then-Commissioner and First Deputy Commissioner of the New York City Department of Transportation to his immediate supervisor and the agency's Inspector General. After Plaintiff was retaliated against for his report, he commenced an action pursuant to Civil Service Law § 75-b (the statute governing retaliatory action by public employers). Defendants argued that Plaintiff failed to comply with Civil Service Law § 75-b by not reporting the allegedly wrongful actions to the appointing authority (which under these facts were the defendants) before reporting to the Inspector General. The Court of Appeals held that because Plaintiff's appointing authorities were defendants, and because he understandably did not report their alleged misconduct to them, strict compliance with the reporting requirements of Civil Service Law § 75-b would not serve the purpose of the statute - therefore, Plaintiff's good faith effort to comply was sufficient under Civil Service Law § 75-b.

Summary of Case Context & HoldingA member-teacher of the Teachers Retirement System of Georgia within the state of Georgia retired in April 1994. Under the System's calculation and interpretation of the law, O.C.G.A. § 47-3-120(a)(2), she was entitled to annual retirement allowance "equal to 2 percent of [her] average compensation over the two consecutive years of membership service producing the highest such average, multiplied by the number of [her] years of creditable service, not to exceed 40." The teacher claimed that the System miscalculated the amount she was entitled to because the statutory reference in O.C.G.A. § 47-3-120(a)(2) to “two consecutive years” does not mean 24 consecutive calendar months and that it is compensation paid not earned. The Supreme Court determined it was not unreasonable to understand "two consecutive years" as the 24 consecutive calendar months and defer to the understanding of the System, denying Plaintiff's appeal. The Supreme Court did not address compensation paid versus earned.

Summary of Case Context & HoldingRep. Thompson sued to stop Gov. DeSantis’s appointment of Judge Renatha Francis to the Florida Supreme Court on the basis that Judge Francis did not meet the Florida Constitution's requirement that a Supreme Court Justice be a member of the Florida bar for ten years. Thompson further asked the Court to require the Governor to choose a replacement from a new list of nominees (in Florida, Governors choose judges from lists offered by nominating commissions). The Court agreed with Thompson that the Governor exceeded his authority by appointing Francis because she was ineligible, but denied Rep. Thompson's petition on the grounds that there was no legal justification for her requested remedy: ordering the Judicial Nominating Commission to create a new list of judicial nominees from which the Governor must appoint a replacement. In a subsequent unanimous opinion, the Court granted Thompson's motion to amend her requested remedy and ordered the Governor to appoint a constitutionally eligible candidate.

Summary of Case Context & HoldingAppellant was convicted and sentenced to death, but then successfully challenged the sentence on his first habeas petition. He then received a retrial on his sentence, and was again sentenced to death. Appellant filed a second petition challenging the new sentence which was denied, and the Court affirmed. Finally, Appellant filed a third petition, challenging the effectiveness of his counsel at all the stages below. The district court denied the petition as procedurally barred. The Court reversed the district court, holding that Appellant's claims were not procedurally barred because they were timely and had merit in as much as they alleged that (1) postconviction counsel failed to present compelling mitigation evidence to support the claim that the sentencing phase counsel provided ineffective assistance in developing and presenting the mitigation case at the sentencing retrial; and (2) that second postconviction counsel should have alleged that sentencing phase counsel provided ineffective assistance during jury selection. The Court noted that an effective post-conviction counsel would have presented more compelling evidence, if available, and would have challenged any jury-related errors made by the penalty phase counsel.

