State Supreme Court Data Tracker

Summary of Case Context & HoldingDuring a rainstorm, the Metropolitan Water Reclamation District of Greater Chicago (District) diverted stormwater into nearby creeks. These creeks flooded the homes of several residents who sued the District under the Takings Clause of the Illinois Constitution. Illinois Supreme Court precedent has held that temporary flooding of personal property due to city action is not a taking. People ex rel Pratt v. Rosenfield, 77 N.E.2d 697 (Ill. 1948). However, a United States Supreme Court case held a temporary flooding is a taking when the United States flooded an Arkansas forest during peak timber growing season. Arkansas Game & Fish Comm'n v. United States, 568 U.S. 23 (2012). Because these two holdings appeared to conflict, the Illinois Supreme Court was asked to determine whether the Takings Clause in the Illinois Constitution ("Private property shall not be taken or damaged for public use without just compensation as provided by law") would differ from the Takings Clause in the federal Constitution ("nor shall private property be taken for public use, without just compensation"). The Illinois Supreme Court held that these two holdings did not conflict. Instead, the degree of damage dictated whether the flooding was a taking. The Plaintiffs would have to show that they were deprived of the ability to enjoy their property to have a claim. The Illinois Supreme Court remanded the case to the Illinois District Court to understand the extent of the damage caused by the temporary flooding and whether it qualified as a taking under this new test.

Summary of Case Context & HoldingPlaintiff Hall, was an employee at UBS Financial Services Inc. (UBS) until UBS terminated his employment following an HR report filed by Hall's former coworker, Mary Reid. Hall subsequently sued UBS for breach of the implied covenant of good faith and fair dealing, and Reid for tortious interference with contractual relations. The South Carolina Supreme Court certified three questions: (1) Whether terminable-at-will employment relationships are contractual in nature as a matter of law?; (2) Does the implied covenant of good faith and fair dealing arise in the context of terminable-at-will employment relationships, and can an employer's termination of an at-will employee constitute a breach of the relationship such that it may give rise to a claim by the former employee against the employer for breach of the implied covenant of good faith and fair dealing?; and (3) Can an employer's termination of an at-will employee, which results from a third-party employee's report to the employer, constitute a breach of the relationship such that it may give rise to a claim by the former employee against the third-party employee for tortious interference with a contractual relationship? The Court answered the first question in the affirmative, reasoning that an employer's offer to pay an employee for services, and the employee's performance of those services, meets the elements of contract formation. The Court noted that the right to fire an employee at any time and for any reason is an integral term of an at-will contract, and the employer does not incur liability for the termination of an at-will employee. The Court next held that the implied covenant of good faith and fair dealing exists in at-will employment contracts because the implied covenant "exists in every contract." The Court noted that if a party to a contract believes another party has breached the implied covenant, then the cause of action "is simply one for breach of contract." In the context of termination of an at-will employee, because an at-will employment contract includes the right for an employer to terminate employment for any reason, termination cannot form the basis of a claim that the employer breached the covenant of good faith and fair dealing. Finally, the Court held where a third party (whether a fellow employee or otherwise) induces the termination of a plaintiff's at-will employment, the third party may be liable for tortious interference with contractual relations if their actions meet the elements of the claim. Further, intentional procurement of termination is sufficient to meet the element of "intentional procurement of the contract's breach" even though the termination of the employee does not constitute a breach of an at-will contract.

Summary of Case Context & HoldingDefendant Bryan Hall appealed his conviction and death sentence resulting from his conviction of robbery and murder of his friend and former coworker. Hall testified at trial that he had killed the victim because of derogatory remarks the friend made about Hall's girlfriend, as would allow for a lesser voluntary manslaughter conviction. Among other evidence, the State argued for the death penalty based on two aggravating circumstances: Hall's previous violent felony conviction and his torture and mutilation of the victim. In mitigation, Hall introduced statements of support from his family, good behavior in prison, and testified about his hardship and apologized for the pain he caused. The jury found that the aggravating circumstances outweighed the mitigating circumstances and sentenced Hall to death. As relevant to the death penalty, Hall argued that under Redmen v. State, 828 P.2d 395, 400 (Nev. 1992) the district court erred in allowing the State to introduce psychological evidence from Hall's time in juvenile detention to support the State's claim of future dangerousness. The Court found no error under Redmen, as that line of precedent prohibited psychological evidence prepared for use at trial, unlike the 8-year old, unrelated evidence here. Hall also alleged that four comments constituted prosecutorial misconduct. First, when the State chastised Hall for sharing, in the State's view, fictionalized and traumatizing testimony about what the victim said to provoke Hall, the Court determined that the State's argument, even if inappropriate, was not so egregious as to amount to plain error. Second, the Court found no misconduct when the State argued that Hall's claims of remorse were not credible because Hall placed his remorse at issue. Third, the Court found no misconduct in the State's argument that "some cases, like this one, deserve the harshest available sentence." This argument did not run afoul of Evans v. State, 28 P.3d 498, 515 (Nev. 2001), which prohibits the State from telling the jury it can only return a death sentence. Fourth, the Court found no misconduct when the state introduced testimony that the victim's father would miss talking to the victim weekly on the phone; although this may have invoked sympathy in the jury, it did not constitute testimony that served no other purpose than to encourage the jury to impose a sentence under the influence of passion, as prohibited by Hernandez v. State, 50 P.3d 1100, 1109 (Nev. 2002). Under Nev. Rev. Stat. § 177.055(2), the Court concluded that sufficient evidence supported the aggravating circumstances, the verdict was impartial, and the death penalty was not excessive considering the length and severity of Hall's attack and Hall's criminal history. Justice Cherry dissented stating that while no error mandated reversal, this case was not the "worst of the worst" sufficient to impose the death penalty.

Summary of Case Context & HoldingDefendant Richard Haberstroh was convicted for murder, kidnapping, sexual assault, and robbery, and sentenced to death. The Court affirmed. On his first petition for postconviction habeas relief, the Court granted relief from the death sentence and ordered a new sentencing hearing. At the second sentencing hearing, the district court sentenced Haberstroh to death; this case arose from Haberstroh's second death sentence. Of note as to the death penalty, Haberstroh first argued that the district court erred in allowing the State to dismiss two jurors for cause because of their views on the death penalty. Under Weber v. State, 119 P.3d 107, 125 (Nev. 2005), the Court analyzed whether the jurors' views would substantially impair the performance of their duties. When questioned by the Court, both jurors ultimately said they would not consider imposing the death penalty. Thus, the district court did not err in dismissing the two jurors for cause, as they would not consider the death penalty. Haberstroh next argued that the Court erred in dismissing a third juror near the end of the trial, when it came to light that the juror had been contacted the prior day by an investigator working on the juror's nephew's capital prosecution. The Court conclude that considering the emotional effect of the nephew's case on the juror observed by the district court, the district court was within its discretion to dismiss the juror. Further, Haberstroh argued that the Court should have instructed the jury that "A sentence of death" may be mitigated by certain circumstances instead of "Murder of the first degree." However, the Court found the district court's use of the statutory language in Nev. Rev. Stat. § 200.035 did not imply mitigation was limited to only the circumstances of the offence. Finally, the Court determined that sufficient evidence supported Haberstroh's death sentence, though it was based in part on an invalid aggravating circumstance regarding Haberstroh's prior violent felony. In light of the entire record, the Court found that the jury would have imposed the death penalty even without the prior violent felony aggravating circumstance based on Haberstroh's extensive criminal history, the under-sentence-of-imprisonment aggravating circumstance, and because the jury imposed an impartial sentence that was not excessive.

