State Supreme Court Data Tracker

Summary of Case Context & HoldingA jury found 17-year old Appellant guilty of malice murder in connection with the shooting death of the Sheriff's Deputy. Appellant was sentenced to life without parole plus an additional 70 years of imprisonment. He appealed arguing his sentence constituted cruel and unusual punishment under both the U.S. and Georgia Constitutions and that his trial counsel provided ineffective assistance. The Supreme Court affirmed, finding that the U.S. Supreme Court's decisions in Roper, Graham, and Miller do not prevent a sentencing court from sentencing juveniles in a homicide case to life imprisonment without the possibility of parole. See Roper v. Simmons, 543 U.S. 551 (2005); Graham v. Florida, 560 U.S. 48 (2010); Miller v. Alabama, 567 U.S. 460 (2012). Roper, Graham, and Miller are all predicated on the fact that juveniles, who are biologically and emotionally immature, are less culpable than adults for their actions. The Supreme Court also found it was not ineffective assistance of counsel to fail to object to the testimony of a former juvenile judge who had presided over a number of defendants' juvenile cases. The dissenting opinion stated that while federal law allows life without parole sentences to be exacted on juvenile offenders who commit homicide as a matter of judicial discretion, federal law does not prohibit the state from disallowing such sentences for juvenile offenders as a matter of state constitutional law. The dissenting opinion took the position that making the Appellant a prisoner well into his 80s constituted cruel and unusual punishment. Additionally, the dissenting opinion contended that it is not permitted to allow former prosecutors, former defense attorneys, and former judges involved in the prior case to testify about a defendant's character for sentencing purposes or otherwise, so failure to object was ineffective assistance of trial counsel.

Summary of Case Context & HoldingGovernor Bullock and the Director of the Department of Fish, Wildlife, and Parks (FWP), in their official capacities, filed petition for declaratory relief to determine whether the law (§ 87-1-209(1), Montana Code Annotated (MCA)) required FWP to bring conservation easement transactions of more than 100 acres or $100,000 in value before the Board of Land Commissioners (the Board) for final approval. The Supreme Court determined the statute requiring Board approval for "land acquisition" involving more than 100 acres, or $100,000 in value, did not apply to conservation easement acquisition. In September 2017 Bullock directed FWP to finalize an easement without the Board's approval, reasoning that "land acquisition" under this part of the MCA did not include conservation easement acquisition. The Supreme Court determined that "land acquisition" should be given its plain and ordinary meaning. In particular, gaining actual possession over land and not a lesser, non-possessory interest in land, which is what easements are. With conservation easements, the private landowners continue to own, pay taxes on and maintain their rights to transfer the property.

Summary of Case Context & HoldingPlaintiff was let go by her employer (a mental health center) for implementing a program that the employer deemed to be harmful to clinic patients. The employer alleged that this was a firing for cause. Plaintiff instead alleged that she was not fired for cause, as she was a managerial employee with a higher level of discretion. The Supreme Court held for the employer, finding that under the Montana Wrongful Discharge from Employment Act, an employer's loss of confidence and trust in a managerial employee's ability is a legitimate business reason sufficient to legally justify discharge for cause. Mont. Code Ann. § 39-2-904.

