State Supreme Court Data Tracker
Use this data to spot trends, anticipate what’s next, and supercharge your advocacy.
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State v. Ugalde, 311 P.3d 772 (Mont. 2013)
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Montana | 2013 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2013
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of aggravated assault in connection with injuries to an infant. At trial, Defendant claimed that the infant had suffered its injuries after falling from its crib. The State claimed that Defendant had shaken the infant. On appeal, Defendant argued that the State's calling of 11 experts to testify to various aspects of the injuries was unnecessarily cumulative and unfairly prejudicial. The Court held that the 11 witnesses were not unduly prejudicial because, while there was some overlap in the testimony of the witnesses, it was impossible to separate which testimony went to the causation element (i.e. that Defendant had shaken the infant) and which testimony went to the serious bodily injury element. Defendant also claimed ineffective assistance of counsel because her attorney failed to object during the State's closing arguments when the State "channel[ed] the victim," speaking in the first person through the infant's point of view (for instance, "The prosecutor—while pretending to be [the infant]—said, 'Now, I can't hang out with kids my own age because I can't say what I want or do what I need. I can't tell my mom I love her.'"). In reviewing the State's closing argument as a whole, and in looking at the defense's closing argument, the Court held that a failure to object did not constitute deficient performance as required by Strickland v. Washington, 466 U.S. 668 (1984). Under Strickland, a defendant bears the burden of proving: (1) that counsel's performance was deficient; and (2) that counsel's deficient performance prejudiced the defense. The Court considered the State's closing argument as a whole and concluded that defense counsel's conduct fell within the wide range of reasonable professional conduct and Defendant had not met her burden of demonstrating deficient performance as required by Strickland.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of aggravated assault in connection with injuries to an infant. At trial, Defendant claimed that the infant had suffered its injuries after falling from its crib. The State claimed that Defendant had shaken the infant. On appeal, Defendant argued that the State's calling of 11 experts to testify to various aspects of the injuries was unnecessarily cumulative and unfairly prejudicial. The Court held that the 11 witnesses were not unduly prejudicial because, while there was some overlap in the testimony of the witnesses, it was impossible to separate which testimony went to the causation element (i.e. that Defendant had shaken the infant) and which testimony went to the serious bodily injury element. Defendant also claimed ineffective assistance of counsel because her attorney failed to object during the State's closing arguments when the State "channel[ed] the victim," speaking in the first person through the infant's point of view (for instance, "The prosecutor—while pretending to be [the infant]—said, 'Now, I can't hang out with kids my own age because I can't say what I want or do what I need. I can't tell my mom I love her.'"). In reviewing the State's closing argument as a whole, and in looking at the defense's closing argument, the Court held that a failure to object did not constitute deficient performance as required by Strickland v. Washington, 466 U.S. 668 (1984). Under Strickland, a defendant bears the burden of proving: (1) that counsel's performance was deficient; and (2) that counsel's deficient performance prejudiced the defense. The Court considered the State's closing argument as a whole and concluded that defense counsel's conduct fell within the wide range of reasonable professional conduct and Defendant had not met her burden of demonstrating deficient performance as required by Strickland.
Link to Opinion
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State v. Urrea, 421 P.3d 153 (Ariz. 2018)
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Arizona | 2018 | Civil Rights, Race, Criminal Justice |
State:
Arizona
Year:
2018
Topics:
Civil Rights, Race, Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThis case involved the question of appropriate remedies for Batson violations—i.e., the racially discriminatory use of peremptory strikes in jury selection. Batson v. Kentucky, 476 U.S. 79 (1986). The trial court sustained the Defendant's Batson challenge and reinstated three of the stricken jurors. The trial court then denied the Defendant's motion for a mistrial and dismissal of the entire jury pool. The Supreme Court affirmed such denial, noting that either a mistrial or restoration of the wrongfully excluded jurors may be proper depending on the circumstances.
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Justice Vote Breakdown
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Summary of Case Context & Holding
This case involved the question of appropriate remedies for Batson violations—i.e., the racially discriminatory use of peremptory strikes in jury selection. Batson v. Kentucky, 476 U.S. 79 (1986). The trial court sustained the Defendant's Batson challenge and reinstated three of the stricken jurors. The trial court then denied the Defendant's motion for a mistrial and dismissal of the entire jury pool. The Supreme Court affirmed such denial, noting that either a mistrial or restoration of the wrongfully excluded jurors may be proper depending on the circumstances.
Link to Opinion
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State v. Valenzuela, 371 P.3d 627 (Ariz. 2016)
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Arizona | 2016 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2016
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was arrested on suspicion of DUI and taken to a police station, where he was read an “admin per se” form. The form provided that Arizona law requires you to submit to breath, blood, or other bodily substance tests chosen by law enforcement. Defendant subsequently submitted to breath and blood tests and was charged with aggravated DUI. Defendant moved to suppress the test results, arguing that the warrantless search violated his Fourth Amendment rights because he did not voluntarily consent to the tests. The trial court denied the motion. Based on the parties’ stipulated facts, the court dismissed three counts and convicted Defendant on the remaining counts. On review, the Supreme Court of Arizona looked to Bumper v. North Carolina, 391 U.S. 543 (1968), for precedent on "informed consent." There, a grandmother consented to the search of her grandson's things within the grandmother's home. This was found by the U.S. Supreme Court to be insufficient to have lawful authority to consent on behalf of the owner. The Supreme Court of Arizona declined to extend this holding to admin per se circumstances. The Supreme Court of Arizona affirmed Defendant’s convictions, holding (1) Defendant’s consent was not freely and voluntarily given in this case; but (2) because the admonition was given in good faith reliance on precedent, exclusion of the test results was not required. This case is a seminal case in Arizona that the Supreme Court turns back to in cases involving an "admin per se" for blood and breath tests.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was arrested on suspicion of DUI and taken to a police station, where he was read an “admin per se” form. The form provided that Arizona law requires you to submit to breath, blood, or other bodily substance tests chosen by law enforcement. Defendant subsequently submitted to breath and blood tests and was charged with aggravated DUI. Defendant moved to suppress the test results, arguing that the warrantless search violated his Fourth Amendment rights because he did not voluntarily consent to the tests. The trial court denied the motion. Based on the parties’ stipulated facts, the court dismissed three counts and convicted Defendant on the remaining counts. On review, the Supreme Court of Arizona looked to Bumper v. North Carolina, 391 U.S. 543 (1968), for precedent on "informed consent." There, a grandmother consented to the search of her grandson's things within the grandmother's home. This was found by the U.S. Supreme Court to be insufficient to have lawful authority to consent on behalf of the owner. The Supreme Court of Arizona declined to extend this holding to admin per se circumstances. The Supreme Court of Arizona affirmed Defendant’s convictions, holding (1) Defendant’s consent was not freely and voluntarily given in this case; but (2) because the admonition was given in good faith reliance on precedent, exclusion of the test results was not required. This case is a seminal case in Arizona that the Supreme Court turns back to in cases involving an "admin per se" for blood and breath tests.
Link to Opinion
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State v. Vang, 847 N.W.2d 248 (Minn. 2014)
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Minnesota | 2014 | Criminal Justice, Juvenile Justice |
State:
Minnesota
Year:
2014
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was found guilty of first-degree murder, second degree murder, and attempted first-degree murder in connection with several drive-by shootings when he was 14 years old. Years later, Appellant filed a petition for postconviction relief, arguing that he was never certified to adult court and that the juvenile court lacked subject matter jurisdiction to impose adult sanctions on him. The Supreme Court agreed and remanded. On remand at the district court, Appellant pled not guilty, but was convicted on all counts and sentenced to life with the possibility of release, and to a consecutive 90-month sentence. Appellant appealed challenging (1) the subject matter jurisdiction of the district court to preside over his case on the basis that he was never certified to adult court and the conviction occurred when he was a juvenile; and (2) the constitutionality of the sentence of life with the possibility of release under Miller v. Alabama, 567 U.S. 460 (2012), which announced that mandatory life-without parole sentences for juvenile homicide offenders are unconstitutional based on the reasoning underlying the Miller decision, and the Minnesota State Constitution, which prohibits cruel and unusual punishment. The Supreme Court held that (1) because Appellant was 23 when his case was remanded to district court, the juvenile court no longer had jurisdiction, despite the fact that he was a juvenile when the crime was committed; (2) Miller is inapplicable because he is eligible for release after 30 years; and the sentence does not constitute cruel and unusual punishment because fist-degree murder is one of the most heinous crimes, and the same sentence has been issued for the same crime to a juvenile in State v. Mitchell, 577 N.W.2d 481, 488 (Minn. 1998).
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant was found guilty of first-degree murder, second degree murder, and attempted first-degree murder in connection with several drive-by shootings when he was 14 years old. Years later, Appellant filed a petition for postconviction relief, arguing that he was never certified to adult court and that the juvenile court lacked subject matter jurisdiction to impose adult sanctions on him. The Supreme Court agreed and remanded. On remand at the district court, Appellant pled not guilty, but was convicted on all counts and sentenced to life with the possibility of release, and to a consecutive 90-month sentence. Appellant appealed challenging (1) the subject matter jurisdiction of the district court to preside over his case on the basis that he was never certified to adult court and the conviction occurred when he was a juvenile; and (2) the constitutionality of the sentence of life with the possibility of release under Miller v. Alabama, 567 U.S. 460 (2012), which announced that mandatory life-without parole sentences for juvenile homicide offenders are unconstitutional based on the reasoning underlying the Miller decision, and the Minnesota State Constitution, which prohibits cruel and unusual punishment. The Supreme Court held that (1) because Appellant was 23 when his case was remanded to district court, the juvenile court no longer had jurisdiction, despite the fact that he was a juvenile when the crime was committed; (2) Miller is inapplicable because he is eligible for release after 30 years; and the sentence does not constitute cruel and unusual punishment because fist-degree murder is one of the most heinous crimes, and the same sentence has been issued for the same crime to a juvenile in State v. Mitchell, 577 N.W.2d 481, 488 (Minn. 1998).
Link to Opinion
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State v. Volkswagen AG, 279 So.3d 1109 (Ala. 2018)
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Alabama | 2018 | Environment, Pollution/Contamination, Climate Change/Global Warming/Emissions |
State:
Alabama
Year:
2018
Topics:
Environment, Pollution/Contamination, Climate Change/Global Warming/Emissions
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe State of Alabama brought action against an automobile manufacturer pursuant to the Alabama Environmental Management Act (AEMA) and the Alabama Air Pollution Control Act (AAPCA) based on allegations that the manufacturer installed and maintained software in its vehicles that was designed to alter emissions readings. After remand following removal of the action to federal court, the trial court dismissed, finding that the State’s claims were preempted by the federal Clean Air Act (CAA). The Alabama Supreme Court held that, given the unique factual situation involved in the case and the reasoning set forth by the multi-district litigation court, allowing the State to proceed would "stand as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress." Therefore, the Court affirmed holding that the trial court properly granted the automobile manufacturer's motion to dismiss.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The State of Alabama brought action against an automobile manufacturer pursuant to the Alabama Environmental Management Act (AEMA) and the Alabama Air Pollution Control Act (AAPCA) based on allegations that the manufacturer installed and maintained software in its vehicles that was designed to alter emissions readings. After remand following removal of the action to federal court, the trial court dismissed, finding that the State’s claims were preempted by the federal Clean Air Act (CAA). The Alabama Supreme Court held that, given the unique factual situation involved in the case and the reasoning set forth by the multi-district litigation court, allowing the State to proceed would "stand as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress." Therefore, the Court affirmed holding that the trial court properly granted the automobile manufacturer's motion to dismiss.
Link to Opinion
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State v. Walston, 766 S.E.2d 312 (N.C. 2014)
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North Carolina | 2014 | Criminal Justice |
State:
North Carolina
Year:
2014
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted in the superior court of sex offense in the first degree, rape in the first degree, and indecent liberties with a child. Defendant appealed. The court of appeals reversed and remanded for a new trial on the basis that (1) the trial court erred in prohibiting witness testimony about Defendant’s character of being respectful towards children; and (2) the trial court erred in not substituting the term “alleged victim” for the word “victim” in the pattern jury instructions. The State sought review. The Supreme Court reversed, holding (1) the trial court did not err in prohibiting evidence of Defendant’s respectful attitude towards children, as the proffered evidence was not sufficiently tailored to the State’s charges of child sexual abuse and was thus inadmissible; and (2) the trial court’s use of the term “victim” in the jury instructions was not impermissible commentary on a disputed issue of fact, and therefore, the trial court did not err in denying Defendant’s request to use the phrase “alleged victim” instead of the word “victim” in its charge to the jury.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted in the superior court of sex offense in the first degree, rape in the first degree, and indecent liberties with a child. Defendant appealed. The court of appeals reversed and remanded for a new trial on the basis that (1) the trial court erred in prohibiting witness testimony about Defendant’s character of being respectful towards children; and (2) the trial court erred in not substituting the term “alleged victim” for the word “victim” in the pattern jury instructions. The State sought review. The Supreme Court reversed, holding (1) the trial court did not err in prohibiting evidence of Defendant’s respectful attitude towards children, as the proffered evidence was not sufficiently tailored to the State’s charges of child sexual abuse and was thus inadmissible; and (2) the trial court’s use of the term “victim” in the jury instructions was not impermissible commentary on a disputed issue of fact, and therefore, the trial court did not err in denying Defendant’s request to use the phrase “alleged victim” instead of the word “victim” in its charge to the jury.