Summary of Case Context & HoldingDefendant Curtis Guy appealed the district court's denial of his postconviction habeas petition, arguing against both his conviction for felony murder and resulting death sentence. The relevant facts were that Guy had initiated a robbery with his accomplice, Larry Pendleton. In the course of the robbery, Pendleton shot and killed the victim. While Guy knew Pendleton was armed and dangerous, no evidence showed that Guy planned the robbery, displayed any weapons, or used or showed force, as required under Nevada's robbery statute. Nev. Rev. Stat. § 200.380(1). Under U.S. Supreme Court decisions Enmund v. Florida, 458 U.S. 782 (1982) and Tison v. Arizona, 481 U.S. 137 (1987), a defendant found guilty of felony murder may only receive a death sentence "if he was a major participant in the felony and demonstrated reckless indifference to human life." First, the Court found Guy was not a major participant because he did not plan the robbery, display weapons, or use or show force. While his involvement was sufficient for a felony murder conviction, it did not satisfy the "major participant" standard under Enmund and Tison. Second, the Court found Guy did not show a reckless disregard for human life, even though he did not try to stop Pendleton and drove away from the scene, the robbery was not a product of extensive planning and occurred in a matter of moments. Thus, the Court determined Guy was not eligible for the death penalty and was ordered a new sentencing hearing. (While the Court ordered a new sentencing hearing, the Court rejected Guy's arguments relating to his felony murder conviction.)

Summary of Case Context & HoldingFollowing a failed structural inspection, the School Board of Crystal Lake South High School (Board) decided to replace the bleachers at their football stadium, which would require moving the home bleachers adjacent to nearby residential properties. The Board sought and received a permit from the county Regional Superintendent of Schools for the construction. Following the superintendent's approval, the school began construction without obtaining any city building permit, zoning approval, or storm water management approval. The city ordered the school to stop construction until requisite approvals were obtained, but the Board argued that a school district's construction on school property for school purposes is not subject to the local city's zoning authority. Three homeowners who held property adjacent to the construction sued the Board and the District, seeking to privately enforce the applicable zoning regulations. The District then filed a third party complaint against the city and the regional superintendent, asking the circuit court to determine whether the City's zoning and storm water ordinances control construction on school property. The circuit court granted a motion for summary judgment in favor of the city, which was then affirmed by the appellate court. On appeal, the Supreme Court held that a school district is subject to, and its school board must comply with, local governmental zoning and storm water restrictions. Reviewing Illinois statutes, the Court determined that school districts were not included in the specific exemptions from municipal zoning regulations. Further, the Court emphasized the city's power as a home rule jurisdiction, holding that it has broad power to regulate land use within its jurisdiction through zoning.

Summary of Case Context & HoldingAfter a pregnant woman was placed into a vegetative state following complications with her pregnancy, her husband (McCoy) sued the hospital, various physicians, and related physician groups. At trial, the jury returned a verdict in favor of McCoy and awarded damages of $10.6 million for the negligence claim against the ob/gyn who was primarily responsible for the pregnant woman’s care (Gunn), as well as the related physician foundation (OGA), which was vicariously liable. The award included $7.2M for future medical expenses. On appeal, the court of appeals held that evidence presented did not support the full $7.2 million for future medical expenses, and McCoy voluntarily remitted $159,854. The woman passed away ten days prior to the decision of the court of appeals. On further appeal to the Supreme Court, the Court first considered the evidence presented, and whether the negligence claims against Gunn (and vicariously against OGA) were supported. The Court reviewed the expert testimony presented by both sides at trial, noted that jurors are the sole judges of the credibility of witnesses, and held that the jurors could have reasonably believed the evidence presented by McCoy’s expert. The Court also considered Gunn and OGA’s argument that the trial court should have provided an instruction to the jury that the complications and resulting vegetative state were an “unavoidable accident” and that no party’s negligence resulted in the damages. The Court noted that this was an instruction more often used for physical environmental conditions, such as fog or sleet, or to account for harms caused by children, and held that although the trial court could have included the instruction, it did not err in omitting it. Additionally, the court reviewed the Defendants’ argument that the death of the pregnant woman had resulted in a windfall for McCoy that called for a remand in the interest of justice. The Court disagreed, noting that the Texas Rule of Appellate Procedure 7.1 provides that appeals proceed as if parties are still alive, and further held that just because the victim died did not necessitate the reconsideration of any issues.

Summary of Case Context & HoldingA group of voters filed a petition with the Minnesota Supreme Court seeking to prohibit former President Donald Trump from being listed on the 2024 presidential primary and general election ballots. Petitioners argued that Section 3 of the Fourteenth Amendment of the U.S. Constitution, which disqualifies anyone from holding office who has engaged in insurrection or rebellion against the U.S., rendered him ineligible to hold office. The Court dismissed the petition, holding that it would not be an error to place Trump's name on the 2024 Republican Party presidential nomination primary ballot and that the claim concerning the general election ballot was not yet ripe. The Supreme Court reasoned that the nomination primary is an internal party election, and Minnesota law does not prohibit a major political party from placing an ineligible candidate on the primary ballot. The Supreme Court further held that Plaintiffs' attempt to exclude Trump's name from the general election ballot was not yet justiciable as it was not "about to occur." The Court acknowledged that the claim was important and agreed with the Secretary of State’s argument that it was functionally justiciable because the record contained the raw material (including effective presentation of both sides of the issues raised) traditionally associated with effective judicial decision-making. Nonetheless, the Court declined to apply the functional justiciability doctrine to exercise jurisdiction over the general ballot claim, explaining that it was similar to the type of nonjusticiable claims that the Court had previously declined to consider in that it required the Court to “address ‘fundamental constitutional questions about the relative powers of’ different branches of our government as well as significant issues of federalism.”

Summary of Case Context & HoldingHoward Griffith was admitted to Aultman Hospital for surgery but passed away while being transferred to another unit. The circumstances surrounding his death raised concerns when a nurse discovered his body unclothed and his chest tube disconnected. Seeking answers, Gene Griffith, Howard's son, requested a copy of his father's medical records from the hospital. Gene found the information provided by the hospital to be unsatisfactory. Gene continued to request more information, ultimately appealing to the Fifth District Court of Appeals to compel the hospital to release more data. The court of appeals determined that the definition of “medical record” in Ohio Rev. Code § RC 3701.74 (RC 3701.74) (a statute requiring hospitals to release family medical records) was ambiguous and it was necessary to determine if Aultman Hospital had fulfilled Gene’s request. The Supreme Court of Ohio accepted the case to determine the definition of “medical record” as interpreted in context of RC 3701.74. The Supreme Court ruled that the definition of "medical record" encompassed more than just what was in a patient’s file, finding that the location of the data was immaterial in determining if data qualified as a medical record and thus was required to be released upon request. The Supreme Court remanded the case to the trial court to determine if Aultman Hospital properly released the requested medical records under this refined definition.