Summary of Case Context & HoldingPlaintiffs Duka and Koski are Christians and owners of Brush & Nib Studio, an art studio and public accommodation that creates custom artwork for weddings, events, and special occasions. The Defendant, the City of Phoenix, adopted an Ordinance that prohibits public accommodations from discriminating against persons based on their status in a "protected group" which includes a person's sexual orientation. Here, Plaintiffs refused to create custom-made wedding products for same-sex weddings and same-sex couples. The Plaintiffs were not cited as violating the Ordinance, but filed suit to enjoin the City from enforcing the Ordinance against them and to obtain a declaration that the Ordinance violates their right to free speech under the Arizona Constitution and their rights to free exercise of religion under the Arizona Free Exercise of Religion Act (FERA). In response, the City conceded that the Ordinance does not require the Plaintiffs to express any messages condoning or celebrating same-sex marriage (for example, the Ordinance does not require the Plaintiffs to create custom invitations containing statements like "support gay marriage" that would be recognized by a third-party observer as condoning same-sex marriage). The City argued instead that the Ordinance regulates conduct, not speech, and that by refusing to create or sell invitations for use in same-sex weddings, the Plaintiffs were engaging in discriminatory conduct prohibited by the Ordinance. Both parties moved for summary judgment. The trial court denied Plaintiffs' motion and granted the Defendant's motion concluding that the Ordinance did not violate Plaintiffs' right to free speech or free exercise of religion. On appeal, the court of appeals affirmed the lower court's decision finding that the Ordinance did not violate Plaintiffs' freedom of speech or substantially burden the free exercise of religion under FERA. On a further appeal, the Arizona Supreme Court reversed the holding of the lower courts. First, the Supreme Court held that the Ordinance as applied to Plaintiffs' custom wedding products unconstitutionally compelled speech in violation of the Arizona Constitution's free speech clause. It reasoned that the Plaintiffs' business of creating custom invitations to celebrate marriage is pure protected speech because the act of creating custom products produces a message or meaning by the creator, even if it is a business activity. Furthermore, the Court reasoned that Plaintiffs would not be discriminating against same-sex couples based on their sexual orientation or identity, but simply expressing free speech in their creations. To hold otherwise, the Supreme Court noted, would unconstitutionally compel Plaintiffs to produce designs and art that they do not desire to create. Second, the Supreme Court held that the Ordinance substantially burdened Plaintiffs' free exercise of religion. In support of this holding, the Supreme Court reasoned that the Ordinance places a substantial burden on Plaintiffs' right to freely exercise their prescribed religion because it would coerce Plaintiffs to abandon their religious beliefs and celebrate same-sex couples in their business or else violate the Ordinance and face criminal and civil sanctions. The Court granted Plaintiffs a blanket exemption from the Ordinance for their business operations of making custom wedding items and allowed them to post a statement declaring that they do not create wedding items for same-sex couples.

Summary of Case Context & HoldingPatient brought a medical malpractice action against a hospital, alleging deviations from standards of medical care in the diagnosis, care, and treatment of her pelvic abscess due to a perforated appendix. The superior court determined that a report containing the hospital's self-critical analysis of patient's care included information on a Serious Preventable Adverse Event (SPAE) and ordered hospital to release to patient a redacted version of the report. The hospital sought leave to appeal. The Superior Court, Appellate Division, reversed. Patient sought leave to appeal. The Supreme Court affirmed in part, reversed in part, and remanded, holding that: (1) although the trial court correctly determined that it could review in camera the facts underlying what the hospital concluded was not a SPAE, the trial court exceeded its authority in declaring that a SPAE had occurred; (2) the finding that an event is not reportable as a SPAE does not abrogate the self-critical-analysis privilege under the Patient Safety Act (PSA), which unconditionally protects the process of self-critical analysis, the analysis' results, and the resulting reports developed by a facility in its compliance with the PSA; but (3) patient was entitled, as a response to her discovery request, to have hospital provide a narrative to steer her to information contained in the approximately 4,500 pages of medical records that would lead her to the discrete yet interconnected notations of an apparent adverse incident, even though the hospital's self-critical analysis of a possible SPAE that happened to patient was privileged under the PSA; patient was unquestionably entitled to the raw data contained in her patient records.