Link to Opinion
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State v. Weakland, 434 P.3d 578 (Ariz. 2019)
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2019 | Criminal Justice, Police Misconduct and Bias |
State:
Year:
2019
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPolice arrested Defendant for a DUI. After handcuffing Defendant and placing her in the backseat of the patrol car, police read her an "admin per se" form that required her to complete certain tests to determine blood alcohol. A blood draw revealed Defendant's blood alcohol content was well over the legal limit. The issue before the Supreme Court was whether the good faith exception to the exclusionary rule applied when the blood draw occurred after State v. Butler, 302 P.3d 609 (Ariz. 2013) but before State v. Valenzuela, 371 P.3d 627 (Ariz. 2016). In Butler, the Arizona Supreme Court determined that the Fourth Amendment requires an arrestee's consent to a warrantless blood draw be voluntary under the totality of the circumstances. Bulter did not expressly address the sufficiency of consent in response to the admin per se admonition. In Valenzuela, the Court held that consent in response to the admonition is not sufficient to show consent was freely and voluntarily given. Here, the Court held that the good-faith exception applies because the application of the exclusionary rule would not have meaningfully deterred police misconduct under the circumstances. The Court reasoned that Butler did not unsettle the law and it would be unreasonable to require police to predict a change in the law when courts failed to, therefore, the police reasonably relied on then-existing authority in conducting the blood draw of Defendant.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Police arrested Defendant for a DUI. After handcuffing Defendant and placing her in the backseat of the patrol car, police read her an "admin per se" form that required her to complete certain tests to determine blood alcohol. A blood draw revealed Defendant's blood alcohol content was well over the legal limit. The issue before the Supreme Court was whether the good faith exception to the exclusionary rule applied when the blood draw occurred after State v. Butler, 302 P.3d 609 (Ariz. 2013) but before State v. Valenzuela, 371 P.3d 627 (Ariz. 2016). In Butler, the Arizona Supreme Court determined that the Fourth Amendment requires an arrestee's consent to a warrantless blood draw be voluntary under the totality of the circumstances. Bulter did not expressly address the sufficiency of consent in response to the admin per se admonition. In Valenzuela, the Court held that consent in response to the admonition is not sufficient to show consent was freely and voluntarily given. Here, the Court held that the good-faith exception applies because the application of the exclusionary rule would not have meaningfully deterred police misconduct under the circumstances. The Court reasoned that Butler did not unsettle the law and it would be unreasonable to require police to predict a change in the law when courts failed to, therefore, the police reasonably relied on then-existing authority in conducting the blood draw of Defendant.
Link to Opinion
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State v. Whalen, 295 P.3d 1055 (Mont. 2013)
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Montana | 2013 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2013
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant pled guilty to one count of felony negligent vehicular assault and one count of felony criminal endangerment. The charges stemmed from an incident in which Defendant, then a licensed commercial driver employed as a bus driver, was driving a school bus full of students when he struck a 15 year-old girl in a designated crosswalk. Defendant was arrested and performed a breath test, which indicated a blood-alcohol concentration of .118. The district court sentenced him to six-year sentences with 18 months suspended on each count, to run concurrently, along with 100 hours of community service and 29 conditions to his suspended sentence. On appeal, Defendant argued that 12 of the 29 conditions violated the Montana Constitution. Defendant only “very briefly” discussed the constitutional claims, claiming that they pertained to “fundamental” rights with “significant components of liberty . . . [a]ny infringement of which will trigger the highest level of scrutiny, and thus the highest level of protection by the Courts.” Defendant identified the allegedly unconstitutional conditions by number and, in the words of the Court, “boldly states they are all 'arbitrary and repressive and are th[u]s violative of the [l]aw' and then cite[d] to three sections of Article II of the Montana Constitution." The Court declined to consider the issue further because Defendant had not developed any arguments that the conditions were unconstitutional. The Court emphasized that it is not the duty of the court to develop a legal argument on behalf of the appellee. The Court also declined to consider Defendant's argument that the district court illegally obtained his guilty plea because his appellate brief was deficient and did not comply with Montana's Rules of Appellate Procedure. Defendant attached a 16-page excerpt of a separate brief that he had filed with the district court and stated that the entire excerpt was incorporated by reference. The Court cited various other instances where the Defendant had properly complied with the Rules of Appellate Procedure, indicating that he was capable of doing so. The Court also cited numerous instances where it had provided guidance and resources to the Defendant in order for him to prepare proper briefs.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant pled guilty to one count of felony negligent vehicular assault and one count of felony criminal endangerment. The charges stemmed from an incident in which Defendant, then a licensed commercial driver employed as a bus driver, was driving a school bus full of students when he struck a 15 year-old girl in a designated crosswalk. Defendant was arrested and performed a breath test, which indicated a blood-alcohol concentration of .118. The district court sentenced him to six-year sentences with 18 months suspended on each count, to run concurrently, along with 100 hours of community service and 29 conditions to his suspended sentence. On appeal, Defendant argued that 12 of the 29 conditions violated the Montana Constitution. Defendant only “very briefly” discussed the constitutional claims, claiming that they pertained to “fundamental” rights with “significant components of liberty . . . [a]ny infringement of which will trigger the highest level of scrutiny, and thus the highest level of protection by the Courts.” Defendant identified the allegedly unconstitutional conditions by number and, in the words of the Court, “boldly states they are all 'arbitrary and repressive and are th[u]s violative of the [l]aw' and then cite[d] to three sections of Article II of the Montana Constitution." The Court declined to consider the issue further because Defendant had not developed any arguments that the conditions were unconstitutional. The Court emphasized that it is not the duty of the court to develop a legal argument on behalf of the appellee. The Court also declined to consider Defendant's argument that the district court illegally obtained his guilty plea because his appellate brief was deficient and did not comply with Montana's Rules of Appellate Procedure. Defendant attached a 16-page excerpt of a separate brief that he had filed with the district court and stated that the entire excerpt was incorporated by reference. The Court cited various other instances where the Defendant had properly complied with the Rules of Appellate Procedure, indicating that he was capable of doing so. The Court also cited numerous instances where it had provided guidance and resources to the Defendant in order for him to prepare proper briefs.
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State v. White, 827 S.E.2d 80 (N.C. 2019)
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North Carolina | 2019 | Criminal Justice |
State:
North Carolina
Year:
2019
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court found that Defendant's indictment was facially invalid because it failed to name the victim. An indictment is facially invalid if it fails to state some essential and necessary element of the offense of which the defendant is found guilty. In this case, the Supreme Court determined that using the phrase "victim #1" was insufficient to name the victim of alleged sexual abuse of a child, a crime which requires a victim. In this case, despite the victim not being named in the indictment, the State argued that the victim's identity was readily ascertainable from documents in the record. The Supreme Court did not accept this argument. The Supreme Court instead found that facial validity of the indictment is only determined by looking at the criminal pleading, regardless of ability to ascertain the victim's identity from other documents in the record because a valid bill of indictment is essential to give the trial court jurisdiction to try a defendant in the first instance.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court found that Defendant's indictment was facially invalid because it failed to name the victim. An indictment is facially invalid if it fails to state some essential and necessary element of the offense of which the defendant is found guilty. In this case, the Supreme Court determined that using the phrase "victim #1" was insufficient to name the victim of alleged sexual abuse of a child, a crime which requires a victim. In this case, despite the victim not being named in the indictment, the State argued that the victim's identity was readily ascertainable from documents in the record. The Supreme Court did not accept this argument. The Supreme Court instead found that facial validity of the indictment is only determined by looking at the criminal pleading, regardless of ability to ascertain the victim's identity from other documents in the record because a valid bill of indictment is essential to give the trial court jurisdiction to try a defendant in the first instance.
Link to Opinion
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State v. Williams, 184 N.E.3d 29 (Ohio 2021)
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Ohio | 2021 | Criminal Justice |
State:
Ohio
Year:
2021
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Defendant and his wife were indicted on charges related to drug possession and trafficking and agreed to a joint plea deal and subsequently pled guilty to certain charges. The wife received five years probation and the Defendant received nine years of prison time. Both were represented by the same attorney at their plea and sentencing hearings. The Defendant thereafter appealed arguing that he was due process and his right to counsel arguing that the trial court “failed to assure that [his] counsel explained the very real conflict posed by joint representation” before allowing the matter to proceed. The Supreme Court held that the trial court did not have an affirmative duty to inquire into the existence of a potential conflict of interest on the part of defense counsel when defense counsel represented both a defendant and his wife in a criminal trial. Instead, an indicia of conflict other than the mere fact of the co-representation must be apparent.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Defendant and his wife were indicted on charges related to drug possession and trafficking and agreed to a joint plea deal and subsequently pled guilty to certain charges. The wife received five years probation and the Defendant received nine years of prison time. Both were represented by the same attorney at their plea and sentencing hearings. The Defendant thereafter appealed arguing that he was due process and his right to counsel arguing that the trial court “failed to assure that [his] counsel explained the very real conflict posed by joint representation” before allowing the matter to proceed. The Supreme Court held that the trial court did not have an affirmative duty to inquire into the existence of a potential conflict of interest on the part of defense counsel when defense counsel represented both a defendant and his wife in a criminal trial. Instead, an indicia of conflict other than the mere fact of the co-representation must be apparent.
Link to Opinion
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State v. Williams, 71 N.E.3d 234 (Ohio 2016), abrogated by, State v. Henderson, 162 N.E.3d 776 (Ohio 2020)
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Ohio | 2016 | Criminal Justice, Access to Justice |
State:
Ohio
Year:
2016
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Defendant broke into his ex-girlfriend's house and shot and killed a person she was sleeping with and subsequently kidnapped and sexually assaulted her. At trial the jury found the Defendant guilty of multiple offenses including two counts of aggravated murder with death penalty specifications. At the sentencing hearing, the state elected to have the Defendant sentenced on the conviction for aggravated murder charged in Count three, and did not request a sentence on the convictions for murder in Count I or aggravated murder in Count II. The trial court merged Counts I and II into Count III and imposed a sentence of life imprisonment with no possibility of parole. The Defendant moved to correct his sentences arguing that the concurrent sentences on the three counts were contrary to law and should be merged into a single conviction for aggravated murder. The Supreme Court held that imposing separate sentences for allied offenses (crimes so similar that one automatically means another) is contrary to law and such sentences are void and thus contestable regardless of res judicata.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Defendant broke into his ex-girlfriend's house and shot and killed a person she was sleeping with and subsequently kidnapped and sexually assaulted her. At trial the jury found the Defendant guilty of multiple offenses including two counts of aggravated murder with death penalty specifications. At the sentencing hearing, the state elected to have the Defendant sentenced on the conviction for aggravated murder charged in Count three, and did not request a sentence on the convictions for murder in Count I or aggravated murder in Count II. The trial court merged Counts I and II into Count III and imposed a sentence of life imprisonment with no possibility of parole. The Defendant moved to correct his sentences arguing that the concurrent sentences on the three counts were contrary to law and should be merged into a single conviction for aggravated murder. The Supreme Court held that imposing separate sentences for allied offenses (crimes so similar that one automatically means another) is contrary to law and such sentences are void and thus contestable regardless of res judicata.
Link to Opinion
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State v. Williams, 862 N.W.2d 701 (Minn. 2015)
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Minnesota | 2015 | Criminal Justice, Access to Justice, Juvenile Justice |
State:
Minnesota
Year:
2015
Topics:
Criminal Justice, Access to Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was convicted of first-degree murder, attempted first-degree murder and burglary, stemming from offenses he committed in October of 1992 when he was 16 years old. Appellant entered a home and killed a woman and her three-year-old daughter, and severely injured her four-year-old son. The district court imposed: (i) a mandatory sentence of life imprisonment with the possibility of release for each first-degree murder conviction; (ii) a sentence of 240 months imprisonment for the attempted murder conviction (exercising its discretion under the statute to impose consecutive sentences due to the presence of aggravating factors); and (iii) a sentence of 18 months imprisonment for the burglary conviction. The district court ordered each sentence to be served consecutively, resulting in an aggregate sentence of at least 74 years. In May 2014, Appellant moved to correct his sentence based on the rule announced by the U.S. Supreme Court in Miller v. Alabama, 567 U.S. 460 (2012), which held that statutory provisions that mandate the imposition of life imprisonment without the possibility of release (LWOR) sentence for juvenile offenders sentenced as adults violate the Eighth Amendment to the U.S. Constitution because they preclude judicial consideration of an offender's youth and attendant circumstances. The Supreme Court of Minnesota affirmed the lower court's conviction, because the statutory provision in question in Miller mandated the imposition of an LWOR sentence, whereas in the Appellant's case, the decision to impose concurrent or consecutive sentences rests within the discretion of the district court.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant was convicted of first-degree murder, attempted first-degree murder and burglary, stemming from offenses he committed in October of 1992 when he was 16 years old. Appellant entered a home and killed a woman and her three-year-old daughter, and severely injured her four-year-old son. The district court imposed: (i) a mandatory sentence of life imprisonment with the possibility of release for each first-degree murder conviction; (ii) a sentence of 240 months imprisonment for the attempted murder conviction (exercising its discretion under the statute to impose consecutive sentences due to the presence of aggravating factors); and (iii) a sentence of 18 months imprisonment for the burglary conviction. The district court ordered each sentence to be served consecutively, resulting in an aggregate sentence of at least 74 years. In May 2014, Appellant moved to correct his sentence based on the rule announced by the U.S. Supreme Court in Miller v. Alabama, 567 U.S. 460 (2012), which held that statutory provisions that mandate the imposition of life imprisonment without the possibility of release (LWOR) sentence for juvenile offenders sentenced as adults violate the Eighth Amendment to the U.S. Constitution because they preclude judicial consideration of an offender's youth and attendant circumstances. The Supreme Court of Minnesota affirmed the lower court's conviction, because the statutory provision in question in Miller mandated the imposition of an LWOR sentence, whereas in the Appellant's case, the decision to impose concurrent or consecutive sentences rests within the discretion of the district court.