Summary of Case Context & HoldingPlaintiffs, each having a prior criminal conviction for sexual offenses against young children, were hired as laborers for Astro Moving and Storage Company. Astro entered into a contract with Allied Van Lines, a subsidiary of Sirva, to perform moving services for Allied. The contract required Astro to adhere to Allied's Certified Labor Program guidelines, which required that employees who "conduct the business of Allied at customer's home or place of business ... must have successfully passed a criminal background screen ... as specifically approved by Allied." Under these guidelines, employees automatically failed the criminal background screen if they had ever been convicted of a sexual offense. Plaintiffs consented to have Sirva investigate their criminal records, which identified their convictions for sexual offenses against young children. Soon thereafter, Astro fired Plaintiffs. In response to three questions certified by the U.S. Court of Appeals for the Second Circuit regarding who may be liable under the New York State Human Rights Law for employment discrimination on the basis of a prior criminal conviction, the Court of Appeals held that (i) Executive Law § 296(15) (which prohibits such discrimination) limits liability to an aggrieved party’s employer; (ii) common-law principles govern who is deemed an employer under the Human Rights Law, with emphasis placed on the employer’s power to order and control the employee in the performance of work; and (iii) Executive Law § 296(6) (which provides for aiding and abetting liability under the Human Rights Law) extends liability to an out-of-state non-employer who aids or abets employment discrimination against individuals based on a prior criminal conviction.

Summary of Case Context & HoldingPlaintiffs who were landowners brought action against the township challenging the validity of an ordinance that rezoned a large tract of land, including most of plaintiffs' property, from residential and commercial use to an Environmental Conservation district (EC district), thereby restricting future development of their property. The Supreme Court held that the ordinances represented a legitimate exercise of the municipality's power to zone property and that Plaintiff did not overcome the ordinance's presumption of validity. The Supreme Court reasoned that the inclusion of the Plaintiffs' property in the EC district rationally related to the municipality's comprehensive smart growth development plan, which concentrated development in a town center surrounded by a green-zone buffer, which plan had the additional benefit of protecting a sensitive coastal ecosystem through preservation of undisturbed, contiguous, forested uplands of which Plaintiffs' property is an integral and connected part.

Summary of Case Context & HoldingA group of personal care assistants (PCAs) requested access to a list of contact information for personal care assistants who provide home-based services to participants in state programs in order to garner support for their attempt to decertify a public union, the Service Employees International Union (SEIU), as their exclusive representative under the Public Employment Labor Relations Act (PELRA) and brought action challenging the state agencies' (including the Department of Human Services (DHS) and Minnesota Management and Budget (MMB)) denial of their request for accessing a list. The district court entered summary judgment in the PCAs' favor, and the court of appeals affirmed reasoning that, although they were not entitled to the list under the PELRA provision, PCAs are public employees for purposes of the Data Practices Act, and therefore their “personnel data” is subject to disclosure under Minn. Stat. § 13.43. The Supreme Court affirmed in part and reversed in part, concluding that neither PERLA nor the Minnesota Government Data Practices Act enable parties seeking decertification of a labor organization to obtain the contact information of bargaining-unit employees because such data about public employees is private.

Summary of Case Context & HoldingLake Oconee Academy, Inc. is a nonprofit corporation with a contract with the Greene County Board of Education to operate a local public charter school in the county. Greene County proposed issuing $14 million in revenue bonds to finance the construction of a facility for the use of the Academy. In connection with its proposal to issue these bonds, the Greene County Development Authority entered into an intergovernmental agreement with Greene County, whereby the county contracted to pay amounts over to the Authority for repayment of the indebtedness on the bonds, amounts that the County contemplated would be raised by an ad valorem tax. The Authority also proposed a lease agreement with the Academy, whereby the Academy generally would have use of the facility for so long as the indebtedness on the bonds remained outstanding, and the Authority would sell the facility to the Academy for $1 when that indebtedness was retired. The State of Georgia filed a petition to validate the bonds but the trial court refused. The trial court in this case found that the Authority's proposal was not sound, feasible, and reasonable, and it refused validation on the basis of that finding, among other grounds. The trial court here did not explain in its order exactly why it found that the proposal was not sound, feasible, and reasonable, and the Appellants did not ask for a detailed explanation of the finding. The Supreme Court speculated from the record that expert witnesses did not provide sufficient information on the particular impact upon economic development and noted that the trial court expressed concern about the extent to which the Authority's proposal would benefit the citizens of Greene County as well as aspects with the structure of the proposal including limited involvement of the Board of Education. On appeal the Supreme Court affirmed, determining that the bonds proposal was not "sound, feasible, and reasonable," and reasoning that a trial court's findings must be sustained on appeal if there is any evidence to support them when it comes to soundness, feasibility, and reasonableness.

Summary of Case Context & HoldingPlaintiff was a bus monitor for Dallas County Schools (DCS), who helped transport children with special needs to and from school on a school bus. When first hired for the position, Plaintiff disclosed to his supervisor that he suffered from congestive heart failure and took diuretic medicine that could cause incontinence. In August 2011, after the bus had dropped off the only student, Plaintiff repeatedly requested that the bus driver stop so that Plaintiff could use the restroom. After the driver failed to stop repeatedly after saying that he would, Plaintiff urinated in his pants and then finished urinating into an empty water bottle. Later, Plaintiff helped a student in a wheelchair board the bus with still-wet pants. Plaintiff would later be fired for urinating on himself and in a water bottle while on a school bus. Plaintiff was unsuccessful in appealing his termination through the DCS’s grievance process, and then sued DCS, alleging that he was terminated due to his disability. Under the Texas Labor Code, it is unlawful for an employer to make an “adverse employment decision” regarding an employee with a disability who was otherwise qualified for the job. Both the Plaintiff and DCS agreed that Plaintiff was disabled and was qualified for the job. At trial, a jury determined that Plaintiff’s disability was a motivating factor in his termination and that DCS would not have otherwise made the decision to terminate the Plaintiff absent his disability. As a result, the jury awarded the Plaintiff $41,292 in back pay and $125,000 in compensatory damages. On appeal, the court of appeals reversed the trial court, holding that there was no evidence that Green’s disability, which the court of appeals determined to be congestive heart failure, caused the incontinence that led to his termination. On appeal to the Supreme Court, Plaintiff argued that his incontinence was a disability in itself, and the court of appeals erred in determining that the only disability he suffered from was congestive heart failure. Turning to the Texas Labor Code, the Supreme Court noted that a physical impairment becomes a disability when it “substantially limits at least one major life activity.” Tex. Lab. Code § 21.002(6). Further, the Labor Code specifically defines the operation of a major bodily function, including the functions of the bladder, as a major life activity. Finally, the jury at trial was instructed specifically to determine whether Plaintiff was terminated because of a disability. As a result, the Court held that it was reasonable for the jury to determine that incontinence itself was a disability, and that DCS had improperly discriminated by firing Plaintiff due to his disability.

Summary of Case Context & HoldingThe Plaintiff-employee had an employment offer revoked prior to starting at the prospective employer, and after she had given notice at her former employer. The Plaintiff brought a claim against her prospective employer, and the employer argued that the employee's claim was preempted by the Montana Wrongful Discharge from Employment Act (WDEA), which precludes discharge claims arising from tort or employment contracts, whether express or implied (where contractual promises are inferred from parties' intentional conduct). Mont. Code Ann. § 39-2-913. The lower court held that the WDEA did not apply here and granted summary judgment for the Plaintiff on his breach of contract claim. The Supreme Court affirmed holding that the WDEA did not preclude the Plaintiff's claim as the WDEA applies only to employees discharged from employment, and the Plaintiff was never employed with the Defendant.