Summary of Case Context & HoldingThe Montana Water Use Act (MWUA) provides a comprehensive permit based system for new appropriations of water in Montana, but allows certain groundwater appropriations to be exempt from permitting. Section 85-2-306(3)(a)(iii) of the MWUA provides an exemption when a groundwater appropriation does not exceed 35 gallons per minute and 10 acre feet per year, however, it provides an exception to that exemption when a "combined appropriation" from the same source by two or more wells or developed springs exceeds 10 acre-feet per year, regardless of the flow rate. The Department of Natural Resources and Conservation (DNRC) issued a rule, under the MWUA, which interpreted the term "combined appropriation" to mean "groundwater developments, that are physically manifold into the same system." Upon challenge of that rule, the Montana Supreme Court affirmed the district court's conclusion that the term "combined appropriation" did not refer to the manner in which wells or developed springs were physically connected, as reflected in the rule, but rather referred to the total amount or maximum quantity of water that could be appropriated without a permit under the Act and, thus, invalidated the rule. In reaching this conclusion, the Supreme Court said that where a court invalidates a rule it is appropriate for the court to reinstate a prior rule that was in place, if not inconsistent with the act, which is what the district court did. Notwithstanding, the Supreme Court found that the district court did err in directing the DNRC to institute new rulemaking consistent with the court's order, given that the court also concluded that it was up to the DNRC to determine whether it should actually initiate rulemaking to change the reinstated rule.

Summary of Case Context & HoldingDr. Lindsey Niehay was a morbidly obese medical resident at the University. Dr. Radosveta Wells ran the residency program under the supervision of the chair of the department, Dr. John MacKay. Concerns arose regarding Niehay’s performance, including her inability to stand and profuse sweating during operations. In response, Wells solicited input from, and received, concerns from other attending physicians regarding issues with Niehay. After consulting with others, Wells recommended an emergency meeting of the Clinical Competency Committee to consider how to respond to Niehay's issues. The Committee recommended that Wells place Niehay on a 3-month probation with a remediation plan, of which Wells and MacKay informed Niehay thereof. Niehay requested a 1-month leave of absence to give herself time for self-assessment and to demonstrate her good-faith desire to address any deficiencies, which was approved. Niehay returned to her residency, but Wells received more reports expressing concerns about her performance, attendance, professionalism, and patient care. The Committee met and recommended that Niehay be suspended pending an investigation and evaluation of her post-leave performance, eventually resulting in Niehay’s dismissal from the residency program. Niehay filed the instant suit, complaining that the University dismissed her because of her morbid obesity, which she asserted constitutes unlawful discrimination because of a disability under the Texas Commission on Human Rights Act (TCHRA), which makes it unlawful for an employer to discriminate against an employee for being regarded as having an impairment. The University filed a combined plea to the jurisdiction and summary-judgment motion, arguing that the Labor Code does not waive its sovereign immunity because Niehay presented no evidence to support her claim. The trial court denied the plea and motion. The court of appeals affirmed. Upon review, the Court stated that the TCHRA makes it unlawful for an employer to discharge an individual because of the individual's disability, which is defined as "(1) a mental or physical impairment that substantially limits at least one major life activity of that individual; (2) a record of such an impairment; or (3) being regarded as having such an impairment." (citation modified). Neihay asserted a “regarded as” claim, in which she had to show that she was perceived as having an impairment and was terminated based on that perception. The Court found that one’s weight, even well outside the normal range, is not a physiological disorder or condition, but is instead a physical characteristic. The Court cited to holdings by the Sixth, Seventh, and Eighth circuits which held that morbid obesity must stem from a physiological disorder or condition to qualify as an impairment for regarded-as claims. The Court concluded that morbid obesity does not qualify as an impairment absent an underlying physiological disorder or condition. Since Niehay did not present evidence of an underlying physiological disorder or condition or that her employer regarded her morbid obesity as being caused by an underlying physiological disorder or condition, the Court found that her claim failed and reversed.