Link to Opinion
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State v. Wilson, 350 P.3d 800 (Ariz. 2015)
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Arizona | 2015 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2015
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant told the neighbors he had seven pounds of mercury in his house and they called the police. Responding to the call, first responders, including police officers, entered Defendant’s home without a warrant. Once inside, an officer smelled marijuana and found marijuana plants. Defendant was charged with production of marijuana and three counts of possession of drug paraphernalia. The trial court denied Defendant’s motion to suppress, concluding that exigent circumstances permitted the warrantless search. The court of appeals reversed, concluding that the search was not justified by exceptions to the warrant requirement (neither exigent circumstances nor the community caretaking exception). The State petitioned for review only the court of appeals' determination regarding the community caretaking exception arguing that entering a home under the community caretaking exemption preempted the Fourth Amendment challenge here. However, the Court distinguished this: "police officers do not become exempt from the Fourth Amendment’s warrant requirement merely because they are engaged in community caretaking functions." The Supreme Court reversed the trial court’s order denying the motion to suppress, holding that the community caretaking exception does not apply to homes. The Court further explained if exigent circumstances or an emergency are present, police may make a warrantless entry into the home under those exceptions.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant told the neighbors he had seven pounds of mercury in his house and they called the police. Responding to the call, first responders, including police officers, entered Defendant’s home without a warrant. Once inside, an officer smelled marijuana and found marijuana plants. Defendant was charged with production of marijuana and three counts of possession of drug paraphernalia. The trial court denied Defendant’s motion to suppress, concluding that exigent circumstances permitted the warrantless search. The court of appeals reversed, concluding that the search was not justified by exceptions to the warrant requirement (neither exigent circumstances nor the community caretaking exception). The State petitioned for review only the court of appeals' determination regarding the community caretaking exception arguing that entering a home under the community caretaking exemption preempted the Fourth Amendment challenge here. However, the Court distinguished this: "police officers do not become exempt from the Fourth Amendment’s warrant requirement merely because they are engaged in community caretaking functions." The Supreme Court reversed the trial court’s order denying the motion to suppress, holding that the community caretaking exception does not apply to homes. The Court further explained if exigent circumstances or an emergency are present, police may make a warrantless entry into the home under those exceptions.
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State v. Wilson, 884 S.Ed.2d 298 (Ga. 2023)
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Georgia | 2023 | Criminal Justice, Police Misconduct and Bias |
State:
Georgia
Year:
2023
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe State appealed the trial court's grant of the motion to suppress evidence. Defendant was arrested and the officers impounded his vehicle, which was later searched pursuant to a warrant. In the course of that search, the officers located two cell phones belonging to Defendant. The lead investigator sought a second search warrant to conduct a forensic investigation of the cell phones. Although the warrant was submitted with the investigator’s sworn affidavit, there was no other additional information, materials or testimony provided to the magistrate, who later issued the warrant. Defendant successfully challenged the validity of the warrant, contending that it was overly broad and authorized a general search of Defendant’s personal effects in contravention of the Fourth Amendment. With respect to search warrants, the Fourth Amendment requires that officers have sufficient guidance to locate and seize only those items the warrant authorizes them to take (the “particularity” requirement). Thus, a search conducted pursuant to a warrant that falls below the level of particularity required is unconstitutional under the Fourth Amendment. Here, the State argued that the warrant was limited to the search for evidence connected to the crimes at issue, yet the warrant authorized the search of “any and all stored electronic information.” The Supreme Court agreed with Defendant that such language cannot plausibly be read to restrict the otherwise limitless search for any and all cell phone data from Defendant’s phone. Without language narrowing the scope of the warrant, the Supreme Court easily distinguished this case from other successful appeals. The distinguishing factor in those other precedents was the presence of a residual clause or a provision applying to situations not explicitly listed in the statute, which in this case, somewhat negates the particularity requirement. Because there was no such clause and the warrant failed to satisfy the particularity requirement, the Supreme Court affirmed the trial court’s grant of Defendant’s motion to suppress. In a concurring opinion, Justice Peterson wrote separately to note how the majority’s analysis of residual clauses can, at times, overcomplicate the issue. In a separate concurring opinion, Justice Pinson addressed the modern cell phone in the context of the Fourth Amendment.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The State appealed the trial court's grant of the motion to suppress evidence. Defendant was arrested and the officers impounded his vehicle, which was later searched pursuant to a warrant. In the course of that search, the officers located two cell phones belonging to Defendant. The lead investigator sought a second search warrant to conduct a forensic investigation of the cell phones. Although the warrant was submitted with the investigator’s sworn affidavit, there was no other additional information, materials or testimony provided to the magistrate, who later issued the warrant. Defendant successfully challenged the validity of the warrant, contending that it was overly broad and authorized a general search of Defendant’s personal effects in contravention of the Fourth Amendment. With respect to search warrants, the Fourth Amendment requires that officers have sufficient guidance to locate and seize only those items the warrant authorizes them to take (the “particularity” requirement). Thus, a search conducted pursuant to a warrant that falls below the level of particularity required is unconstitutional under the Fourth Amendment. Here, the State argued that the warrant was limited to the search for evidence connected to the crimes at issue, yet the warrant authorized the search of “any and all stored electronic information.” The Supreme Court agreed with Defendant that such language cannot plausibly be read to restrict the otherwise limitless search for any and all cell phone data from Defendant’s phone. Without language narrowing the scope of the warrant, the Supreme Court easily distinguished this case from other successful appeals. The distinguishing factor in those other precedents was the presence of a residual clause or a provision applying to situations not explicitly listed in the statute, which in this case, somewhat negates the particularity requirement. Because there was no such clause and the warrant failed to satisfy the particularity requirement, the Supreme Court affirmed the trial court’s grant of Defendant’s motion to suppress. In a concurring opinion, Justice Peterson wrote separately to note how the majority’s analysis of residual clauses can, at times, overcomplicate the issue. In a separate concurring opinion, Justice Pinson addressed the modern cell phone in the context of the Fourth Amendment.
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State v. Wilson, 900 N.W.2d 373 (Minn. 2017)
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Minnesota | 2017 | Criminal Justice, Access to Justice |
State:
Minnesota
Year:
2017
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was convicted of first-degree premeditated murder, on the basis of accomplice-liability. Appellant argues the district court erred by denying his objection to the State's peremptory challenge of a black prospective juror under Batson v. Kentucky, 476 U.S. 79 (1986) (holding that the exclusion of prospective jurors through peremptory challenges is subject to the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution) who had told the district court both that he could be impartial, and that he thought it was a stretch to think a jury can be totally impartial in a trial. At trial, to decide whether the exercise of a peremptory challenge violates the Fourteenth Amendment, Minnesota follows the U.S. Supreme Court's three step Batson framework for determining whether a peremptory challenge is motivated by racial discrimination, where (1) the initial burden rests on the opponent of the challenge to make a prima facia showing that the state exercised its peremptory challenge against a prospective juror on the basis of race, by showing that one or more members of a racial minority had been peremptorily excluded and that circumstances of the case raise an inference that the exclusion was based on race; (2) once this burden is satisfied, the burden shifts to the State to articulate a race-neutral reason for the challenge (which need not be persuasive or plausible); and (3) if the burden is met, the opponent must persuade the district court that the proffered reason was merely a pretext for the party's true motive—purposeful discrimination. The Supreme Court of Minnesota held that: the fact that the State accepted one female African immigrant from Liberia and exercised peremptory challenge on one African-American male before exercising its peremptory challenge on a second African-American male did not satisfy Appellant’s burden under Batson; African-American juror’s conflicting statements on impartiality were sufficient to support court’s conclusion that Appellant failed to make a prima facie showing of racial discrimination under Batson.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant was convicted of first-degree premeditated murder, on the basis of accomplice-liability. Appellant argues the district court erred by denying his objection to the State's peremptory challenge of a black prospective juror under Batson v. Kentucky, 476 U.S. 79 (1986) (holding that the exclusion of prospective jurors through peremptory challenges is subject to the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution) who had told the district court both that he could be impartial, and that he thought it was a stretch to think a jury can be totally impartial in a trial. At trial, to decide whether the exercise of a peremptory challenge violates the Fourteenth Amendment, Minnesota follows the U.S. Supreme Court's three step Batson framework for determining whether a peremptory challenge is motivated by racial discrimination, where (1) the initial burden rests on the opponent of the challenge to make a prima facia showing that the state exercised its peremptory challenge against a prospective juror on the basis of race, by showing that one or more members of a racial minority had been peremptorily excluded and that circumstances of the case raise an inference that the exclusion was based on race; (2) once this burden is satisfied, the burden shifts to the State to articulate a race-neutral reason for the challenge (which need not be persuasive or plausible); and (3) if the burden is met, the opponent must persuade the district court that the proffered reason was merely a pretext for the party's true motive—purposeful discrimination. The Supreme Court of Minnesota held that: the fact that the State accepted one female African immigrant from Liberia and exercised peremptory challenge on one African-American male before exercising its peremptory challenge on a second African-American male did not satisfy Appellant’s burden under Batson; African-American juror’s conflicting statements on impartiality were sufficient to support court’s conclusion that Appellant failed to make a prima facie showing of racial discrimination under Batson.
Link to Opinion
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State v. Witt, 126 A.3d 850 (N.J. 2015)
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New Jersey | 2015 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2015
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDuring a routine traffic stop of Defendant for failure to dim his headlights, police conducted a search of the vehicle and discovered a firearm. Defendant was charged with unlawful possession of a handgun and possession of a handgun by a convicted person. Defendant challenged the search, arguing it was illegal because police did not have exigent circumstances to search the car. The Supreme Court was asked to determine whether the constitutional standard governing an automobile search in State v. Pena-Flores, 965 A.2d 114 (N.J. 2009) is unsound in principle and unworkable in practice. Such existing standard is a pure exigent-circumstances requirement to justify an automobile search, with a multi-factor test to guide police officers in determining whether exigent circumstances excuse the securing of a warrant. The Supreme Court stated that "Experience and common sense persuade us that the exigent circumstances test in Pena-Flores does not provide greater liberty or security to New Jersey's citizens and has placed on law enforcement unrealistic and impracticable burdens." The Supreme Court re-established the standard from State v. Alston, 440 A.2d 1311 (N.J. 1981), which was overruled by Pena-Florez, which provides that a warrantless search of an automobile is constitutionally permissible, provided that the police have probable cause to search the vehicle and that the police action was prompted by the "unforeseeability and spontaneity of the circumstances giving rise to the probable cause." The Supreme Court reasoned that the overruled test was not practical because the multi-factor exigency formula was too complex for a reasonable police officer to apply in circumstances requiring quick thinking and action and "the securing of telephonic warrants results in unacceptably prolonged roadway stops."
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Justice Vote Breakdown
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Summary of Case Context & Holding
During a routine traffic stop of Defendant for failure to dim his headlights, police conducted a search of the vehicle and discovered a firearm. Defendant was charged with unlawful possession of a handgun and possession of a handgun by a convicted person. Defendant challenged the search, arguing it was illegal because police did not have exigent circumstances to search the car. The Supreme Court was asked to determine whether the constitutional standard governing an automobile search in State v. Pena-Flores, 965 A.2d 114 (N.J. 2009) is unsound in principle and unworkable in practice. Such existing standard is a pure exigent-circumstances requirement to justify an automobile search, with a multi-factor test to guide police officers in determining whether exigent circumstances excuse the securing of a warrant. The Supreme Court stated that "Experience and common sense persuade us that the exigent circumstances test in Pena-Flores does not provide greater liberty or security to New Jersey's citizens and has placed on law enforcement unrealistic and impracticable burdens." The Supreme Court re-established the standard from State v. Alston, 440 A.2d 1311 (N.J. 1981), which was overruled by Pena-Florez, which provides that a warrantless search of an automobile is constitutionally permissible, provided that the police have probable cause to search the vehicle and that the police action was prompted by the "unforeseeability and spontaneity of the circumstances giving rise to the probable cause." The Supreme Court reasoned that the overruled test was not practical because the multi-factor exigency formula was too complex for a reasonable police officer to apply in circumstances requiring quick thinking and action and "the securing of telephonic warrants results in unacceptably prolonged roadway stops."