Summary of Case Context & HoldingIn this action under the Texas Administrative Procedure Act, Tex. Gov’t Code Section 2001.038, mothers detained at immigration detention centers and their children challenged the Texas Department of Family and Protective Services’ (the Department) licensing rule that permitted housing adults and unrelated children in detention centers in the same bedroom at the Dilley and Karnes centers. In 2015, a federal court ruled that the Dilley and Karnes centers lacked an appropriate childcare license and thus the operators had violated a federal consent decree requiring that such facilities be state-licensed when housing detained minors. The federal court enjoined family detention at the two facilities. The Department then promulgated a rule, first on an emergency basis and then formally as 26 Tex. Admin. Code Section 748.7(c) (Rule 748.7 or the Rule), that eliminated a prior limitation prohibiting licensed facilities from housing adults and children in the same bedroom except in narrow circumstances. Plaintiffs alleged that the Dilley and Karnes centers permitted unrelated adults to share bedrooms with children in reliance on Rule 748.7, resulting in the sexual assault of a minor who was sharing her room with an unrelated adult, and accordingly sought a permanent injunction and declaration stating that the Department lacked authority to adopt Rule 748.7. Plaintiffs also alleged that the Rule resulted in longer detention periods. The trial court enjoined the Department from granting licenses under Rule 748.7, but the court of appeals reversed, holding that Plaintiffs lacked standing to assert their claims under the Texas law parallel to Article III standing, which requires plaintiffs to allege a concrete personal injury traceable to the defendant’s conduct. With respect to the detained mothers' claims, the court of appeals concluded that their alleged injuries were not traceable to the adoption of Rule 748.7, because the court of appeals' interpretation of the Rule "does not allow a minor to share a bedroom with an unrelated adult." The court of appeals also held that any increase in the length of detention is not traceable to the Rule but instead resulted from the interplay of federal policy and the federal consent decree. Upon review, the Supreme Court of Texas found that the harm the Plaintiffs allege from the housing arrangement is "fairly traceable" to the Rule because the Plaintiffs alleged that at least one detained child was sexually assaulted by an unrelated adult following the Rule’s adoption, so that Plaintiffs had alleged harm in the form of increased risk of such assaults to minor detainees sharing rooms with unrelated adults, as well as the invasion of the children’s privacy from such room-sharing, which is a personal injury. Further the Supreme Court disagreed with the court of appeals' interpretation of the Rule explaining that the Rule permits bedroom sharing between a child and unrelated adult so long as that sharing facilitates housing a child with a family member. Because the alleged injuries included the actual and impending harm of a legally protected interest, the Court held that Plaintiffs' allegations were sufficiently concrete to satisfy the standing requirements. Accordingly, the Court granted the petition for review and reversed the court of appeals' judgment. The Court remanded to the court of appeals for consideration of the remaining jurisdictional issues and the merits, as appropriate.

Summary of Case Context & HoldingA group of health and welfare funds brought a class action against pharmacies alleging violations of the pricing provision of a generic-prescription-drug-substitution statute (the Pharmacy Practice Act, Minn. Stat. § 151.21, subd. 4 and the Minnesota Prevention of Consumer Fraud Act (CFA), Minn. Stat. § 325F.69, subd. 1) for failing to pass on the difference between the acquisition cost of brand name drugs and substituted generic prescription drugs. The district court granted the pharmacies' motion to dismiss the complaint, concluding that the Pharmacy Practice Act does not create a private cause of action in favor of the funds, and that the funds failed to plead a claim for relief under the CFA. The court of appeals affirmed the dismissal of the claim brought under the Pharmacy Practice Act, but reversed the dismissal of the claim brought under the CFA, concluding that the funds pleaded a legally sufficient claim. The Supreme Court affirmed in part and reversed in part, holding that: (1) pricing provision of the Pharmacy Practice Act provided no private cause of action for the funds; (2) but the funds were permitted to bring a consumer fraud claim under the CFA for conduct that violated pricing provision of the Pharmacy Practice Act; (3) an actionable omission-based consumer fraud claim under the CFA required a legal or equitable duty to disclose omitted facts; and (4) the pharmacies had no legal or equitable duty to disclose prescription-drug acquisition costs.

Summary of Case Context & HoldingFrank Tamburri sought to run in the Libertarian primary election for the United States Senate in 2016. In 2015, the Arizona legislature amended A.R.S. 16-322, which controlled the formula for determining the number of signatures required of a senatorial candidate to qualify as a nominee. Before 2015, a candidate in Tamburri's position would have needed 133 signatures from registered Libertarians to qualify for the primary ballot (0.5% of the party's registered voters). The amended formula required a Libertarian candidate to obtain at least 3,034 signatures to qualify for the election (0.25% of voters who are registered Libertarians or unaffiliated with a recognized political party). Tamburri conceded that he did not collect 3,034 signatures from qualified signers but argued that the 2015 amendments unconstitutionally burdened his First Amendment rights to political speech and association. The trial court rejected this argument and issued an injunction excluding Tamburri's name from the ballot. Tamburri appealed. The Arizona Supreme Court clarified that it must weigh the burdens the law imposes on the exercise of First Amendment rights against the state interests promoted by the restriction. Specifically, if the statute severely burdens the candidate's ability to exercise his or her rights, the law must be narrowly tailored to advance a compelling state interest; whereas, if the statute imposes only reasonable, nondiscriminatory restrictions on the candidate's rights, the state's important regulatory interests are generally sufficient to justify the restrictions, as long as those interests are rationally related to the restrictions. The Court held that the amended statute did not severely burden the ability of candidates to exercise their First Amendment right because Tamburri had not shown that the amended signature requirements would prevent reasonably diligent minority party candidates from gaining ballot access, and that the State had a strong interest in ensuring candidates in a general election have a significant modicum of support so as to avoid clutter and confusion on the election ballot.

Summary of Case Context & HoldingFrancis Graef alleged in a tort action that his employer Equity Livestock's worker's compensation insurance carrier, Continental Indemnity Company, was negligent in failing to approve payment for a refill of his antidepressant medication, prescribed after a workplace injury, and that as result of this negligence he suffered a self-inflicted gunshot injury during an attempted suicide. In relevant part, the Supreme Court held that the self-inflicted gunshot wound satisfied the conditions for worker's compensation liability. Thus, the Wisconsin Worker's Compensation Act provided the exclusive remedy and the employee could not bring a tort action against his employer.

Summary of Case Context & HoldingCasino host Sumona Islam entered into an agreement with her employer, Atlantis Casino Resort Spa (Atlantis), to refrain from employment, association, or service with any other gaming establishment within 150 miles of Atlantis for one year following the end of her employment. Islam eventually grew dissatisfied with her work at Atlantis and, while searching for work elsewhere, altered and copied gaming customers' information from Atlantis' computer management system. Soon after, she resigned from Atlantis and began working as a casino host at Grand Sierra Resort (GSR), where she accessed the computer management system to enter the copied information. Without knowing the information was wrongfully obtained, GSR used this and other information conveyed by Islam to market to those customers. The Supreme Court held that a noncompete agreement prohibiting an employee who was a casino host from working for any gaming business or enterprise in a specified area was overbroad because it prohibited working in any capacity and absent ambiguity, the overbroad provision rendered the noncompete agreement wholly unenforceable because the court could not redraft it (Nevada statute was later passed in NRS 613.195(5), which requires district courts to blue-pencil unreasonable noncompetition agreements and enforce the revised agreement). Additionally, although the employee's act of taking contact information caused some disruption to the employer's database, it was not severe enough to amount to conversion and the new employer had no liability for trade secret misappropriation under Nev. Rev. Stat. § 600A.030(2) because it reasonably relied on the employee's assurances that the contact information had been properly obtained.