Summary of Case Context & HoldingLoretta Flores worked for Texas Tech University Health Sciences Center-El Paso becoming the "director" in charge of operations in the regional dean's office. In recognition of the work she was performing as the director during the school’s transition from a regional campus of the Texas Tech University School of Medicine to a separate university within the Texas Tech University System, Flores received a forty percent salary increase from around $60,000 to around $85,000 per year. Coinciding with this transition, Dr. Richard Lange was named the university's first president and dean of the university's medical school. Dr. Lange restructured the administrative operations and eliminated the director position, instead creating an assistant-to-the-president position for which Flores was not selected and Vanessa Solis, someone younger, was. President Lange informed Flores that she would be moving to the provost's office with the title of executive associate and an annual salary of $60,000—the amount Flores was making before she received the forty-percent raise under the interim president the previous year. Although other administrative staff were reclassified due to the restructuring, Flores was the only one who received a pay cut. Flores sued for age discrimination. Texas Tech-El Paso filed a plea to the jurisdiction. The trial court denied the plea, and the court of appeals affirmed. The court of appeals held that there was a genuine issue of material fact as to whether age was a motivating factor in the determination. Upon review, the Supreme Court found that a reasonable juror could not conclude that Solis took or was placed in Flores's former position as director in the president's office. Instead, Dr. Lange reorganized the president's office eliminating Flores's position and creating a new assistant to the president position. The Court also found that the evidence did not support a finding that Flores was replaced by Solis or treated less favorably than others who were similarly situated but outside the protected class. Finally, the Court found that Flores failed to produce any direct evidence that a discriminatory intent was a motivating factor in her demotion. Accordingly, the Court reversed the court of appeals' judgment and rendered judgment dismissing Flores's claims for lack of jurisdiction.

Summary of Case Context & HoldingIn 1994, the Texas State Board of Examiners of Marriage and Family Therapists (Therapists Board) adopted Rule 801.42(13), which permitted marriage and family therapists (MFTs) to provide "[d]iagnostic assessments" concerning "emotional, mental, and behavioral problems." In 2008, the Texas Medical Association (Medical Association) filed suit, asserting that Rule 801.42(13) was invalid as, in the Medical Association's view, the Texas Occupations Code only authorizes those who are licensed to practice medicine to provide diagnostic assessments of mental conditions. The Medical Association specifically pointed to the Medical Practice Act, which requires a license to practice medicine in Texas, defining “practicing medicine” as “the diagnosis, treatment, or offer to treat a mental or physical disease or disorder . . . by any system or method.” In response, the Therapists Board argued that although MFTs may not be permitted to provide a “medical” diagnosis, they are able to diagnose “non-medical” disorders, including relational dysfunction, depression, and addiction. The trial court granted a motion for summary judgment in favor of the Medical Association and entered judgment declaring Rule 801.42(13) invalid as exceeding the scope of the regulations concerning MFTs. The court of appeals affirmed. The Supreme Court reviewed the language of the Texas Licensed Marriage and Family Therapists Act, which regulates MFTs, and its explicit permitting of MFTs to “evaluate” their patients. Turning to dictionary and healthcare industry definitions, the Court held that the concept of a diagnostic assessment is included as a narrower subset of an evaluation and that Rule 801.42(13), and its allowance of MFTs to diagnose certain conditions, was permissible.