Link to Opinion
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State v. Yang, 452 P.3d 897 (Mont. 2019)
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Montana | 2019 | Criminal Justice |
State:
Montana
Year:
2019
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant pled guilty to possessing 144 pounds of marijuana. The district court fined her $75,600—35% of the drugs' market value—pursuant to Section 45-130(1) of the MCA. Defendant appealed, arguing that the statute was facially unconstitutional because it mandated the imposition of a 35% fine and does not allow a court to consider—before imposing the fine—the nature of the crime committed, the offender's financial resources, or the nature of the burden of the mandatory fine on the offender. The Court remanded, holding that the statute was unconstitutional because it did not allow the sentencing judge to consider whether the 35% market value fine is grossly disproportional to the gravity of the offense. In particular, "[a] sentencing judge may not impose the 35%-market-value fine contained in [the statute] without considering the factors in § 46-18-231(3), MCA, thereby ensuring that the offender's fine is not grossly disproportional to the offense committed and protecting an offender's federal and state constitutional rights to be free from excessive fines."
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant pled guilty to possessing 144 pounds of marijuana. The district court fined her $75,600—35% of the drugs' market value—pursuant to Section 45-130(1) of the MCA. Defendant appealed, arguing that the statute was facially unconstitutional because it mandated the imposition of a 35% fine and does not allow a court to consider—before imposing the fine—the nature of the crime committed, the offender's financial resources, or the nature of the burden of the mandatory fine on the offender. The Court remanded, holding that the statute was unconstitutional because it did not allow the sentencing judge to consider whether the 35% market value fine is grossly disproportional to the gravity of the offense. In particular, "[a] sentencing judge may not impose the 35%-market-value fine contained in [the statute] without considering the factors in § 46-18-231(3), MCA, thereby ensuring that the offender's fine is not grossly disproportional to the offense committed and protecting an offender's federal and state constitutional rights to be free from excessive fines."
Link to Opinion
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State v. Young, 794 S.E.2d 274 (N.C. 2016)
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North Carolina | 2016 | Criminal Justice, Juvenile Justice |
State:
North Carolina
Year:
2016
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court held that Defendant's sentence of life in prison without the possibility for parole, for a murder conviction from when the Defendant was 17, violated the Eighth Amendment prohibition on cruel and unusual punishment. The Court reached this conclusion by retroactively applying the U.S. Supreme Court's decision in Miller v. Alabama, 567 U.S. 460 (2012). In Miller, the U.S. Supreme Court ruled that mandatory life sentences for juveniles, without the possibility for parole, almost always violate the Eighth Amendment prohibition on cruel and unusual punishment. Though the Defendant in this case was convicted prior to the Miller decision, the Supreme Court held in this case that Miller must apply retroactively as well.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court held that Defendant's sentence of life in prison without the possibility for parole, for a murder conviction from when the Defendant was 17, violated the Eighth Amendment prohibition on cruel and unusual punishment. The Court reached this conclusion by retroactively applying the U.S. Supreme Court's decision in Miller v. Alabama, 567 U.S. 460 (2012). In Miller, the U.S. Supreme Court ruled that mandatory life sentences for juveniles, without the possibility for parole, almost always violate the Eighth Amendment prohibition on cruel and unusual punishment. Though the Defendant in this case was convicted prior to the Miller decision, the Supreme Court held in this case that Miller must apply retroactively as well.
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State v. Zalcberg, 180 A.3d 304 (N.J. 2018)
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New Jersey | 2018 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2018
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingZalcberg, the Defendant, was charged with second-degree vehicular homicide and assault by auto. On the night of the incident, the Defendant was driving with two passengers in Freehold Township when her car collided with another vehicle and one the passengers in the Defendant's car died in the crash. At the scene, paramedics reportedly told police that the Defendant smelled like alcohol, and the officers also found a small bottle of liquor in the vehicle’s console. Using this evidence, the officers said they had probable cause to believe the Defendant was driving while intoxicated. The Defendant moved to suppress results of a warrantless blood draw, arguing that the police procedure violated her Fourth Amendment right. The trial court judge granted the motion, which was reversed and remanded on appeal. The Supreme Court ultimately decided, in a 5-2 ruling in favor of the State, that objective exigency justified the officers' warrantless taking of defendant's blood sample after the vehicular accident. The majority determined that the circumstances fulfilled the exigency requirement to conduct warrantless blood sampling on a person suspected of drunk driving in New Jersey. The Court explained, “We conclude that the officers’ lack of awareness of any formal procedure through which they could obtain a telephonic warrant, coupled with their pre-McNeely [referring to Missouri v. McNeely, 569 U.S. 141 (2013)] belief that they did not need such a warrant, suggests there was no reasonable availability of a warrant.”
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Justice Vote Breakdown
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Summary of Case Context & Holding
Zalcberg, the Defendant, was charged with second-degree vehicular homicide and assault by auto. On the night of the incident, the Defendant was driving with two passengers in Freehold Township when her car collided with another vehicle and one the passengers in the Defendant's car died in the crash. At the scene, paramedics reportedly told police that the Defendant smelled like alcohol, and the officers also found a small bottle of liquor in the vehicle’s console. Using this evidence, the officers said they had probable cause to believe the Defendant was driving while intoxicated. The Defendant moved to suppress results of a warrantless blood draw, arguing that the police procedure violated her Fourth Amendment right. The trial court judge granted the motion, which was reversed and remanded on appeal. The Supreme Court ultimately decided, in a 5-2 ruling in favor of the State, that objective exigency justified the officers' warrantless taking of defendant's blood sample after the vehicular accident. The majority determined that the circumstances fulfilled the exigency requirement to conduct warrantless blood sampling on a person suspected of drunk driving in New Jersey. The Court explained, “We conclude that the officers’ lack of awareness of any formal procedure through which they could obtain a telephonic warrant, coupled with their pre-McNeely [referring to Missouri v. McNeely, 569 U.S. 141 (2013)] belief that they did not need such a warrant, suggests there was no reasonable availability of a warrant.”
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State v. Zimmerman, 328 P.3d 1132 (Mont. 2014)
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Montana | 2014 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2014
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was arrested on July 21, 2012 for driving under the influence. He made his first court appearance two days later on July 23, 2012. The preliminary hearing was scheduled for August 3, 2012, but was continued due to scheduling conflicts and never rescheduled. Defendant spent three days in jail after the initial hearing and as a condition to his release was required to abstain from alcohol and wear a leg monitor which was checked once a week to report whether he had consumed alcohol. The State took no action on Defendant’s case until mid-January 2013, which the State later explained was the result of the case “falling off the . . . Court’s calendar.” Defendant was arraigned on January 31, 2013 and trial was scheduled for May 5, 2013, 289 days after his arrest. Defendant moved to dismiss the charges due to a denial of his right to a speedy trial. The district court denied the request and Defendant was sentenced to 13 months of incarceration plus a four-year suspended sentence. On appeal, the Court applied a four-part balancing test to determine whether Defendant’s right to a speedy trial was violated: (i) the length of the delay, which was in favor of Defendant because it was at least 200 days, which is the threshold for conducting the rest of the analysis; (ii) the reasons for the delay, which was in favor of Defendant because it was due to the State’s "lack of diligence . . . in bringing the matter forward" and institutional delay occasioned by the court's crowded docket; (iii) the Defendant’s response to the delay, which, although not strongly in favor of the Defendant, did not hurt his case because he made no acquiescence to the delay and filed a speedy trial motion as soon as the information (formal criminal charge which begins a criminal proceeding in the courts) was filed; and (iv) prejudice to the accused, here, involving prolonged anxiety about the trial, prolonged use of the monitoring bracelet, and a risk that the Defendant’s case would be detrimentally impacted due to fading memories about the incident. Balancing these factors, the Court concluded that Defendant’s right to a speedy trial had been violated.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was arrested on July 21, 2012 for driving under the influence. He made his first court appearance two days later on July 23, 2012. The preliminary hearing was scheduled for August 3, 2012, but was continued due to scheduling conflicts and never rescheduled. Defendant spent three days in jail after the initial hearing and as a condition to his release was required to abstain from alcohol and wear a leg monitor which was checked once a week to report whether he had consumed alcohol. The State took no action on Defendant’s case until mid-January 2013, which the State later explained was the result of the case “falling off the . . . Court’s calendar.” Defendant was arraigned on January 31, 2013 and trial was scheduled for May 5, 2013, 289 days after his arrest. Defendant moved to dismiss the charges due to a denial of his right to a speedy trial. The district court denied the request and Defendant was sentenced to 13 months of incarceration plus a four-year suspended sentence. On appeal, the Court applied a four-part balancing test to determine whether Defendant’s right to a speedy trial was violated: (i) the length of the delay, which was in favor of Defendant because it was at least 200 days, which is the threshold for conducting the rest of the analysis; (ii) the reasons for the delay, which was in favor of Defendant because it was due to the State’s "lack of diligence . . . in bringing the matter forward" and institutional delay occasioned by the court's crowded docket; (iii) the Defendant’s response to the delay, which, although not strongly in favor of the Defendant, did not hurt his case because he made no acquiescence to the delay and filed a speedy trial motion as soon as the information (formal criminal charge which begins a criminal proceeding in the courts) was filed; and (iv) prejudice to the accused, here, involving prolonged anxiety about the trial, prolonged use of the monitoring bracelet, and a risk that the Defendant’s case would be detrimentally impacted due to fading memories about the incident. Balancing these factors, the Court concluded that Defendant’s right to a speedy trial had been violated.
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State v. Zimmerman, 417 P.3d 289 (Mont. 2018)
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2018 | Criminal Justice |
State:
Year:
2018
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was charged with aggravated DUI, a statutory crime under Montana law that requires as an element the proof of one or more aggravating factors, one of which is the proof of prior DUI convictions. The Defendant was willing to stipulate to the prior DUI convictions at sentencing in order to avoid having the evidence of the prior DUI's introduced to the jury, which he argued would be unduly prejudicial. The State argued that one of the reasons that the prior convictions were included in the statute as an aggravating factor was precisely to allow the jury to consider the repeat behavior and know that "this is a person who is familiar with the process and is still doing it." The district court agreed and denied the motion to suppress. The jury returned a guilty verdict. The Court reversed on this issue, concluding that the existence of other aggravating factors (e.g. a BAC over 0.16) each of which would be sufficient to satisfy the element, shows that the legislature did not intend to have the prior DUI convictions necessarily introduced. Since the Defendant was willing to stipulate to these convictions, and the conviction would have avoided undue prejudice, the district court erred in denying the motion. In a footnote, the Court suggested that bifurcating the evidence (i.e. trying the Defendant on the instant DUI charge, then introducing evidence at the sentencing hearing) could be a "workable solution," but did not adopt the approach.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was charged with aggravated DUI, a statutory crime under Montana law that requires as an element the proof of one or more aggravating factors, one of which is the proof of prior DUI convictions. The Defendant was willing to stipulate to the prior DUI convictions at sentencing in order to avoid having the evidence of the prior DUI's introduced to the jury, which he argued would be unduly prejudicial. The State argued that one of the reasons that the prior convictions were included in the statute as an aggravating factor was precisely to allow the jury to consider the repeat behavior and know that "this is a person who is familiar with the process and is still doing it." The district court agreed and denied the motion to suppress. The jury returned a guilty verdict. The Court reversed on this issue, concluding that the existence of other aggravating factors (e.g. a BAC over 0.16) each of which would be sufficient to satisfy the element, shows that the legislature did not intend to have the prior DUI convictions necessarily introduced. Since the Defendant was willing to stipulate to these convictions, and the conviction would have avoided undue prejudice, the district court erred in denying the motion. In a footnote, the Court suggested that bifurcating the evidence (i.e. trying the Defendant on the instant DUI charge, then introducing evidence at the sentencing hearing) could be a "workable solution," but did not adopt the approach.
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State v. Zuber, 152 A.3d 197 (N. J. 2017)
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New Jersey | 2017 | Criminal Justice, Juvenile Justice |
State:
New Jersey
Year:
2017
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe First Petitioner sought postconviction relief, alleging that sentences imposed following his convictions for gang rape, arising out of two different instances when he was a juvenile, were unconstitutional. The Second Petitioner filed a motion to correct an illegal sentence, challenging the imposition of consecutive sentences for robbery and murder offenses committed as a juvenile. The New Jersey Supreme Court adopted the holding from Miller v. Alabama, 132 S.Ct. 2455 (2012), where the U.S. Supreme Court held that a sentencing judge must consider youth and its attendant characteristics prior to sentencing a juvenile to life without parole, finding that the requirements of Miller apply to a sentence that is the practical equivalent of life without parole. The New Jersey Supreme Court found that the term-of-years sentences at issue, a minimum of 55 years' imprisonment and 68 years and 3 months, respectively for the First Petitioner and Second Petitioner, were sufficient to trigger Miller, and that Petitioners were each entitled to resentencing.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The First Petitioner sought postconviction relief, alleging that sentences imposed following his convictions for gang rape, arising out of two different instances when he was a juvenile, were unconstitutional. The Second Petitioner filed a motion to correct an illegal sentence, challenging the imposition of consecutive sentences for robbery and murder offenses committed as a juvenile. The New Jersey Supreme Court adopted the holding from Miller v. Alabama, 132 S.Ct. 2455 (2012), where the U.S. Supreme Court held that a sentencing judge must consider youth and its attendant characteristics prior to sentencing a juvenile to life without parole, finding that the requirements of Miller apply to a sentence that is the practical equivalent of life without parole. The New Jersey Supreme Court found that the term-of-years sentences at issue, a minimum of 55 years' imprisonment and 68 years and 3 months, respectively for the First Petitioner and Second Petitioner, were sufficient to trigger Miller, and that Petitioners were each entitled to resentencing.