Summary of Case Context & HoldingPlaintiff was injured in an accident and Florida's Medicaid program, administered by the Agency for Health Care Administration (ACHA), paid $322,222.27 for his medical care. He also settled with his alleged tortfeasor for $1,000,000. Pursuant to the formula outlined in the relevant Florida statute, AHCA calculated a presumptively appropriate amount of its lien at $321,720.16 and asserted a lien in that amount against Plaintiff's settlement. Of the 1,000,000 settlement only $13,881.79 was for compensation for past medical expenses. An administrative law judge upheld the lien amount, and the appeals court concurred, stating that both Florida law and the federal Medicaid Act permit AHCA to recover its Medicaid expenses for both past and future medical needs from Plaintiff's settlement funds. On appeal, the Florida Supreme Court overturned the decision, ruling that the federal Medicaid Act does not allow AHCA to place a lien on the future medical expenses portion of a Medicaid beneficiary’s third-party tort recovery. Under federal law, the AHCA can only claim the portion of a Medicaid recipient’s tort recovery allocated to past medical expenses to satisfy its Medicaid lien. The Court opined that the statute "is most naturally and reasonably read as referring to those 'health care items or services' already 'furnished' and for which 'payment has been made under the State plan.' Those are the health care items and services for which 'the State is considered to have acquired ... rights' by assignment 'to any payments by any other party,' and they are past medical expenses only." The partial concurrence agreed with the majority that the AHCA only allows for a lien on the past medical expenses portion of a Medicaid beneficiary's tort recovery, but arrives at its conclusion from reliance on federal case law as opposed to the unambiguity of the statute. The partial concurrence also disagreed with the majority's reduction of the lien without further fact finding on past medical expenses.

Summary of Case Context & HoldingThe Supreme Court denied a writ of mandamus that would require the Secretary of State and Elections Canvassing Commission to refrain from canvassing and reporting votes on Proposed Amendment #3, after the votes had started being cast, but before voting ended. Proposed Amendment #3 would have established a top-two open primary system for all state elections in Florida. According to the Court, Plaintiffs failed to show (1) clear legal right to the requested relief; (2) indisputable legal claim to perform the requested action; and (3) no other adequate remedy available. The Court did not expand on the standards required for each of these elements.

Summary of Case Context & HoldingThe City of Phoenix enters memoranda of understanding (MOUs) with the union representing municipal employees. One MOU permitted "release time," which allowed for employees to engage in lawful union activities under the sole supervision of the Union while being paid by the City. City employees who did not belong to the Union sued, alleging that the release time provisions violated their free speech, associational, and right-to-work rights, and violated the Gift Clause of the Arizona Constitution. The Arizona Supreme Court concluded that the release time provisions did not violate the non-union employees' rights because the time was paid for by the City, not out of mandatory union contributions by City employees. However, the Court went on to hold that the release time provisions were invalid under the Gift Clause because releasing employees to the Union to engage in Union activities was "substantially disproportionate to any benefits received by the City."

Summary of Case Context & HoldingA Medicaid recipient, who received discounted healthcare expenses through managed-care organizations established by the state's Prepaid Medical Assistance Program (PMAP), brought an action against a school bus driver and a bus owner after her vehicle was struck by a bus. After trial, the jury awarded the recipient damages, but the district court deducted from the award the amount of discounts negotiated by the recipient's managed-care organizations. Recipient appealed. The court of appeals reversed, holding that the discounts were excepted from offset because they were “payments made pursuant to the United States Social Security Act,” under the collateral-source statute, Minn. Stat. Ann. § 548.251, subdivision 1(2). The Supreme Court affirmed, holding that: (1) benefit payments and the discounts negotiated by managed-care organizations were payments made “pursuant to” the Social Security Act for purposes of collateral-source statute; (2) discounts negotiated by managed-care organizations under Minnesota's PMAP are payments made pursuant to the Social Security Act and, therefore, are not deducted from jury's damages award under collateral-source statute; and (3) the district court erred by subtracting the amount of the discounts negotiated by the Medicaid recipient's managed-care organizations from the damages awarded to that recipient.

Summary of Case Context & HoldingThe Georgia Governor signed two opposing pieces of legislation into law within weeks of each other. HB 826 was signed on April 22, 2014, and allowed for a person to be permitted with a licensed to carry a firearm in a school safety zone without limitation; HB 60 was signed on April 23, 2014 and was a more comprehensive bill addressing issues of weapons carry and licensing. HB 60 expressly prohibited the carrying of a weapon (including a firearm) within a school safety zone with enumerated exceptions. One of those exceptions included allowing persons licensed under O.C.G.A. § 16-11-129 to carry or possess a firearm within a school safety zone but only "when such person carries or picks up a student within a school safety zone." The Georgia Code Revision Commission (CRC) determined there was a conflict and HB 60 was controlling. This was determined based on O.C.G.A. § 28-9-5(b) which states when two bills are in obvious conflict and cannot both be carried out, the last one signed into law controls. Given that HB 60 was signed one day later than HB 826, HB 60 would control. This made it effectively unlawful to carry a firearm in a school zone outside of the exceptions. GeorgiaCarry.Org, a nonprofit organization, challenged this decision but the Supreme Court affirmed CRC's actions. The Supreme Court, however, did not reach the substantive merits of campus carry in schools context and made the decision solely on the basis of statutory procedural grounds.

Summary of Case Context & HoldingCharles Gary was injured in a collision while being transported in an ambulance operated by Low Country Medical Services. Low Country had been subcontracted by American Medical Response, Inc. (d/b/a Access2Care), which itself had a contract with the South Carolina Department of Health and Human Services (DHHS) to administer Medicaid's Nonemergency Medical Transportation Program. Gary sued Access2Care, arguing that both the contract with DHHS and public policy imposed a nondelegable duty on Access2Care to ensure the safe transportation of patients, making Access2Care liable for the injuries caused by its subcontractor. Shortly after Access2Care filed its amended answer—and before any meaningful discovery occurred—Gary moved for summary judgment. The trial court granted summary judgment in Gary’s favor, finding Access2Care owed a nondelegable duty. However, the South Carolina Court of Appeals reversed, concluding Access2Care did not owe such a duty. The South Carolina Supreme Court reviewed the case and determined that summary judgment had been granted prematurely because significant factual questions remained unresolved regarding the nature of the collision, and the parties had not yet conducted adequate discovery. The Supreme Court did not reach a conclusion regarding whether Access2Care owed a nondelegable duty. Instead the Supreme Cort vacated the court of appeals' decision and remanded the case to the circuit court for further proceedings to develop the factual record fully.

Summary of Case Context & HoldingPlaintiff, Golden State Equality along with six same-sex families, filed a lawsuit against the State of New Jersey in 2011, alleging that the New Jersey's civil union system failed to provide the same-sex couples with the same rights and protections as heterosexual couples and, therefore, violated the guarantees of equal protection contained in both the New Jersey and United States Constitutions. Plaintiff moved for summary judgement after the U.S. Supreme Court's ruling in United States v. Windsor, 570 U.S. 744 (2013), which struck down the federal Defense of Marriage Act and held that the federal government must extend federal marital benefits to same-sex couples who are lawfully married in states that have granted same-sex couples the right to civil marriage. The trial court granted Plaintiff's motion, holding that civil-union partners are being denied equal access to federal benefits because of the label placed on their relationship, and therefore, it held that the state must extend the right to civil marriage to same-sex couples. The state moved for a stay of the order, which was denied, and then appealed. In the absence of the state showing a reasonable probability of success on the merits, the Supreme Court affirmed the trial court's ruling that directed the state to permit same-sex couples to enter into civil marriage.