Summary of Case Context & HoldingUnder the Texas Insurance Code, health insurance companies are required to pay a non-network physician for emergency care rendered to insured individuals “at the usual and customary rate.” Before the Supreme Court here were two cases in which groups of emergency-medicine doctors outside of an insurer’s network sued an insurer, alleging that the insurer failed to pay the doctors at the usual and customary rates. In both cases, the Plaintiffs based their claims primarily as a violation of the Texas Insurance Code. The Supreme Court accepted petitions for appeal in both cases to determine whether the Insurance Code provided a private cause of action that the Doctor-Plaintiffs could sue under. The Court began its analysis by reviewing precedent that any private cause of action “must be clearly implied in the statutory text.” The Court further noted that the bar to imply a cause of action is high: even if a statute is otherwise unenforceable, a court should not imply a private cause of action without a clear authorization in the text. The Doctor-Plaintiffs argued that because the insurance statutes did not impose a penalty, the inclusion of an entitlement to compensation was sufficient to create a private cause of action. Referencing the separation of powers doctrine, the Court held that because the Legislature had previously given the Department of Insurance broad authority to regulate insurers and enforce the code, implying a cause of action would be a power grab on the part of the judiciary giving the civil courts the power to enforce a law that was intended to be enforced by the executive. Further, it would also disrupt the potential intention of the Legislature that such issues be heard in criminal courts, considering that Section 843.464 of the Insurance Code provides for a broad criminal penalty for agents of an insurance company not complying with the Code. As a result, the Court held that it would be incorrect to imply a cause of action. The Court also addressed claims brought by the Doctor-Plaintiffs under the equitable theory of quantum meruit that permits plaintiffs to recover for valuable services provided with the expectation of compensation. Importantly, in order for a plaintiff to recover under quantum meruit, they must show that services were rendered explicitly for the defendant, and not merely that the defendant benefitted as a result. The Court held that the doctors had rendered services not to the Defendant insurers, but instead to the insured. As a result, they could not recover under quantum meruit.

Summary of Case Context & HoldingAfter the child suffered nerve damage, following complications in the birth of the child where the child’s shoulder was dislocated when pulled from the mother’s birth canal, the parents filed suit, individually and as the child’s next friends, alleging that the attending physician and nurse had acted negligently in performing certain maneuvers that dislodged the child’s shoulder. The physician contended both that he and the nurse had not been negligent in their actions and that the care provided under the circumstances constituted emergency medical care. Under the Texas Medical Liability Act (TMLA), plaintiffs must prove willful and wanton negligence in order to recover for damages suffered as a result of emergency medical care in a hospital’s emergency department or obstetrical unit. The trial court found that the Defendants had not caused the complications, that the actions undertaken constituted emergency medical care, and that the Plaintiffs were required to prove willful and wanton negligence. The trial court permitted an interlocutory appeal on (1) whether the TMLA required the proving of willful and wanton negligence; and (2) what conduct would qualify under that standard. The court of appeals held that the TMLA did not require proof of willful and wanton negligence, reversing the judgment of the trial court, and did not consider the second issue. The Supreme Court reviewed the text and grammar of the TMLA against common standards and similar precedent and held that the Legislature intended for all claims arising out of emergency medical care provided in a hospital’s obstetrical unit to require proof of willful and wanton negligence.

Summary of Case Context & HoldingHouston Independent School District (District) brought an action seeking declaratory and injunctive relief against the Texas Education Agency (Agency), the Commissioner of Education (Commissioner), and a conservator appointed by the Commissioner for the purpose of supervising and overseeing the District. The lawsuit began as part of the District's opposition to the Agency's planned measures in 2016 to redress academic performance issues of two allegedly failing high schools in the District (i.e., Kashmere High School and Wheatley High School). The District argued that the Commissioner was barred from taking any regulatory actions against it (e.g., lowering the District's accreditation status to "Accredited-Warned" or appointing a board of managers for the District) because the Education Code did not authorize the planned remedial measures. The trial court did not rule on the Agency's jurisdictional plea, which argued that the Education Code authorized the Commissioner to take such action, but granted the petition for a temporary injunction in favor of the District which the court of appeals affirmed. The Supreme Court reversed and directed the trial court to consider the jurisdictional plea, holding that the District was not entitled to injunctive relief and that the District's claims did not support a temporary injunction against the Commissioner and his conservator. The Supreme Court specifically held the following: (1) temporary injunction confining the conservator's authority to low-performing campuses was no longer warranted following amendments to the Education Code, which clarified that the Commissioner may delegate review authority to agency staff; (2) temporary injunction prohibiting the Commissioner from appointing a board of managers was no longer warranted, given amendments to the Education Code when "a campus is considered to have an unacceptable performance rating for five consecutive school years;" and (3) temporary injunction prohibiting the Commissioner from acting based on the recommendations of accreditation investigation was no longer warranted, because the new/current law, which entitles a District to request a contested case hearing does not apply in the instant case, because the investigation had been completed prior to September 1, 2021, and, as a result a District's remedy is limited to the presentment of preliminary findings and “an opportunity for an informal review by the commissioner or a designated hearing examiner.”