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State v. Zurawski, 690 S.W.3d 644 (Tex. 2024)
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Texas | 2024 | Health Care, Reproductive Rights/Abortion, Public Health |
State:
Texas
Year:
2024
Topics:
Health Care, Reproductive Rights/Abortion, Public Health
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingUnder Texas law, an abortion may only be performed when the physician, exercising “reasonable medical judgment” concludes that the pregnant woman has a “life-threatening physical condition” posing a risk of death or serious physical issues if an abortion is not performed. The Center for Reproductive Rights (Center), on behalf of certain Texas Plaintiffs, sued the State challenging aspects of the State’s abortion regulations. Included among the Plaintiffs were numerous Texas women who had suffered severe complications during their pregnancies, as well as two doctors. The Center claimed that the complications suffered by each of the women should have made their abortions permissible under the Texas law. Instead, the Plaintiff doctors were adverse to performing abortions for fear of legal consequences. As a result, each of the women either did not receive abortions or were forced to be delayed as they sought abortions in other states. The Center sued seeking an injunction against the enforcement of a trio of Texas laws that formed the basis of the State’s abortion restrictions. At trial, the court heard testimony from patients, a doctor, and experts regarding the dangerous conditions the women experienced in their pregnancies, and the extent to which said conditions could have resulted in their death or serious injury, meeting the threshold to allow an abortion. Following trial, the trial court ordered a temporary injunction, preventing the State from enforcing the bans against any physician who performed an abortion on a pregnant woman who, in the doctor’s “good faith judgment,” had (1) a pregnancy complication that posed a risk of infection or made the pregnancy unsafe; (2) a condition exacerbated by the pregnancy; or (3) a fetal condition causing the fetus to be unlikely to survive pregnancy and live after. The State appealed directly to the Supreme Court. The Court first analyzed the ways that the trial court’s injunction had fundamentally shifted the structure of the Texas abortion bans. First, the Court noted, the trial court’s injunction replaced the standard of “reasonable medical judgment” with one of “good faith judgment.” The Court viewed that such a change would fundamentally alter the scope of the law, as it would require an inquiry into the intentions of the doctor (through the “good faith” standard), rather than an inquiry into the medical facts underlying the pregnant women’s status. As a result, the Court held that this was a “call for amending the law, not for interpreting it” and held that the trial court was wrong to alter this standard. The Court then turned to the trial court’s alteration of the “life-threatening physical condition” threshold into a standard that the Court characterized as permitting abortion for any “unsafe” abortion. The Court held that the trial court’s alteration of the law had unjustly lowered the standard such that essentially any pregnancy could pose enough risk to allow for an abortion. Finally, the Court held that the health of the fetus could not permit an abortion and that instead only the health of the mother could be considered. As a result, the Court overruled the trial court’s injunction holding that the lower court had incorrectly and unjustly modified the State’s laws.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Under Texas law, an abortion may only be performed when the physician, exercising “reasonable medical judgment” concludes that the pregnant woman has a “life-threatening physical condition” posing a risk of death or serious physical issues if an abortion is not performed. The Center for Reproductive Rights (Center), on behalf of certain Texas Plaintiffs, sued the State challenging aspects of the State’s abortion regulations. Included among the Plaintiffs were numerous Texas women who had suffered severe complications during their pregnancies, as well as two doctors. The Center claimed that the complications suffered by each of the women should have made their abortions permissible under the Texas law. Instead, the Plaintiff doctors were adverse to performing abortions for fear of legal consequences. As a result, each of the women either did not receive abortions or were forced to be delayed as they sought abortions in other states. The Center sued seeking an injunction against the enforcement of a trio of Texas laws that formed the basis of the State’s abortion restrictions. At trial, the court heard testimony from patients, a doctor, and experts regarding the dangerous conditions the women experienced in their pregnancies, and the extent to which said conditions could have resulted in their death or serious injury, meeting the threshold to allow an abortion. Following trial, the trial court ordered a temporary injunction, preventing the State from enforcing the bans against any physician who performed an abortion on a pregnant woman who, in the doctor’s “good faith judgment,” had (1) a pregnancy complication that posed a risk of infection or made the pregnancy unsafe; (2) a condition exacerbated by the pregnancy; or (3) a fetal condition causing the fetus to be unlikely to survive pregnancy and live after. The State appealed directly to the Supreme Court. The Court first analyzed the ways that the trial court’s injunction had fundamentally shifted the structure of the Texas abortion bans. First, the Court noted, the trial court’s injunction replaced the standard of “reasonable medical judgment” with one of “good faith judgment.” The Court viewed that such a change would fundamentally alter the scope of the law, as it would require an inquiry into the intentions of the doctor (through the “good faith” standard), rather than an inquiry into the medical facts underlying the pregnant women’s status. As a result, the Court held that this was a “call for amending the law, not for interpreting it” and held that the trial court was wrong to alter this standard. The Court then turned to the trial court’s alteration of the “life-threatening physical condition” threshold into a standard that the Court characterized as permitting abortion for any “unsafe” abortion. The Court held that the trial court’s alteration of the law had unjustly lowered the standard such that essentially any pregnancy could pose enough risk to allow for an abortion. Finally, the Court held that the health of the fetus could not permit an abortion and that instead only the health of the mother could be considered. As a result, the Court overruled the trial court’s injunction holding that the lower court had incorrectly and unjustly modified the State’s laws.
Link to Opinion
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State v.Miranda, 292 A.3d 473 (N.J. 2023)
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New Jersey | 2023 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2023
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA woman that lived with Defendant went to the police station to report an assault and threats by Defendant, explaining Defendant had a black bag of weapons in the residential trailer he lived in with her. Officers obtained a temporary restraining order against Defendant and a search warrant for the shared residential trailer. The woman accompanied the officers to the residential trailer. Defendant answered the door and an Officer arrested him. While an Officer transported Defendant to the police station, another Officer searched the residential trailer, but found no weapons. The Officer then conducted a warrantless search of a nearby storage trailer after confirming the woman also stored items in the trailer. The Officer located a black bag with weapons in the trailer that was used as evidence against Defendant at trial after his motion to suppress was denied. The Supreme Court held that, although the woman had apparent authority to consent to the officer’s search of the storage trailer, that authority did not extend to all items inside the storage trailer including the black bag, which belonged only to the Defendant. The Court found the woman had apparent authority over the trailer based on a number of factors including that she also stored items in it, she had access to it, she had lived in the community longer than Defendant and he was planning on leaving but she was planning to stay. The authority over the trailer itself did not extend to all items in it. Additionally, the Court found that the exigent-circumstances exception to the warrant requirement did not justify the officer’s search of the black bag or his seizure of the weapons in that bag because, although there was probable cause and it related to a serious crime, there was not adequate urgency because Defendant was not in a position to retrieve the evidence while the Officer waited for a warrant, it was unlikely the evidence could be lost or destroyed, and the Defendant was not currently armed and dangerous. The Court found that the denial of Defendant’s motion to suppress constituted error and vacated the conviction because the weapons were central evidence to his conviction.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A woman that lived with Defendant went to the police station to report an assault and threats by Defendant, explaining Defendant had a black bag of weapons in the residential trailer he lived in with her. Officers obtained a temporary restraining order against Defendant and a search warrant for the shared residential trailer. The woman accompanied the officers to the residential trailer. Defendant answered the door and an Officer arrested him. While an Officer transported Defendant to the police station, another Officer searched the residential trailer, but found no weapons. The Officer then conducted a warrantless search of a nearby storage trailer after confirming the woman also stored items in the trailer. The Officer located a black bag with weapons in the trailer that was used as evidence against Defendant at trial after his motion to suppress was denied. The Supreme Court held that, although the woman had apparent authority to consent to the officer’s search of the storage trailer, that authority did not extend to all items inside the storage trailer including the black bag, which belonged only to the Defendant. The Court found the woman had apparent authority over the trailer based on a number of factors including that she also stored items in it, she had access to it, she had lived in the community longer than Defendant and he was planning on leaving but she was planning to stay. The authority over the trailer itself did not extend to all items in it. Additionally, the Court found that the exigent-circumstances exception to the warrant requirement did not justify the officer’s search of the black bag or his seizure of the weapons in that bag because, although there was probable cause and it related to a serious crime, there was not adequate urgency because Defendant was not in a position to retrieve the evidence while the Officer waited for a warrant, it was unlikely the evidence could be lost or destroyed, and the Defendant was not currently armed and dangerous. The Court found that the denial of Defendant’s motion to suppress constituted error and vacated the conviction because the weapons were central evidence to his conviction.
Link to Opinion
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State. v. Tidwell, 175 N.E.3d 527 (Ohio 2021)
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Ohio | 2021 | Criminal Justice |
State:
Ohio
Year:
2021
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA person yelled to an officer that they need to stop a car because the driver was drunk and the officer proceeded to pursue the driver by stopping it on foot. The driver smelled of alcohol, admitted she was drinking, and failed a sobriety test. She was subsequently arrested and at trial she filed a motion to suppress the evidence gathered at the stop on the basis that there was no reasonable suspicion for the stop and therefore it was a violation of the driver's Fourth Amendment right. The Supreme Court held that an in-person tip from an unidentified informant–“Hey, you need to stop that vehicle. That lady is drunk”– had some indicia of reliability and was sufficient to support reasonable suspicion to allow a Terry stop to investigate the possible operating-a-vehicle-impaired offense when combined with the officer’s personal observation of very slow driving and a blank stare.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A person yelled to an officer that they need to stop a car because the driver was drunk and the officer proceeded to pursue the driver by stopping it on foot. The driver smelled of alcohol, admitted she was drinking, and failed a sobriety test. She was subsequently arrested and at trial she filed a motion to suppress the evidence gathered at the stop on the basis that there was no reasonable suspicion for the stop and therefore it was a violation of the driver's Fourth Amendment right. The Supreme Court held that an in-person tip from an unidentified informant–“Hey, you need to stop that vehicle. That lady is drunk”– had some indicia of reliability and was sufficient to support reasonable suspicion to allow a Terry stop to investigate the possible operating-a-vehicle-impaired offense when combined with the officer’s personal observation of very slow driving and a blank stare.
Link to Opinion
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Steak N. Shake, Inc. v. Ramos, 415 So. 3d 107 (Fla. 2025)
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Florida | Labor, Employment & Economic Justice |
State:
Florida
Year:
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC) and the Florida Commission on Human Rights and in doing so signed off on the statement that he wanted “this charge filed with both the EEOC and the State or local agency, if any." While he did not specifically call out the Florida Civil Rights Act, the relevant state statute governing discrimination claims, in doing so the court found that he had none the less exhausted administrative remedies and, therefore was entitled to bring a case directly against his employer for discrimination.
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Justice Vote Breakdown Justices Political Affiliation
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Summary of Case Context & Holding
Plaintiff filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC) and the Florida Commission on Human Rights and in doing so signed off on the statement that he wanted “this charge filed with both the EEOC and the State or local agency, if any." While he did not specifically call out the Florida Civil Rights Act, the relevant state statute governing discrimination claims, in doing so the court found that he had none the less exhausted administrative remedies and, therefore was entitled to bring a case directly against his employer for discrimination.