Summary of Case Context & HoldingParents of children enrolled in child care programs filed suit against the New York City Department of Health and Mental Hygiene and related agencies challenging amendments to city health code mandating that children who attend city-regulated child care or school-based programs receive annual flu vaccines. When determining whether agency rulemaking has exceeded legislative fiat, the circumstances to be considered are whether (1) the agency did more than balance the costs and benefits according to preexisting guidelines, but instead made value judgments entailing difficult and complex choices between broad policy goals to resolve social problems; (2) the agency merely filled in details of a broad policy or if it wrote on a clean slate, creating its own comprehensive set of rules without benefit of legislative guidance; (3) the legislature has unsuccessfully tried to reach an agreement on the issue, which would indicate that the matter is a policy consideration for the elected body to resolve; and (4) the agency used special expertise or competence in the field to develop the challenged regulation. Boreali v. Axelrod, 517 N.E.2d 1350 (N.Y. 1987). The Court of Appeals held that the new rule was written without benefit of legislative guidance pursuant to significant delegated power, it was not a result of choice between competing public policies, it did not conflict with state law, and the state did not preempt field of mandatory school vaccinations. Accordingly, the rule was permissibly adopted pursuant to legislatively-delegated and long-exercised authority to regulate vaccinations.

Summary of Case Context & HoldingWhile working as a driver, an employee was injured and filed a worker's compensation claim with Associated Rick Management, Inc. (ARM). The employee returned to work but was fired by the employer for creating a hostile work environment. After being terminated the employee filed for temporary total disability benefits. ARM denied benefits on the basis that a light duty job would still be available if the employee had not been terminated for creating a hostile work environment. Accordingly, ARM notified the employee that pursuant to NRS 616C.475, he was no longer eligible for temporary total disability benefits. The issue before the Supreme Court was whether NRS 616C.232, which provided that a claim could only be denied if the employee had been terminated for gross misconduct, applied. However, the Court found that because the evidence showed that the employee no longer had a temporary disability at the time he applied for temporary total disability benefits, he was not eligible for benefits in the first place. Therefore, NRS616C.232 was not applicable and the benefits would be denied regardless. The Supreme Court thus held that NRS 616C.232 did not apply and that the case had been correctly decided.

Summary of Case Context & HoldingRenown Health (Renown) terminated Appellant Michael Gamino's employment. Gamino sued, alleging that his termination was in retaliation for filing a workers compensation claim. Renown moved for summary judgment, introducing declarations and other evidence supporting its contention that Gamino was terminated for breaching Renown's confidentiality policy. The district court granted Renown's motion for summary judgment. Gamino appealed, arguing that the district court improperly granted summary judgment because the declarations submitted by Renown contained inadmissible hearsay. The Supreme Court affirmed the district court's holding of summary judgment and held that Gamino was required to demonstrate that his filing of the workers' compensation claim "was the proximate cause of his discharge" by affidavit or other admissible evidence, introducing specific facts that showed a genuine issue of material fact, but instead merely alleged that the evidence provided by Renown was inadmissible.

Summary of Case Context & HoldingThe Supreme Court held that a School District Board of Education's resolution following a school shooting authorizing certain superintendent-designated employees to carry a deadly weapon on school property for the welfare and safety of its students does not comply with Ohio law. Many students' parents challenged the resolution by filing a lawsuit. The Twelfth District Court of Appeals granted a permanent injunction barring implementation of the resolution. The case was about statutory interpretation and the Supreme Court held that Ohio law plainly states that those who wish to enter school property with weapons need a certain amount of training or experience, and that thus, the proposed resolution, which does not require the necessary training and experience per Ohio Rev. Code Ann. § 109.78(D), is non-compliant with Ohio law.

Summary of Case Context & HoldingParents of students filed action against school board and related defendants, seeking a permanent injunction precluding the school district from implementing a resolution allowing authorization of several district employees to carry concealed firearms into school safety zones and seeking declaratory judgment that the resolution was unlawful as it conflicted with the authority of a school board implicitly recognized in O.R.C. 2923.122(D)(1)(a) and the limitation on the category of employees a school board may authorize to go armed while on duty under O.R.C. 109.78(D). The Supreme Court held that O.R.C. 109.78(D) prohibits a school from employing a person who goes armed while on duty in his or her job unless the employee has satisfactorily completed an approved basic peace-officer-training program or has 20 years of experience as a peace officer. Otherwise, possessing a deadly weapon in a school safety zone is a criminal offense.

Summary of Case Context & HoldingA landlord's commercial general liability insurer brought action against the landlord and tenant for a declaratory judgment that lead paint ingested by the tenant's child was a "pollutant." The Supreme Court stated that when an insurance policy provision is susceptible to more than one meaning, even if each meaning is logical and reasonable, the provision is ambiguous and will be construed strictly against the insurer/drafter and in favor of the insured. In this case, the Supreme Court held that lead in paint ingested by tenant's child was a "pollutant" within the meaning of absolute pollution exclusion of landlord's commercial insurance policy.

Summary of Case Context & HoldingThe Center for a Sustainable Coast brought action against the Georgia Department of Natural Resources (DNR) seeking to enjoin the agency from issuing letters of permissions to third parties authorizing land alterations to property within the jurisdiction of the Georgia Shore Protection Act. The Supreme Court held that the Shore Protection Act did not provide statutory waiver of sovereign immunity; therefore, the group's action was barred. The Supreme Court also held that the group's action seeking to enjoin the DNR from issuing letters of permission to third parties to alter land within the jurisdiction of the Shore Protection Act was not moot, even though legislation had been passed specifically allowing the state to issue such letters, where the state had not yet been enjoined from issuing such letters, and had not voluntarily stopped issuing them.

Summary of Case Context & HoldingApplicants for aged, blind, and disabled Medicaid benefits separately appealed decisions of the Department of Human Services, Division of Medical Assistance and Health Services (DMAHS), that denied their applications based upon conclusion that each applicant's income exceeded the federal poverty line for a single individual as calculated under state regulation (Regulation) for the New Jersey Medical Assistance and Health Services Act (Act). In a consolidated appeal, the Superior Court, Appellate Division, reversed and remanded on the ground that the Regulation violated the state statutory law enabling the New Jersey Medicaid program. The Supreme Court affirmed as modified, holding that: (1) the Regulation requiring an individual's income to be compared against the poverty income guideline for one person conflicted with the plain language and legislative intent of the Act, which explicitly made medical assistance available to aged, blind, and disabled applicants whose income does not exceed 100% of the poverty level, adjusted for family size; (2) the Regulation altered the language of legislation and frustrated plain import of the legislative direction to adjust the poverty level to family size when determining eligibility; and (3) the Regulation was not compelled by federal Medicaid statute to operate in a manner that was at odds with the Act.

Summary of Case Context & HoldingCommonwealth court decision affirmed by Supreme Court with no opinion. This case involved a challenge under the Environmental Rights Amendment of the Pennsylvania Constitution, asking for relief to address the impact of Pennsylvania's fossil fuel activities on climate change. While the commonwealth court found that the Petitioners had standing to bring the suit and that they had jurisdiction to hear the case, the court ruled that Petitioners did not meet the requirements for their requested relief and dismissed their petition.

Summary of Case Context & HoldingJohn and Melissa Fritz purchased property adjacent to Whites Creek. Prior to their purchase, Washoe County approved plat maps for the development of an upstream development, Lancer Estates, and accepted various street dedications that were incorporated into the upstream developments' drainage system. The construction of the developments caused the Fritzes' property to flood. The Fritzes filed an inverse condemnation complaint against Washoe County, arguing the development constituted a taking. The district court granted summary judgment in favor of Washoe County finding approving the maps did not amount to the substantial involvement needed to support a claim of inverse condemnation. The Supreme Court held that because Washoe County did not participate in engineering or constructing the developments, there were genuine issues of material fact as to whether Washoe County's actions constituted substantial involvement in the drainage system and reversed the district court's grant of summary judgment.