Summary of Case Context & HoldingThe Texas Department of Transportation (TxDOT) terminated Albert Lara, Jr.'s employment after he exhausted his five months of sick leave. Lara sued under the Texas Commission on Human Rights Act (TCHRA), alleging in part that TxDOT (1) failed to reasonably accommodate his disability by granting him additional leave without pay in accordance with its policy, in violation of Section 21.128; and (2) discharged him in retaliation for his request for additional leave, in violation of Section 21.055. Section 21.051, provides that "[a]n employer commits an unlawful employment practice if because of . . . disability . . . the employer . . . discharges an individual, or discriminates in any other manner against an individual in connection with . . . the terms, conditions, or privileges of employment." Section 21.055, in turn, makes it an unlawful employment practice if an employer "retaliates or discriminates against a person who . . . opposes a discriminatory practice[,] . . . files a complaint[,] . . . or participates in any manner in an investigation." Finally, Section 21.128(a) makes it unlawful for an employer to "fail or refuse to make a reasonable workplace accommodation to a known physical . . . limitation of an otherwise qualified individual with a disability who is an employee . . . unless the [employer] demonstrates that the accommodation would impose an undue hardship on the operation of [its] business." TxDOT filed a combined plea to the jurisdiction and motion for summary judgment based on sovereign immunity. The trial court denied the motion and a divided panel of the court of appeals affirmed in part and reversed and rendered in part. Although the parties had briefed two disability-discrimination theories (discrimination by termination under Section 21.051 and discrimination by failure to accommodate under Section 21.128), the panel improperly read Lara's pleadings as asserting only the latter. The panel concluded that the trial court should have dismissed Lara's retaliation claim under Section 21.055 because Lara had not, before he was terminated, engaged in a protected activity by opposing a discriminatory practice, making a complaint, or participating in an investigation. Upon review, the Court found that: (1) Laura did make a leave without pay (LWOP) request as an accommodation as a matter of law; and (2) granting Lara LWOP would not have rendered Lara unqualified nor would it have been a reasonable accommodation as a matter of law. The Court held that the court of appeals correctly affirmed the trial court's denial of TxDOT's motion to dismiss Lara's failure-to-accommodate claim under Section 21.128(a). Regarding the court of appeals' judgment dismissing Lara’s retaliation claim under Section 21.055, the Court found that none of Lara’s accommodation requests alerted TxDOT to Lara’s belief that disability discrimination was at issue, and without, there was no evidence of illegal intent on the part of TxDOT. Thus, the Court affirmed the court of appeals’ judgement dismissing Lara’s retaliation claim under Section 21.055. Finally, the Court remanded the case to adjudicate in the first instance TxDOT's appeal of the trial court's denial of its motion to dismiss Lara's Section 21.051 adverse-action (discrimination by termination) claim because the court of appeals improperly determined that the claim had not been pled.