Link to Opinion
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Steilman v. Michael, 407 P.3d 313 (Mont. 2017)
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Montana | 2017 | Criminal Justice, Juvenile Justice |
State:
Montana
Year:
2017
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant petitioned for a writ of habeas corpus by relying on Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, 136 S. Ct. 718 (2016). Defendant argued that his sentence of 110 years imprisonment without parole for deliberate homicide with use of a weapon violated his Eighth Amendment rights. Defendant claimed the violation stems from him being 17 when the offense took place and that the court did not take that into consideration. The Court addressed two issues: (1) whether Miller and Montgomery apply to Montana’s discretionary sentencing scheme; and (2) whether Defendant's sentence qualifies as a de facto life sentence. The Court held that both cases applied to discretionary sentences in Montana. Regarding the applicability to de facto life sentences in Montana, the dispositive issue in this case was whether the unique circumstances of Defendant's Montana sentence, when viewed in light of his eligibility for day-for-day good time credit and the concurrent sentence he was serving at the time in Washington, qualified as a de facto life sentence to which Miller’s substantive rule applies. The Court concluded that the sentence did not qualify as a de facto life sentence and did not reach the merits of whether the district court properly considered the special circumstances of his youth which would be required under Miller. Miller’s substantive rule requires Montana’s sentencing judges to adequately consider the mitigating characteristics of youth. In this case, the State argued that because Montana law provided a distinction between sentences of life imprisonment, term-of-years, and death, a term-of-years sentence could not become a de facto life sentence and equate to a de jure life imprisonment under Montana law. The Court disagreed. The same principles that made Miller applicable to Montana’s discretionary scheme similarly applied to a term-of-years sentence that was the practical equivalent of life without parole. In this case, the issue remained if this was a de facto life sentence given that it was 110 years. The Court concluded it was not because with good time credit the Defendant could be released after serving 55 years. Defendant's sentence does not trigger Eighth Amendment protections under Montgomery, Miller, or Graham v. Florida, 560 U.S. 48 (2010) (a case Miller relied on). The Court held this was to Defendant's benefit and the Court could not allow him to reap this benefit while disregarding it for purposes of assessing the proportionality of his Montana sentence.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant petitioned for a writ of habeas corpus by relying on Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, 136 S. Ct. 718 (2016). Defendant argued that his sentence of 110 years imprisonment without parole for deliberate homicide with use of a weapon violated his Eighth Amendment rights. Defendant claimed the violation stems from him being 17 when the offense took place and that the court did not take that into consideration. The Court addressed two issues: (1) whether Miller and Montgomery apply to Montana’s discretionary sentencing scheme; and (2) whether Defendant's sentence qualifies as a de facto life sentence. The Court held that both cases applied to discretionary sentences in Montana. Regarding the applicability to de facto life sentences in Montana, the dispositive issue in this case was whether the unique circumstances of Defendant's Montana sentence, when viewed in light of his eligibility for day-for-day good time credit and the concurrent sentence he was serving at the time in Washington, qualified as a de facto life sentence to which Miller’s substantive rule applies. The Court concluded that the sentence did not qualify as a de facto life sentence and did not reach the merits of whether the district court properly considered the special circumstances of his youth which would be required under Miller. Miller’s substantive rule requires Montana’s sentencing judges to adequately consider the mitigating characteristics of youth. In this case, the State argued that because Montana law provided a distinction between sentences of life imprisonment, term-of-years, and death, a term-of-years sentence could not become a de facto life sentence and equate to a de jure life imprisonment under Montana law. The Court disagreed. The same principles that made Miller applicable to Montana’s discretionary scheme similarly applied to a term-of-years sentence that was the practical equivalent of life without parole. In this case, the issue remained if this was a de facto life sentence given that it was 110 years. The Court concluded it was not because with good time credit the Defendant could be released after serving 55 years. Defendant's sentence does not trigger Eighth Amendment protections under Montgomery, Miller, or Graham v. Florida, 560 U.S. 48 (2010) (a case Miller relied on). The Court held this was to Defendant's benefit and the Court could not allow him to reap this benefit while disregarding it for purposes of assessing the proportionality of his Montana sentence.
Link to Opinion
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Steinhardt v. N.J. Redistricting Comm'n, 268 A.3d 299 (N.J. 2022)
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New Jersey | 2022 | Democracy & Voting, Gerrymandering/Redistricting |
State:
New Jersey
Year:
2022
Topics:
Democracy & Voting, Gerrymandering/Redistricting
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingOn December 30, 2021, Plaintiffs, who were Republican members of the New Jersey Redistricting Commission (Commission), sued the Commission, John E. Wallace, Jr. (in his capacity as Chair of Commission), and the Democratic members of the Commission challenging the Chair's decision to choose the congressional redistricting map proposed by the Democratic members of the Commission. In accordance with the requirements laid out in the state Constitution, the Commission was comprised of six Republicans, six Democrats, and one independent member who was selected by the Supreme Court from a list of two names (one chosen by the Democratic members and one chosen by the Republican members). The Republican members asked the Supreme Court, which has sole and original jurisdiction over "any action" of the Commission under the state Constitution, to declare the maps unlawful because, according to Plaintiffs, the Chair did not adequately explain his reasons for voting in favor of the map the Democratic members put forth. In granting the Defendants' motion to dismiss, the Supreme Court reiterated that its only role in reviewing the redistricting maps was to determine if the map was "unlawful or reflects invidious discrimination," and that "[i]t is not the Court's task to decide whether one map is fairer or better than another." Here, the Supreme Court said the Republican members did not argue that the map that the Commission adopted was "unlawful or . . . the result of invidious discrimination," and as such their claim could not prevail. The Supreme Court also rejected Plaintiffs' argument that the Chair had a conflict of interest under the common law because his wife made a political donation to a New Jersey congressman in 2021 and thus should have recused himself. In rejecting this claim, the Supreme Court said that the information about political donations was readily and publicly available to Plaintiffs and that political contributions did not bar someone from being selected as Chair under the state Constitution.
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Justice Vote Breakdown
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Summary of Case Context & Holding
On December 30, 2021, Plaintiffs, who were Republican members of the New Jersey Redistricting Commission (Commission), sued the Commission, John E. Wallace, Jr. (in his capacity as Chair of Commission), and the Democratic members of the Commission challenging the Chair's decision to choose the congressional redistricting map proposed by the Democratic members of the Commission. In accordance with the requirements laid out in the state Constitution, the Commission was comprised of six Republicans, six Democrats, and one independent member who was selected by the Supreme Court from a list of two names (one chosen by the Democratic members and one chosen by the Republican members). The Republican members asked the Supreme Court, which has sole and original jurisdiction over "any action" of the Commission under the state Constitution, to declare the maps unlawful because, according to Plaintiffs, the Chair did not adequately explain his reasons for voting in favor of the map the Democratic members put forth. In granting the Defendants' motion to dismiss, the Supreme Court reiterated that its only role in reviewing the redistricting maps was to determine if the map was "unlawful or reflects invidious discrimination," and that "[i]t is not the Court's task to decide whether one map is fairer or better than another." Here, the Supreme Court said the Republican members did not argue that the map that the Commission adopted was "unlawful or . . . the result of invidious discrimination," and as such their claim could not prevail. The Supreme Court also rejected Plaintiffs' argument that the Chair had a conflict of interest under the common law because his wife made a political donation to a New Jersey congressman in 2021 and thus should have recused himself. In rejecting this claim, the Supreme Court said that the information about political donations was readily and publicly available to Plaintiffs and that political contributions did not bar someone from being selected as Chair under the state Constitution.
Link to Opinion
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Stenz v. Indus. Comm'n of Ariz., 353 P.3d 361 (Ariz. 2015)
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Arizona | 2015 | Labor, Employment & Economic Justice |
State:
Arizona
Year:
2015
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2005, Charles Stenz suffered an on-the-job injury for which he filed a claim with his employer’s insurance carrier, Pinnacle Risk Management. Pinnacle accepted the claim and paid the benefits. In 2009, Stenz died. Alleging that his death resulted partly from the 2005 injury, Stenz’s widow filed a claim for death benefits under A.R.S. § 23-1061(A). The claim was filed with the Industrial Commission on September 21, 2009, and Pinnacle received notice of the claim on October 21, 2009. One week later, Pinnacle denied the claim. An Administrative Law Judge (ALJ) upheld the claim, but the court of appeals set aside that award. Following a new hearing, the ALJ issued an award granting death benefits, and in 2013, the ALJ entered a final order affirming the award. Pinnacle paid the benefits dating back to Stenz’s death, but did not pay interest on the unpaid benefits. Stenz's widow requested a hearing pursuant to A.R.S. § 23-1061(J), alleging that she was owed interest on unpaid death benefits from the time the claim was originally filed until the award was ultimately paid. The ALJ ruled that no interest was owed on the death benefit before the award became final in 2013. The court of appeals set this ruling aside, concluding that the claim was liquidated as of the date Pinnacle received notice of it. The Arizona Supreme Court concluded that Arizona's general interest statute, A.R.S. § 44-1201, applied to the death benefits at issue (which are considered liquidated under A.R.S. § 23-1046) and therefore, interest on them accrues from the time a carrier receives notice that a survivor has filed a claim with the Industrial Commission pursuant to A.R.S. § 23-1061(A). The Court based its conclusion on three reasons. First, that A.R.S. § 44-1201 has been interpreted to mean that interest begins to accrue when “(1) there is a legal ‘indebtedness . . . or other obligation’ to pay benefits, and (2) when the carrier has ‘notice of [this] obligation to pay.’” Second, no court action is required to create a legal obligation under Arizona's workers' compensation scheme, as the obligation to pay was created by statute for a liquidated amount prescribed by the statute’s schedule. Since Pinnacle had notice of the obligation upon its receipt of Stenz's widow's claim in October 2009, interest began to accrue at that time. Lastly, the Court reasoned that a contrary ruling would deprive a claimant of the full value of the benefit owed, while undesirably encouraging insurance carriers to protract litigation to delay paying benefits for as long as possible.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 2005, Charles Stenz suffered an on-the-job injury for which he filed a claim with his employer’s insurance carrier, Pinnacle Risk Management. Pinnacle accepted the claim and paid the benefits. In 2009, Stenz died. Alleging that his death resulted partly from the 2005 injury, Stenz’s widow filed a claim for death benefits under A.R.S. § 23-1061(A). The claim was filed with the Industrial Commission on September 21, 2009, and Pinnacle received notice of the claim on October 21, 2009. One week later, Pinnacle denied the claim. An Administrative Law Judge (ALJ) upheld the claim, but the court of appeals set aside that award. Following a new hearing, the ALJ issued an award granting death benefits, and in 2013, the ALJ entered a final order affirming the award. Pinnacle paid the benefits dating back to Stenz’s death, but did not pay interest on the unpaid benefits. Stenz's widow requested a hearing pursuant to A.R.S. § 23-1061(J), alleging that she was owed interest on unpaid death benefits from the time the claim was originally filed until the award was ultimately paid. The ALJ ruled that no interest was owed on the death benefit before the award became final in 2013. The court of appeals set this ruling aside, concluding that the claim was liquidated as of the date Pinnacle received notice of it. The Arizona Supreme Court concluded that Arizona's general interest statute, A.R.S. § 44-1201, applied to the death benefits at issue (which are considered liquidated under A.R.S. § 23-1046) and therefore, interest on them accrues from the time a carrier receives notice that a survivor has filed a claim with the Industrial Commission pursuant to A.R.S. § 23-1061(A). The Court based its conclusion on three reasons. First, that A.R.S. § 44-1201 has been interpreted to mean that interest begins to accrue when “(1) there is a legal ‘indebtedness . . . or other obligation’ to pay benefits, and (2) when the carrier has ‘notice of [this] obligation to pay.’” Second, no court action is required to create a legal obligation under Arizona's workers' compensation scheme, as the obligation to pay was created by statute for a liquidated amount prescribed by the statute’s schedule. Since Pinnacle had notice of the obligation upon its receipt of Stenz's widow's claim in October 2009, interest began to accrue at that time. Lastly, the Court reasoned that a contrary ruling would deprive a claimant of the full value of the benefit owed, while undesirably encouraging insurance carriers to protract litigation to delay paying benefits for as long as possible.
Link to Opinion
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Stockmeier v. Green, 340 P.3d 583 (Nev. 2014)
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Nevada | 2014 | Health Care, Public Health, Criminal Justice |
State:
Nevada
Year:
2014
Topics:
Health Care, Public Health, Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingUnder Nevada law, Nevada's Chief Medical Officer (CMO) is required to examine and report semiannually to the Board of State Prison Commissioners on the current state of nutrition for incarcerated individuals. An inmate in a Nevada correctional center filed a petition for mandamus and injunctive relief compelling the then-CMO to undergo these examinations and to report to the Board her findings. Stockmeier alleged that the CMO had inadequately relied on a report of a dietitian alone, and had further not communicated the dietitian's findings of poor nutrition to the Board. In response, the CMO presented a 2011 report and minutes from a meeting of the Board indicating that they had presented nutritional information to the Board, but had presented no recommendations. However, the report mostly concerned medical care in correctional facilities, and indicated that nutritional information was only reviewed at a single facility every six months. Nonetheless, the district court denied the Plaintiff's petition, ruling that Nevada law only required the CMO to ensure that inmates were not being malnourished. On appeal, the Supreme Court considered the extent to which the requirements placed on the CMO by Nevada law were being met. The Supreme Court held that the CMO's report and reporting practices were inadequate, as they had not properly surveyed the nutritional information at the different correctional facilities by merely reviewing uninformative menus. Further, although the Supreme Court would refrain from setting parameters for the CMO's review, they found that Nevada law required a higher standard than protection against malnourishment in the prison population.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Under Nevada law, Nevada's Chief Medical Officer (CMO) is required to examine and report semiannually to the Board of State Prison Commissioners on the current state of nutrition for incarcerated individuals. An inmate in a Nevada correctional center filed a petition for mandamus and injunctive relief compelling the then-CMO to undergo these examinations and to report to the Board her findings. Stockmeier alleged that the CMO had inadequately relied on a report of a dietitian alone, and had further not communicated the dietitian's findings of poor nutrition to the Board. In response, the CMO presented a 2011 report and minutes from a meeting of the Board indicating that they had presented nutritional information to the Board, but had presented no recommendations. However, the report mostly concerned medical care in correctional facilities, and indicated that nutritional information was only reviewed at a single facility every six months. Nonetheless, the district court denied the Plaintiff's petition, ruling that Nevada law only required the CMO to ensure that inmates were not being malnourished. On appeal, the Supreme Court considered the extent to which the requirements placed on the CMO by Nevada law were being met. The Supreme Court held that the CMO's report and reporting practices were inadequate, as they had not properly surveyed the nutritional information at the different correctional facilities by merely reviewing uninformative menus. Further, although the Supreme Court would refrain from setting parameters for the CMO's review, they found that Nevada law required a higher standard than protection against malnourishment in the prison population.