Summary of Case Context & HoldingThe Plaintiffs are collective owners of real property in a remote area of the Adirondack Mountains, which is bounded on the north side by the William C. Whitney Wilderness Area (Wilderness Area) consisting of more than 20,000 acres of state forest preserve land. Shortly after the Wilderness Area entered public ownership, Defendant New York State Department of Environmental Conservation constructed a .8 mile trail to permit canoe travelers to avoid the Mud Pond Waterway—a two mile system of ponds and streams that crosses the Plaintiffs' property—and complete the waterway without entering the Plaintiffs' property. The Defendants claim that the Waterway is navigable-in-fact and therefore open to the public. The parties jointly requested a determination as a matter of law, but the Court of Appeals rejected this request. The Court held the record was inconclusive with regard to a number of material facts; for example, the Waterway's historical and prospective commercial utility, the Waterway's historical accessibility to the public, among other considerations.

Summary of Case Context & HoldingPetitioners filed an emergency ex parte application for extraordinary relief challenging the statutory authority for, and constitutionality of, the Governor's order requiring the closure of all non-life-sustaining businesses to reduce the spread of COVID-19. The Supreme Court denied the claim for relief, holding that: (1) the Supreme Court would exercise its Kings Bench powers (the extraordinary jurisdiction of the Supreme Court over inferior courts) to decide statutory and constitutional challenges to the Governor's executive order; (2) the Governor had the statutory authority to issue executive order; (3) the COVID-19 pandemic qualified as a “natural disaster” under the Pennsylvania Emergency Code; (4) the Governor's executive order was a proper exercise of his police power; (5) the doctrine of separation of powers was not violated by executive order; (6) the executive order did not constitute a taking of private property without just compensation; and (7) the executive order did not deprive the owners/operators of non-life-sustaining businesses of procedural due process.

Summary of Case Context & HoldingKohler-Andrae State Park borders private land owned by Kohler. In 2014, Kohler revealed plans to develop a golf course near the park, and in 2017, the Wisconsin Department of Natural Resources (DNR) recommended a land exchange agreement with Kohler. The land in question was 4.59 acres of woodland within the Park that "was no longer needed for the state's use for conservation purposes," and would be restricted use so that any development would not "compromise park aesthetics." In exchange, Kohler would give up 9.5 acres of land including woodlands, crop land, and a building that straddled the boundary of the Park. The Friends of Black River sought review of the conveyance, and Kohler filed a motion to dismiss, asserting that the Friends lacked standing because they failed to satisfy both the "injury in fact" and "zone of interest" prongs under Wis. Stat. Ch. 227 standing. The Friends argued that they suffered injuries from the land exchange because they currently enjoyed the land in the state park that was being exchanged, and they would lose the opportunity to study the wildlife on the 4.59 acres in question. Relying on federal standing principles, and analogizing those to the Wisconsin standing doctrine (Wis. Stat. Ch. 227), the Supreme Court explained that Wisconsin courts apply a two step standing approach, rooted in "sound judicial policy." The first step asks "whether the decision of the agency directly causes injury to the interest of the petitioner" and the second step asks "whether the interest asserted is recognized by law." Here, the Supreme Court found that the Friends lacked standing because none of their asserted interests were protected by law (which fails the second prong). While there are several Wisconsin statutes governing the preservation of park lands, and the transfer of land between the DNR and private parties, none of these laws protect, recognize, or regulate the asserted interests that the Friends cite, including their enjoyment and study of wildlife.

Summary of Case Context & HoldingThe Supreme Court upheld a law that, with some exceptions, nullified and voided all ordinances/rules/regulations directed at gun control at the local level and imposed civil penalties and actions on persons, counties, agencies, or municipalities deemed in violation of the statute. Petitioners (a group of 30 municipalities, 3 counties, and 70 elected officials) alleged that the law would violate "legislative immunity” and/or “governmental function immunity.” The Court disagreed. First, it found legislative immunity to be a common law doctrine, which the Legislature could overrule through statute. Second, it found that the establishment of ordinances, rules, and regulations did not fall within the limited scope of activity by government officials protected from tort claims by the doctrine of governmental function immunity.

Summary of Case Context & HoldingA employee was injured when she slipped and fell on the wet floor of the breakroom on her employer’s premises during a scheduled lunch break. She subsequently filed a claim for benefits under the Workers’ Compensation Act, Ga. Code Ann. § 34-9-1 (which provides for compensation for injuries that occur “in the course of” employment and “aris[e] out of” employment), but the State Board of Workers’ Compensation denied her claim. Employee sought judicial review, and the superior court upheld the denial of her claim. Employee then appealed the decision of the superior court, and the Court of Appeals of the State of Georgia affirmed. Relying on Ocean Accident & Guaranty Corp. v. Farr, 178 S.E. 128 (Ga. 1935) (holding that that the injury at issue did not “arise out of” employment because it occurred at a time when the employee had left his work duties and was engaged in an “individual pursuit”), the court of appeals held that the employee suffered no injury compensable under Ga. Code Ann. § 34-9-1 because she sustained her injury during a scheduled break, and her injury, therefore, did not arise out of her employment. Overruling Farr, the Supreme Court found that Farr misinterpreted and misapplied the general statutory definition of a compensable injury by acknowledging (i) that Farr did not address the “in the course of” prerequisite of Ga. Code Ann. § 34-9-1 and (ii) the Supreme Court has never relied on Farr in connection with the “arising out of” inquiry (consistently adhering instead to the proper, causation-based approach which asks whether there was a causal connection between the conditions under which the work [was] required to be performed and the resulting injury. The Supreme Court then reversed the decision of the court of appeals after finding that the employee's injury took place while she was engaged in an activity incidental to her employment (satisfying the “in the course of” prerequisite) and that the accident resulted from a risk reasonably incident to her employment, giving rise to a causal connection between the employment and the injury (satisfying the “arising out of” prerequisite).

Summary of Case Context & HoldingThe Supreme Court held that the Mount Vernon City School District Board of Education was correct in firing a public school teacher for good and just cause when the teacher did not obey reasonable and valid School Board orders and policy to remove religious displays in his classroom and to stop injecting personal Christian religious beliefs into his classroom teachings. The Supreme Court decided this case purely on the matter of employee termination and not on any Constitutional grounds; the Supreme Court did not consider any constitutional issues of religious beliefs in the classroom because the issue could be resolved by finding that the teacher was terminated for insubordination under Ohio Rev. Code Ann. § 3319.16, which provides that the contract of any teacher employed by the Board of Education of any city may only be terminated for good and just cause.

Summary of Case Context & HoldingA former employee brought an action against their employer alleging unlawful employment practices after they were terminated based on a positive test for cannabis, while holding at the time a valid state identification card for the medical cannabis registry. The employer terminated the employee consistent with a collective bargaining agreement with a zero-tolerance provision for drug use, and also sent the union a letter stating that the employee was no longer eligible for dispatch to the employer’s worksites. The Supreme Court held that: (i) the statute in the NRS Chapter on the Medical Use of Cannabis (NRS Chapter 678C), which requires an employer to make a reasonable accommodation for employee's medical cannabis use, with certain exceptions, provides an implied right of private action; (ii) the termination, without attempting to make a reasonable accommodation of employee's medical cannabis use did not offend a strong and compelling public policy and thus could not support a claim for tortious discharge; (iii) the state statute providing employment protections for the lawful use of products outside of the workplace did not provide a basis for an employment discrimination claim arising out of termination for use of medical cannabis outside the workplace; and (iv) the employee had failed to state a claim for negligent hiring, training, and supervision given that the alleged wrong related to the employer's decision to terminate the employee's employment because he used medical cannabis. Since the issue before the Supreme Court was essentially an appeal of the trial court’s resolution of a motion to dismiss for failure to state a claim, the Supreme Court declined to address the merits of the case, including whether an employer must attempt to accommodate an individual who uses marijuana after the individual has been involved in a workplace incident.