Summary of Case Context & HoldingThe Texas Chiropractic Act (TCA) defined the practice of chiropractic to include the evaluation of the musculoskeletal system. The Texas Board of Chiropractic Examiners (TBCE) later issued rules clarifying this definition to include related nerves in addition to muscles and bones. A further TCBE rule authorized chiropractors to perform an eye-movement test known as VONT. The Texas Medical Association (TMA) commented on the rules, noting that they were too broad and that the scope of the chiropractic practice should be limited to the spine. The TMA then initiated an action seeking a declaratory judgment that the adopted rules were overly broad and that the TBCE was overstepping the authorized bounds of the TCA, which limited chiropractic conditions to “biomechanical condition[s].” Following a bench trial, the trial court held that the rules were invalid for exceeding the statutory scope of chiropractic practice. On appeal, the appellate court affirmed, holding that the rules exceeded the intended scope of the TCA by including aspects of the nervous system. On further appeal, the Supreme Court reviewed the TBCE rules and held that because the rules only referred to nerves associated with the musculoskeletal system, nothing in the rules indicated that the TBCE was overstepping the limits of the TCA. The Court held that the TMA had read the TBCE rules too broadly and that merely permitting chiropractors to consider related nerves did not mean that chiropractors would delve into the field of neurology generally. Finally, the Court reviewed the VONT procedure and held that the test was a helpful tool for chiropractors in treating patients, and that nothing in the TCA seemed to prevent chiropractors from performing VONT.

Summary of Case Context & HoldingThe anesthetic propofol, known by its brand name Diprivan, was approved for sale by the Food and Drug Administration (FDA) in 1989. Manufacturers of the drug were permitted to distribute generic propofol in three vial sizes: 20, 50, and 100 mL, with each vial clearly prescribed exclusively for single-patient use. Dr. Depak Desai used these vials in his endoscopy centers in Las Vegas, improperly using 50 mL vials of the drug on multiple patients. Subsequently, Desai was criminally charged, and former patients were notified of a risk of their possible infection with bloodborne diseases. Approximately 800 patients then filed suit against the manufacturers of propofol alleging claims of state products liability, negligence, violation of the Nevada Deceptive Trade Practices Act, and punitive damages. Although each of the Plaintiffs had been tested for various bloodborne diseases and tested negative, they sought damages for testing costs as well as related pain and suffering. Primarily, Plaintiffs claimed that the manufacturers knew, or should have known, that selling 50 mL vials of the drug, as opposed to smaller vials, to a clinic with high patient turnover would entice the use of each vial multiple times. The Defendant drug manufacturers then filed a motion to dismiss, claiming that the class's claims were in conflict with the federal Hatch-Waxman Act, which the district court dismissed. On appeal, the Supreme Court held that the claims based in state products liability were entirely preempted by federal law. Reviewing federal precedent, the Supreme Court held that the Hatch-Waxman Act imposes a duty for generic drug manufacturers to match the labeling and design of those approved for the branded alternative by the FDA. As such, the manufacturers could not have changed their designs without violating the Act. However, the Supreme Court also held that the claims based on a theory of negligence were not preempted, as the manufacturers could not demonstrate that they had a continuing duty under federal law to sell larger vials to clinics that they should have known were misusing them. Further, because the FDA had already separately approved the sale of the smaller 20 mL vials of propofol, the manufacturers would be able to sell the smaller vials without violating their duties under the Hatch-Waxman Act. As a result, the Supreme Court held that only those claims based in negligence and punitive damages could remain.

Summary of Case Context & HoldingThe Supreme Court held that the water court had appropriately assigned a 1936 priority date to the Teton Canal's Eureka Reservoir, as required by the remand order associated with Teton I (Teton Co-Op Canal Co. v. Teton Coop Reservoir Co., 365 P.3d 442 (Mont. 2015)) because the priority date aligned with the date the Water Conversation Board-which jointly built the Eureka Reservoir with Teton Canal, filed its declaration of intention to store, control and divert water in connection with the reservoir. Further, the Supreme Court held that the water court did not exceed its authority by identifying volumes for Teton Canal's flow and storage of water rights, finding that when the priority date of a water right is adjusted, the water court has discretion to consider whether other elements of the water right are impacted. With respect to the specific volume levels assigned by the district court, the Supreme Court found that there was substantial evidence to support the water court's decision to limit Teton Canal to a volume amount of 12,000 acre feet for any combination of Teton Canal's water right claims. Among other things, the Supreme Court found that the volume calculation was supported by a stipulation entered into by Teton Canal. Further, the Supreme Court found that (1) the water court appropriately concluded that Eureka Reservoir, for which a 1936 priority date was assigned, had water rights with a priority date that was junior to rights that extended from the 1890 notice (see Teton I); (2) Teton Canal was permitted to store water, pursuant to the water rights extending from its 1890 notice, in a reservoir for future use as long as it did not increase flow and volume and the period of diversion was not expanded and, thus, that it was permitted to store its direct flow in April and May—early irrigation season—to be used in August and October—late irrigation season; and (3) Teton Canal was entitled to year-round diversion under the 1890 Notice.