Link to Opinion
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Strong v. State, 845 S.E.2d 653 (Ga. 2020)
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Georgia | 2020 | Criminal Justice, Access to Justice |
State:
Georgia
Year:
2020
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of felony murder, aggravated assault, and knife-possession offenses. At trial, Defendant claimed that he acted in self-defense. Defendant argued that the trial court abused its discretion when it admitted under OCGA § 24-4-404(b) evidence of multiple other acts of violence that he allegedly committed. The Supreme Court held that the trial court erred by admitting numerous incidents of other acts evidence because the fact that a defendant may have committed violent crimes against other people many years earlier had nothing to do with his reason for stabbing the victims in the case being considered, and had no purpose other than to show a propensity toward violence. Defendant's convictions were reversed.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of felony murder, aggravated assault, and knife-possession offenses. At trial, Defendant claimed that he acted in self-defense. Defendant argued that the trial court abused its discretion when it admitted under OCGA § 24-4-404(b) evidence of multiple other acts of violence that he allegedly committed. The Supreme Court held that the trial court erred by admitting numerous incidents of other acts evidence because the fact that a defendant may have committed violent crimes against other people many years earlier had nothing to do with his reason for stabbing the victims in the case being considered, and had no purpose other than to show a propensity toward violence. Defendant's convictions were reversed.
Link to Opinion
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Stuckey v. State, 804 S.E.2d 76 (Ga. 2017)
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Georgia | 2017 | LGBTQ+ Rights, LGBTQ+ Discrimination, Criminal Justice |
State:
Georgia
Year:
2017
Topics:
LGBTQ+ Rights, LGBTQ+ Discrimination, Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant appealed his conviction in a criminal trial on the grounds of, among other things, ineffective assistance of counsel. Among one of the ineffective assistance claims raised was trial counsel's failure to object to the State's admission into evidence of a printout of Defendant's social media account, which was mainly comprised of sexually provocative photos of the Defendant and his homosexual lifestyle. The Supreme Court held that Defendant was not prejudiced by that admission because only six photos were shown at trial, there was substantial other evidence of Defendant's homosexual lifestyle, and other evidence that Defendant committed the crimes was overwhelming.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant appealed his conviction in a criminal trial on the grounds of, among other things, ineffective assistance of counsel. Among one of the ineffective assistance claims raised was trial counsel's failure to object to the State's admission into evidence of a printout of Defendant's social media account, which was mainly comprised of sexually provocative photos of the Defendant and his homosexual lifestyle. The Supreme Court held that Defendant was not prejudiced by that admission because only six photos were shown at trial, there was substantial other evidence of Defendant's homosexual lifestyle, and other evidence that Defendant committed the crimes was overwhelming.
Link to Opinion
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Sullivan v. Cont'l Constr. of Mont., LLC, 299 P.3d 832 (Mont. 2013)
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Montana | 2013 | Labor, Employment & Economic Justice |
State:
Montana
Year:
2013
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Plaintiff-employee was a managerial employee in his company, which was headquartered in Florida. The Plaintiff was fired for cause, with the employer alleging that he lowered employee morale and had unexplained absences at work. Plaintiff sued on the basis that the termination for cause violated the Montana Wrongful Discharge from Employment Act (WDEA). Mont. Code Ann. § 39-2-901-905. The lower court granted the employer's motion for summary judgment, and Plaintiff appealed. The Supreme Court affirmed the termination for cause and grant of summary judgment, holding that employers had broad discretion to terminate managerial employees and that summary judgment for the employer was appropriate due to the evidence on the record that the employer had lost its trust in the employee as a manager.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Plaintiff-employee was a managerial employee in his company, which was headquartered in Florida. The Plaintiff was fired for cause, with the employer alleging that he lowered employee morale and had unexplained absences at work. Plaintiff sued on the basis that the termination for cause violated the Montana Wrongful Discharge from Employment Act (WDEA). Mont. Code Ann. § 39-2-901-905. The lower court granted the employer's motion for summary judgment, and Plaintiff appealed. The Supreme Court affirmed the termination for cause and grant of summary judgment, holding that employers had broad discretion to terminate managerial employees and that summary judgment for the employer was appropriate due to the evidence on the record that the employer had lost its trust in the employee as a manager.
Link to Opinion
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Sullivan v. Lincoln Cnty. Water Dist., 542 P.3d 411 (Nev. 2024)
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Nevada | 2024 | Environment, Actions Against Government, Water Rights |
State:
Nevada
Year:
2024
Topics:
Environment, Actions Against Government, Water Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe State Engineer combined seven water basins into one "superbasin" for administration purposes based on the basins sharing a source of water and withdrawals from one basin affecting the amount of water in the other basins. The State Engineer found that the various basins originated from one large underground carbonate rock aquifer system. The district court found that the State Engineer exceeded his statutory authority to conjunctively manage surface water and groundwater and jointly administer multiple sub-basins. The Supreme Court reversed the district court's finding, holding that the interconnectedness of water requires that the State Engineer have the statutory authority to manage surface waters and groundwater and to jointly administer multiple basins based on a shared water source. The Supreme Court held that the State Engineer is required to consider the best available science in rendering decisions, which here required that the sub-basins should be administered together based on a shared source of supply.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The State Engineer combined seven water basins into one "superbasin" for administration purposes based on the basins sharing a source of water and withdrawals from one basin affecting the amount of water in the other basins. The State Engineer found that the various basins originated from one large underground carbonate rock aquifer system. The district court found that the State Engineer exceeded his statutory authority to conjunctively manage surface water and groundwater and jointly administer multiple sub-basins. The Supreme Court reversed the district court's finding, holding that the interconnectedness of water requires that the State Engineer have the statutory authority to manage surface waters and groundwater and to jointly administer multiple basins based on a shared water source. The Supreme Court held that the State Engineer is required to consider the best available science in rendering decisions, which here required that the sub-basins should be administered together based on a shared source of supply.
Link to Opinion
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Sunset Irrigation Dist. v. United States, 480 P.3d 214 (Mont. 2021)
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Montana | 2021 | Environment, Water Rights |
State:
Montana
Year:
2021
Topics:
Environment, Water Rights
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThis case involved an appeal of a water court decision and a private party objection by the Anderson family (the Andersons) to a point of diversion (the area where water has been diverted) claimed by the Mack family (the Macks). The Macks own a 160-acre section adjacent to the Andersons, who individually own several adjoining five-acre parcels, along with a forty-acre parcel. The water court denied the objections. The Supreme Court upheld the water court's decision, addressing several issues on appeal. The primary issue involved whether the prima facie validity of a water right claim includes amendments to the claim. The Supreme Court ruled prima facie status applies to claim amendments made prior to issuance of a preliminary decree. Thus, as objectors, the Andersons retained the burden of proof in objecting the Macks' amended claim, which the Andersons did not meet. The Supreme Court also held that objectors (here the adjacent landowners) have the burden of proof to rebut prima facie proof of the correct legal description of the point of diversion for the landowners' water claim.
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Justice Vote Breakdown
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Summary of Case Context & Holding
This case involved an appeal of a water court decision and a private party objection by the Anderson family (the Andersons) to a point of diversion (the area where water has been diverted) claimed by the Mack family (the Macks). The Macks own a 160-acre section adjacent to the Andersons, who individually own several adjoining five-acre parcels, along with a forty-acre parcel. The water court denied the objections. The Supreme Court upheld the water court's decision, addressing several issues on appeal. The primary issue involved whether the prima facie validity of a water right claim includes amendments to the claim. The Supreme Court ruled prima facie status applies to claim amendments made prior to issuance of a preliminary decree. Thus, as objectors, the Andersons retained the burden of proof in objecting the Macks' amended claim, which the Andersons did not meet. The Supreme Court also held that objectors (here the adjacent landowners) have the burden of proof to rebut prima facie proof of the correct legal description of the point of diversion for the landowners' water claim.
Link to Opinion
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Swicegood v. Thompson, 865 S.E.2d 775 (S.C. 2021)
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South Carolina | 2021 | LGBTQ+ Rights, LGBTQ+ Discrimination |
State:
South Carolina
Year:
2021
Topics:
LGBTQ+ Rights, LGBTQ+ Discrimination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff Swicegood and Defendant Thompson cohabited as domestic partners for over thirteen years, agreed to be married, and held themselves out publicly as a married couple. Plaintiff alleged that the couple exchanged wedding rings, co-owned property as joint tenants, shared a joint bank account, included each other as devisees in their wills, and listed each other as beneficiaries on their health insurance and retirement accounts. Furthermore, Plaintiff attested that Defendant proposed marriage to her in 2008 and the couple was declared married during a ceremony in Las Vegas in 2011. Defendant argues that the relationship was a domestic partnership and not marriage, especially because at the time same-sex marriage was not legal in Nevada. Swicegood filed an action in family court seeking an order recognizing the existence of a common-law marriage, a decree of separation support and maintenance, alimony, equitable division of marital property, and related relief. The trial court found that no common law marriage existed because Section 20-1-15 of the South Carolina Code (2014) was in place at the time of their cohabitation, which prohibited same-sex marriages, and, therefore, the couple lacked the legal right to be married. The court of appeals also found that no common law marriage existed because Section 20-1-15 prohibited same-sex marriage. The court of appeals further determined that Swicegood and Thompson lacked the requisite intent and mutual agreement to enter into a legally binding common law marriage as a matter of law because they separated before Obergefell v. Hodges, 576 U.S. 644 (2015), where the U.S. Supreme Court held that same sex couples may exercise the fundamental right to marry, was decided. The South Carolina Supreme Court ruled that Section 20-1-15 was void and that same-sex couples in South Carolina do have the fundamental right to marry because as a result of the holding in Obergefell, the restriction on same sex marriage in Section 20-1-15 was rendered void ab initio and treated as though it never existed. However, the Court affirmed the court of appeals' determination that there was no common law marriage between Swicegood and Thompson because they lacked the requisite intent and mutual agreement to enter into a common law marriage.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiff Swicegood and Defendant Thompson cohabited as domestic partners for over thirteen years, agreed to be married, and held themselves out publicly as a married couple. Plaintiff alleged that the couple exchanged wedding rings, co-owned property as joint tenants, shared a joint bank account, included each other as devisees in their wills, and listed each other as beneficiaries on their health insurance and retirement accounts. Furthermore, Plaintiff attested that Defendant proposed marriage to her in 2008 and the couple was declared married during a ceremony in Las Vegas in 2011. Defendant argues that the relationship was a domestic partnership and not marriage, especially because at the time same-sex marriage was not legal in Nevada. Swicegood filed an action in family court seeking an order recognizing the existence of a common-law marriage, a decree of separation support and maintenance, alimony, equitable division of marital property, and related relief. The trial court found that no common law marriage existed because Section 20-1-15 of the South Carolina Code (2014) was in place at the time of their cohabitation, which prohibited same-sex marriages, and, therefore, the couple lacked the legal right to be married. The court of appeals also found that no common law marriage existed because Section 20-1-15 prohibited same-sex marriage. The court of appeals further determined that Swicegood and Thompson lacked the requisite intent and mutual agreement to enter into a legally binding common law marriage as a matter of law because they separated before Obergefell v. Hodges, 576 U.S. 644 (2015), where the U.S. Supreme Court held that same sex couples may exercise the fundamental right to marry, was decided. The South Carolina Supreme Court ruled that Section 20-1-15 was void and that same-sex couples in South Carolina do have the fundamental right to marry because as a result of the holding in Obergefell, the restriction on same sex marriage in Section 20-1-15 was rendered void ab initio and treated as though it never existed. However, the Court affirmed the court of appeals' determination that there was no common law marriage between Swicegood and Thompson because they lacked the requisite intent and mutual agreement to enter into a common law marriage.