Summary of Case Context & HoldingIn 2010, the City of Miami declared a "financial urgency," which, under Florida state law, permitted the City to renegotiate its collective bargaining agreement with the Miami police union, Miami Lodge No. 20, Fraternal Order of Police. The union moved for a declaratory judgment against the city and challenged the facial constitutionality of Florida law because (1) it was too vague; (2) it deprived the union of due process; and (3) it violated equal protection. The lower court sided with the City, and the appellate court affirmed. The Florida Supreme Court denied the union's claims, reasoning that: (1) the law at issue was not impermissibly vague due to the lack of definition of "financial urgency" as the legislature purposely declined to define the term to defer to the Public Employees Relations Commission's expertise; (2) the statute does not violate due process under the Florida law or the Federal constitutions, as it is narrowly tailored to achieve a legitimate state interest where the statute only allows modification of a particular agreement once the government at issue has demonstrated that the only way of addressing its dire financial condition is through modification of that particular agreement in order to tend to the local government's immediate dire financial condition, the latter constituting a valid interest for which the narrowly tailored remedy of modifying an agreement is appropriate; and (3) there is no equal protection violation where the statute requires that persons similarly situated be treated similarly.

Summary of Case Context & HoldingFollowing convictions for three assaults, Franklin, a juvenile, was sentenced to three 1000-year concurrent sentences with parole. After more than ten parole hearings, the Parole Commission calculated a parole release date of 2352. Franklin filed a motion to vacate his sentences pursuant to Graham v. Florida, 560 U.S. 48 (2010) (forbidding a sentence of life without parole for juvenile nonhomicide offenders and requiring that a life sentence be accompanied by a meaningful opportunity to obtain release before the end of the sentence, but during a person's natural life), claiming that the sentences violate his Eighth Amendment rights. The Supreme Court found that the state's parole process fulfills the Graham requirement of providing a meaningful opportunity to be considered for release and that, since all three of Franklin's 1000-year sentences stipulated an opportunity for parole release, he has been given a meaningful opportunity. The Supreme Court further reasoned that the Graham Court did not require that the State actually release a juvenile offender during his natural life or guarantee his eventual freedom, as “those who commit truly horrifying crimes as juveniles may turn out to be irredeemable” and “will remain behind bars for life.”

Summary of Case Context & HoldingFrances was convicted of first-degree murder and sentenced to death. He made a motion before the circuit court to vacate his conviction, and upon the motion's denial, he directly appealed to the Supreme Court. Some issues with France's conviction considered by the court were claims that his conviction was the result of multiple failures of trial counsel. Among the claimed failures by trial counsel, was failure to object to the trial court's improper comments regarding "[y]anks" and "[s]outherners," failure to object to race being used as a basis to offer a life sentence, and failure to object to the court's racial bias in jury selection. The Supreme Court held that Frances failed to demonstrate purposeful discrimination, because he could not show that he was prejudiced by trial counsel's failure to object to the juror removal. Likewise the Supreme Court held that there was no basis that the death penalty was sought with race as a factor. Subsequently, his conviction was upheld.

Summary of Case Context & HoldingPetitioner, a Gila County deputy sheriff, developed post-traumatic stress disorder (PTSD) after he shot and killed a man who threatened him with a shotgun during a welfare check (Shooting Incident). In denying the Petitioner’s claim for benefits, the administrative law judge (ALJ) for the Industrial Commission of Arizona (ICA) based her determination on whether the Petitioner’s job duties encompassed the possibility of using lethal force in the line of duty, failing to consider whether the Shooting Incident itself was “unexpected, unusual, or extraordinary.” The Petitioner requested a review of the decision, which was confirmed by the ALJ. Thereafter, the ICA entered a decision and an award denying the Petitioner's claim for workers' compensation benefits. The Petitioner appealed, and the court of appeals set aside the ICA's decision and award, stating that the ALJ erroneously based the determination “upon the nature of the event, rather than the nature of the stress," and held that the phrase “unexpected, unusual, or extraordinary stress” should be construed as meaning “that the injury-inducing stress, imposed upon the claimant by virtue of his employment was sufficiently significant and noteworthy to differentiate it from the non-compensable, general stress caused by the work regimen.” The Arizona Supreme Court granted review to clarify the standard that applies to whether a mental injury arises from "some unexpected, unusual, or extraordinary stress related to employment." According to the statute, to prove a compensable injury, a claimant must show that: (1) the work-related stress “was a substantial contributing cause of the mental injury,” and (2) the stress was “unexpected, unusual, or extraordinary.” The Arizona Supreme Court confirmed that the Shooting Incident caused the Petitioner's post-traumatic stress disorder and the sole issue before it was whether his injury was caused by some unexpected, unusual, or extraordinary work-related stress. The Arizona Supreme Court differentiated the standards for singular work-related incidents versus injuries caused by a gradual build-up of work-related stress. The Court clarified that the statute requires an objective standard: the work-related event must be assessed from the perspective of a reasonable employee with similar job duties and training. The Court ultimately concluded that the Shooting Incident was not the type of incident that was part of a law enforcement officer’s daily routine, nor was it expected that a deputy would face such a dramatic brush with death when responding to a welfare check. The Court rejected Gila County’s argument that to bring a compensable mental injury claim under the applicable statute, a claimant must prove that the injury-causing event was outside the scope of his assigned job duties.

Summary of Case Context & HoldingFrom 1966-1970, Folta was a shipping clerk and product tester for Ferro Engineering. During this time, he was exposed to products containing asbestos. In 2011, Folta was diagnosed with mesothelioma, a disease that is associated with asbestos exposure. Folta sued Ferro for negligently causing the asbestos exposure and his resulting disease. Ferro argued Folta was barred from bringing a negligence claim because, given that the injury occurred at work, the Worker’s Compensation Act and Workers’ Occupational Disease Act were his only remedies. The Supreme Court held that the Folta's exclusive remedy is under the Workers’ Compensation Act because the legislature intended that the Workers Compensation Act be an absolute bar on the right to bring a claim.

Summary of Case Context & HoldingPlaintiff Tracie Flug appealed a decision by the Labor and Industry Review Commission (LIRC) denying her claim for partial disability benefits. The disability claim was spurred by complications from a surgery that Flug thought was aimed at remedying a workplace injury but was in reality targeted at correcting a pre-existing condition. Flug's employer, Wal-Mart, disputed the claim with a doctor's report that distinguished the workplace injury from the pre-existing condition. On that basis, LIRC denied Flug's claim. Flug appealed. The Supreme Court's decision involved discussion of Wis. Stat. § 102.42(1m), which potentially allows compensation for complications stemming from a good-faith invasive treatment of a workplace injury that goes wrong. However, the Supreme Court held that for an employee to receive permanent disability compensation due to a disability-causing surgery, that surgery must be directed at treating a workplace injury, not a pre-existing condition. In Flug's case, her treatment was directed at the pre-existing condition, and the connection between Flug's treatment and her workplace injury was too attenuated to result in compensation.