Summary of Case Context & HoldingTeton Coop Reservoir Company (Teton Reservoir), and others, objected to water right claims asserted by Teton Canal, a company formed for the purpose of appropriating, transporting, storing, and using water for irrigation in Teton County, in the Eureka Reservoir. In 1890, and then in 1891, Teton Canal's predecessors filed an appropriation notice claiming rights to portions of the Teton River to use its waters for irrigation purposes and identifying a diversion point (the 1890 Notice and 1891 Notice). Teton thereafter acquired the rights reflected in the 1890 and 1891 Notices and between 1936 and 1937, together with the Water Conversation Board, constructed the Eureka Reservoir. Following passage of the Montana Water Use Act (MWQA), Teton filed a claim for its existing water rights, including rights related to the Eureka Reservoir, identifying 1890 as the priority date for its water rights claims (as required by the MWUA). But, Teton Reservoir objected arguing that Teton Canal had no right to water storage in the Eureka Reservoir under the 1890 Notice and, thus, that should not be the priority date applied. The Supreme Court agreed finding that (1) Teton Canal’s predecessors developed the diversion point described in the 1890 Notice (and, thus, that diversion could not have referred to the Eureka Reservoir); (2) the 1890 Notice did not contemplate the Eureka Reservoir; and (3) the Teton Canal did not proceed with reasonable diligence after the 1890 Notice in developing the Eureka Reservoir. As a result, the Supreme Court reversed the water court’s order granting Teton Canal’s water rights claim to the Eureka Reservoir, and remanded to the water court to assign a priority date to Teton Canal’s water rights with respect to the Eureka Reservoir.

Summary of Case Context & HoldingDue to a cancer diagnosis that would impact reproduction in the future, an unmarried dating couple elected to freeze embryos. The couple entered into a contract governing any disputes between them related to the embryos. The contract provided that the embryos were the couple's joint property and joint consent would be required for use or disposition of the embryos. The contract provide three options for the embryos in the event of dissolution of the relationship: (1) discard the embryos; (2) donate the embryos to another couple; or (3) allow one partner to use the embryos with the contemporaneous permission of the other. The agreement also provided that upon dissolution of the relationship, a court decree/settlement could decide if one member of the couple could use the embryos or if they would be donated. After signing the agreement, the couple married but later divorced. Upon dissolution of the relationship a dispute arose regarding the treatment of the embryos. One party (the wife) wanted to retain the embryos whereas the husband did not want a child with his soon to be ex-wife. Family court balanced the parties' interest and concluded the husband's right not to be a parent outweighed the wife's right to procreate. The court of appeals vacated the decision and awarded the wife the embryos. The Supreme Court focused on the language of the contract and the parties' express intent. The Supreme Court explained that the contract contemplated the option of one party using the embryos if the parties contemporaneously agreed or donation if an agreement could not be reached. Without an agreement to provide the wife the embryos there was no choice for a court but to order donation.