Link to Opinion
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Taghivand v. Rite Aid Corp., 768 S.E.2d 385 (S.C. 2015)
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South Carolina | 2015 | Labor, Employment & Economic Justice |
State:
South Carolina
Year:
2015
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPlaintiff Taghivand, a store manager and at-will employee, was terminated for reporting a suspected crime (shoplifting) at the store. Police officers came to the store and searched the suspect and found no shoplifted items. Taghivand brought an action against his former employer in federal court for wrongful termination, arguing that South Carolina recognizes a strong public policy in crime prevention through its statutory scheme and justice system. The district court certified the question of whether South Carolina's public policy exception to the at-will doctrine provides an at-will employee a tort cause of action for wrongful termination where the employee reasonably suspected criminal activity on the employer's premises, made a good faith report to law enforcement, and was terminated in retaliation for the report. The South Carolina Supreme Court rejected Plaintiff's arguments that (1) South Carolina statutory and common law established a clear mandate of public policy favoring the reporting of crimes; and (2) general public policy favored the reporting of crimes as inherent in the functioning of the state's justice system. The Supreme Court held that no plain statutory language supported Plaintiff's argument, and reasoned that in light of the General Assembly's choice not to include a “clear and articulable definition of policy” about reporting crimes, the Court would not read such a policy into the statutory language. Plaintiff's second argument was based on an Illinois Supreme Court decision, Palmateer v. International Harvester Co., 421 N.E.2d 876 (Ill. 1981). The South Carolina Supreme Court declined to adopt the reasoning of the Illinois decision on the grounds that South Carolina defers to the legislature in matters of public policy, and the Illinois decision finding a public policy favoring the reporting of crimes was not based on any legislative action. Accordingly, the Court held that there was no public policy exception to the at-will employment doctrine in Plaintiff's case, and as a result Plaintiff did not have a cause of action in tort for wrongful termination.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiff Taghivand, a store manager and at-will employee, was terminated for reporting a suspected crime (shoplifting) at the store. Police officers came to the store and searched the suspect and found no shoplifted items. Taghivand brought an action against his former employer in federal court for wrongful termination, arguing that South Carolina recognizes a strong public policy in crime prevention through its statutory scheme and justice system. The district court certified the question of whether South Carolina's public policy exception to the at-will doctrine provides an at-will employee a tort cause of action for wrongful termination where the employee reasonably suspected criminal activity on the employer's premises, made a good faith report to law enforcement, and was terminated in retaliation for the report. The South Carolina Supreme Court rejected Plaintiff's arguments that (1) South Carolina statutory and common law established a clear mandate of public policy favoring the reporting of crimes; and (2) general public policy favored the reporting of crimes as inherent in the functioning of the state's justice system. The Supreme Court held that no plain statutory language supported Plaintiff's argument, and reasoned that in light of the General Assembly's choice not to include a “clear and articulable definition of policy” about reporting crimes, the Court would not read such a policy into the statutory language. Plaintiff's second argument was based on an Illinois Supreme Court decision, Palmateer v. International Harvester Co., 421 N.E.2d 876 (Ill. 1981). The South Carolina Supreme Court declined to adopt the reasoning of the Illinois decision on the grounds that South Carolina defers to the legislature in matters of public policy, and the Illinois decision finding a public policy favoring the reporting of crimes was not based on any legislative action. Accordingly, the Court held that there was no public policy exception to the at-will employment doctrine in Plaintiff's case, and as a result Plaintiff did not have a cause of action in tort for wrongful termination.
Link to Opinion
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Tallman v. Eighth Jud. Dist. Ct., 359 P.3d 113 (Nev. 2015)
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Nevada | 2015 | Labor, Employment & Economic Justice |
State:
Nevada
Year:
2015
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPetitioners sought to vacate the district court's orders compelling arbitration of their claims against their former employer, CPS Security (USA), Inc. (CPS). Petitioners signed the same long-form arbitration agreement, which included a clause waiving the right to initiate or participate in class actions. Petitioners argued that the Supreme Court should invalidate the agreement, first, because it was not countersigned by CPS and, second, because its class action waiver violated state and federal law. The Supreme Court held that the employer's failure to sign the agreement containing the class action waiver did not make the waiver unenforceable because Nev. Rev. Stat. § 38.219(1) (providing that an agreement to arbitration is valid and irrevocable with certain exceptions) did not require a signature. The Supreme Court also held that case law invalidating class arbitration waivers was federally preempted under the Supremacy Clause of the U.S. Constitution as inconsistent with the Federal Arbitration Act, 9 U.S.C.S. § 2 (a contract evidencing a transaction involving commerce to settle by arbitration a controversy is valid and irrevocable with certain exceptions). Further, the rights secured to employees under Nev. Rev. Stat. §§ 608.018 (governing compensation for overtime), 608.250 (governing minimum wages) and Nev. Const. art. XV, § 16 (governing minimum wages) were of great importance; and collective bargaining rights under 29 U.S.C.S. §§ 157, 158(a)(1) (granting employees the right to unionize) did not override the Federal Arbitration Act.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Petitioners sought to vacate the district court's orders compelling arbitration of their claims against their former employer, CPS Security (USA), Inc. (CPS). Petitioners signed the same long-form arbitration agreement, which included a clause waiving the right to initiate or participate in class actions. Petitioners argued that the Supreme Court should invalidate the agreement, first, because it was not countersigned by CPS and, second, because its class action waiver violated state and federal law. The Supreme Court held that the employer's failure to sign the agreement containing the class action waiver did not make the waiver unenforceable because Nev. Rev. Stat. § 38.219(1) (providing that an agreement to arbitration is valid and irrevocable with certain exceptions) did not require a signature. The Supreme Court also held that case law invalidating class arbitration waivers was federally preempted under the Supremacy Clause of the U.S. Constitution as inconsistent with the Federal Arbitration Act, 9 U.S.C.S. § 2 (a contract evidencing a transaction involving commerce to settle by arbitration a controversy is valid and irrevocable with certain exceptions). Further, the rights secured to employees under Nev. Rev. Stat. §§ 608.018 (governing compensation for overtime), 608.250 (governing minimum wages) and Nev. Const. art. XV, § 16 (governing minimum wages) were of great importance; and collective bargaining rights under 29 U.S.C.S. §§ 157, 158(a)(1) (granting employees the right to unionize) did not override the Federal Arbitration Act.
Link to Opinion
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Taxpayers for Mich. Const. Gov't v. State, 972 N.W.2d 738 (Mich. 2021)
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Michigan | 2021 | Education, Access to Education/Funding |
State:
Michigan
Year:
2021
Topics:
Education, Access to Education/Funding
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA taxpayer organization sued the Michigan Department of Technology, Management, and Budget arguing that (1) the state was improperly counting payments to school districts as spending for local governments in violation of the state constitution; and (2) the state was improperly counting payments to "public school academies" as part of spending for local governments in violation of the state constitution. The Supreme Court held that payments to school districts were appropriately counted as local government spending but that public school academies were not appropriately counted as local government spending because they are not school districts or political subdivisions of the state as voters would have understood the terms at the time the state constitution was amended. In 1978, Michigan voters approved an amendment, known as the Headlee Amendment, which established the proportion of total state spending that could be paid to local government units. On the first issue, the state introduced a funding scheme whereby money was collected and disbursed by the state to school districts. The Supreme Court reasoned that, because the Headlee Amendment expressly provides that local government includes school districts, including money collected by the state and disbursed to school districts was local government funding consistent with the Headlee Amendment. On the second issue, the Plaintiffs argued that money paid to public school academies should not count as local government spending because they are not local government as that term was understood at the time the Headlee Amendment was approved. A public school academy is a state-supported public school operating under a charter contract issued by a public authorizing body. The Supreme Court agreed with the Plaintiffs, finding that, public school academies are not equivalent to school districts because of key differences including that the academies are nonprofit organizations, are not defined to a local geographic area, are funded solely by the state and cannot levy taxes like a school district, and are viewed as an alternative to traditional public schools. Further, the Supreme Court found that public school academies could not otherwise be considered local government under the Headlee Amendment because they are not a "geographically limited unit of government formed to exercise political power and that is beholden to a local electorate."
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Justice Vote Breakdown
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Summary of Case Context & Holding
A taxpayer organization sued the Michigan Department of Technology, Management, and Budget arguing that (1) the state was improperly counting payments to school districts as spending for local governments in violation of the state constitution; and (2) the state was improperly counting payments to "public school academies" as part of spending for local governments in violation of the state constitution. The Supreme Court held that payments to school districts were appropriately counted as local government spending but that public school academies were not appropriately counted as local government spending because they are not school districts or political subdivisions of the state as voters would have understood the terms at the time the state constitution was amended. In 1978, Michigan voters approved an amendment, known as the Headlee Amendment, which established the proportion of total state spending that could be paid to local government units. On the first issue, the state introduced a funding scheme whereby money was collected and disbursed by the state to school districts. The Supreme Court reasoned that, because the Headlee Amendment expressly provides that local government includes school districts, including money collected by the state and disbursed to school districts was local government funding consistent with the Headlee Amendment. On the second issue, the Plaintiffs argued that money paid to public school academies should not count as local government spending because they are not local government as that term was understood at the time the Headlee Amendment was approved. A public school academy is a state-supported public school operating under a charter contract issued by a public authorizing body. The Supreme Court agreed with the Plaintiffs, finding that, public school academies are not equivalent to school districts because of key differences including that the academies are nonprofit organizations, are not defined to a local geographic area, are funded solely by the state and cannot levy taxes like a school district, and are viewed as an alternative to traditional public schools. Further, the Supreme Court found that public school academies could not otherwise be considered local government under the Headlee Amendment because they are not a "geographically limited unit of government formed to exercise political power and that is beholden to a local electorate."
Link to Opinion
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Taylor v. State, 810 S.E.2d 862 (S.C. 2018)
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South Carolina | 2018 | Immigration, Deportation |
State:
South Carolina
Year:
2018
Topics:
Immigration, Deportation
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPetitioner pled guilty to possession of marijuana after his attorney assured him he would not be deported as a result of his plea. Petitioner was then deported and applied for post-conviction relief (PCR), arguing ineffective assistance of counsel under Padilla v. Kentucky, 559 U.S. 356, 366 (2010), which held that counsel must advise clients of the possible immigration consequences of a guilty plea. The PCR court denied relief on the grounds that Petitioner's counsel adequately complied with Padilla and that Petitioner had not met his burden of proof. The Supreme Court reversed, citing evidence that the attorney had not ever read Padilla. The Court held that a broad statement that a guilty plea "could have" immigration consequences is not enough to satisfy Padilla. Thus, the Court reversed the PCR court's judgment.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Petitioner pled guilty to possession of marijuana after his attorney assured him he would not be deported as a result of his plea. Petitioner was then deported and applied for post-conviction relief (PCR), arguing ineffective assistance of counsel under Padilla v. Kentucky, 559 U.S. 356, 366 (2010), which held that counsel must advise clients of the possible immigration consequences of a guilty plea. The PCR court denied relief on the grounds that Petitioner's counsel adequately complied with Padilla and that Petitioner had not met his burden of proof. The Supreme Court reversed, citing evidence that the attorney had not ever read Padilla. The Court held that a broad statement that a guilty plea "could have" immigration consequences is not enough to satisfy Padilla. Thus, the Court reversed the PCR court's judgment.
Link to Opinion
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Teague v. Schimel, 896 N.W.2d 286 (Wis. 2017)
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Wisconsin | 2017 | Criminal Justice, Police Misconduct and Bias |
State:
Wisconsin
Year:
2017
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Plaintiff 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.
Link to Opinion
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Teigen v. Wis. Elections Comm'n, 976 N.W.2d 519 (Wis. 2022)
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Wisconsin | 2022 | Democracy & Voting, Voting Rights |
State:
Wisconsin
Year:
2022
Topics:
Democracy & Voting, Voting Rights
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Two 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.
Link to Opinion
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Templeton Props. v. Town of Boone, 772 S.E.2d 239 (N.C. 2015)
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North Carolina | 2015 | Health Care, Health Care Access/Funding |
State:
North Carolina
Year:
2015
Topics:
Health Care, Health Care Access/Funding
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Templeton 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.
Link to Opinion
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Ter Beek v. City of Wyoming, 846 N.W.2d 531 (Mich. 2014)
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Michigan | 2014 | Criminal Justice |
State:
Michigan
Year:
2014
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A 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.
Link to Opinion
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Ter Beek v. City of Wyoming, 846 N.W.2d 531 (Mich. 2014)
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Michigan | 2014 | Health Care, Public Health |
State:
Michigan
Year:
2014
Topics:
Health Care, Public Health
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A 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.
Link to Opinion
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Terrell v. Torres, 456 P.3d 13 (Ariz. 2020), as amended (Feb. 21, 2020)
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Arizona | 2020 | Health Care, Reproductive Rights/Abortion |
State:
Arizona
Year:
2020
Topics:
Health Care, Reproductive Rights/Abortion
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Due 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.
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Teton Co-Op Canal Co. v. Teton Coop Reservoir Co., 365 P.3d 442 (Mont. 2015)
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Montana | 2015 | Environment, Water Rights |
State:
Montana
Year:
2015
Topics:
Environment, Water Rights
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Teton 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.
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Teton Co-Op Canal Co. v. Teton Coop Reservoir Co., 412 P.3d 1 (Mont. 2018)
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Montana | 2018 | Environment, Water Rights |
State:
Montana
Year:
2018
Topics:
Environment, Water Rights
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The 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.
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Teva Parenteral Meds., Inc. v. Eighth Jud. Dist. Ct., 481 P.3d 1232 (Nev. 2021)
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Nevada | 2021 | Health Care, Public Health |
State:
Nevada
Year:
2021
Topics:
Health Care, Public Health
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The 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.
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Tex. Bd. of Chiropractic Exam'rs v. Tex. Med. Ass'n, 616 S.W.3d 558 (Tex. 2021)
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Texas | 2021 | Health Care, Public Health, Health Care Access/Funding |
State:
Texas
Year:
2021
Topics:
Health Care, Public Health, Health Care Access/Funding
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The 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.
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