Summary of Case Context & HoldingA conflict emerged between the Michigan Medical Marihuana Act (MMMA) and a local city zoning ordinance that prohibited uses banned by federal, state and local law. A qualifying patient under the MMMA wished to grow medical marijuana in his home. This is allowed under the MMMA, but is not allowed under the federal Controlled Substances Act (CSA)—making it also prohibited under the local ordinance, which prohibits uses banned under other laws. A trial court and the court of appeals came to differing conclusions about whether the CSA preempted the MMMA. However, in a unanimous decision, the Supreme Court held that the CSA does not preempt the MMMA because the two laws can be complied with simultaneously. In passing the CSA, Congress’s objective was to address drug abuse and trafficking. To this end, marijuana was categorized by Congress as a “Schedule 1” drug because it had no acceptable medical uses at the time. Michigan also designates marijuana as a “Schedule 1” drug, but merely carved out an exception for a limited class of individuals for new, acceptable medical use of marijuana. The Supreme Court held that such an exception does not frustrate or alter the CSA’s federal criminalization of marijuana or subsequent enforcement. Thus, it is not impossible to simultaneously comply with both the CSA and the MMMA. Furthermore, the Court held that the MMMA does preempt the city’s ordinance because municipalities cannot enact ordinances that conflict, even indirectly, with existing state law.

Summary of Case Context & HoldingA property owner who was a qualified medical marijuana patient under Michigan Medical Marihuana Act (MMMA) filed action against the City of Wyoming, challenging the city's new zoning ordinance that prohibited use of land in a manner that was contrary to federal law (including use contrary to the federal Controlled Substances Act (CSA) which prohibited any and all uses of marijuana). The circuit court entered summary disposition in the City's favor based on determination that the MMMA was preempted by the CSA. The property owner appealed. The court of appeals, reversed and remanded. The City sought leave to appeal. The Supreme Court held that MMMA was not preempted by the CSA, but the city ordinance penalizing qualifying patients for engaging in MMMA-compliant medical marijuana use was preempted by the MMMA to the extent the ordinance and the MMMA conflicted.

Summary of Case Context & HoldingTempleton Properties submitted an application to the Town of Boone to obtain a special use permit to place a 13,050 square foot medical clinic on a parcel of land zoned for single-family residential use, but which was historically used as a church under a special use permit. The Town of Boone's Board of Adjustment, a quasi-judicial body with the authority to interpret local zoning ordinances, rejected Templeton's application for a special use permit for this clinic. The court of appeals held there was sufficient evidence to support a finding that the proposed medical clinic was not harmonious with its surrounding area, and reversed the lower court's decision to overturn the Board's decision to deny the special permit. The Supreme Court remained divided, with three members voting to affirm and three voting to reverse, so the court of appeals' decision stands.

Summary of Case Context & HoldingTwo Wisconsin voters challenge the validity of two documents created by employees of the Wisconsin Elections Commission that authorize municipal clerks and local election officials to establish ballot drop boxes. They argue that: (1) the documents are unpromulgated administrative rules; and (2) under Wisconsin statutes, drop boxes are illegal because a voter must personally mail or deliver in person the voter's absentee ballot to the municipal clerk, not to an inanimate object. In a declaratory-judgement action for judicial review of the Wisconsin Elections Commission’s documents, the Supreme Court ruled that the Wisconsin Elections Commission could not authorize municipal clerks and local elections officials to establish absentee-ballot drop boxes and could not allow a voter’s agent to return the voter’s absentee ballot to a drop box because ballot drop boxes are illegal under Wisconsin statutes.

Summary of Case Context & HoldingPlaintiff sued the Wisconsin Attorney General because Plaintiff's criminal history report prepared by the Wisconsin Department of Justice (DOJ) contained inaccurate information, namely, a crime committed by someone who stole the Plaintiff’s identity. The Wisconsin DOJ keeps a database of everyone who comes into contact with the Wisconsin criminal justice system, including individuals who are innocent of any criminal activity. The database is searchable by name. The Plaintiff tried and failed to remove the false entry that appeared when his own name was searched. The Supreme Court ruled that the Plaintiff was "deprived of a liberty interest" and therefore entitled to an equitable remedy. The Supreme Court declined to fashion a remedy on the summary judgment record before it, but remanded to the circuit court to do so.