Summary of Case Context & HoldingDefendant was pulled over and arrested operating a motorized watercraft while under the influence. Once arrested and brought to the station, a police officer informed him via admonition of his obligation under Arizona law to submit to under the influence testing (either blood, urine, or other bodily substance testing). Defendant did not ask any questions about the test. The officer performed a blood test that revealed Defendant had a BAC of .199. Defendant moved to suppress the evidence of the BAC test on the grounds that he did not express consent to the BAC test, resulting in a Fourth Amendment violation. The superior court denied Defendant's motion to suppress, reasoning that his consent was voluntary because the admonition provided a choice of whether to submit to testing and Defendant was convicted of operating a motorized watercraft while under the influence of alcohol or drugs (OUI). Holding that the Defendant's Fourth Amendment rights were violated, the Supreme Court analogized the facts in the present case to State v. Valenzuela, 371 P.3d 627 (Ariz. 2016), where the defendant was given an identical admonition. The Court also rejected the government's argument that the discovery of his BAC was inevitable. The government cannot benefit from the presumption that they "would have done it right had they not done it wrong," absent evidence to the contrary. Here, the police would not have inevitably obtained Defendant's blood sample without a lawful search warrant. Finally, Defendant challenged an Arizona statute that gave police officers the right to the results of a BAC test once it is taken. The Arizona Supreme Court ruled that since Defendant was not injured by the statute, he did not have standing to sue. The case was remanded back to the lower court to determine if the admission of BAC evidence was harmless error to convict Defendant of an OUI.

Summary of Case Context & HoldingA jury found Defendant guilty of the murders of his ex-girlfriend and her daughter. The jury declined in its guilt/innocence phase verdict to find Defendant “mentally retarded” or “mentally ill” and found multiple statutory aggravating circumstances and sentenced Defendant to death for each of the two murders. Upon review of the evidence under O.C.G.A. § 17-10-35(c)(3), including the evidence regarding Defendant's alleged intellectual disability and mental illness, the Supreme Court affirmed the convictions and sentences. The Supreme Court reasoned that the terms “mentally ill” and “insane” as defined in Georgia law overlap significantly in meaning. Every person who fits one of the two legal definitions of “insanity” would also qualify as “mentally ill” under the law. But the reverse is not true, as not every person who is “mentally ill” can meet one of the two narrower definitions of “insanity.” The Court rejected Defendant's argument that persons with “mental illness” constitute a category of persons that, like intellectual disability, must be subject to a categorical exemption from death sentences. Upon our review of the entire record, the Court concluded that the sentence of death in this case was not imposed under the influence of passion, prejudice, or any other arbitrary factor and were not disproportionate punishments within the meaning of Georgia law.

Summary of Case Context & HoldingA jury convicted Defendant of felony murder and criminal attempt to commit armed robbery and recommended a death sentence for the murder. Defendant filed a motion for a new trial, which was denied and then appealed. Defendant argued that no evidence was presented that he took anything during the incident and the evidence was insufficient to authorize the jury to conclude that the State had proven the existence of a statutory aggravating circumstance. The Supreme Court concluded that the evidence supported the jury's finding of the alleged statutory aggravating factor, meaning that the murder was committed while Defendant was engaged in the capital felony of armed robbery. The Supreme Court explained that the statute does not require that the other felony be completed but requires that the State prove beyond a reasonable doubt the existence of the statutory aggravating circumstance for purposes of sentencing, i.e., that the murder was committed “while the offender was engaged in the commission of” the other felony, which makes the Defendant eligible for the death penalty, even though an element of the armed robbery, i.e., a taking, was admittedly absent. Georgia's felony murder statute authorizes the imposition of the death penalty if a person causes the death of another during the commission of a felony “irrespective of malice.” Additionally, the trial court did not err in refusing to exclude three prospective jurors because they would have automatically imposed the death penalty, as one of the jurors was excused before jury selection began and the other two, while indicating a leaning toward the death penalty, stated that they would listen to the evidence and fairly consider both sentencing options.

Summary of Case Context & HoldingBrito was convicted of assault with a deadly weapon and resisting a public officer with the use of a deadly weapon. On appeal, Brito argued that the entry into his home by the officer violated the Fourth Amendment, and that as a result the evidence forming the basis for his conviction should have been suppressed. The Court held that the trial court correctly denied Brito’s motion to suppress. It reasoned that even if the officer violated Brito’s Fourth Amendment rights, his intervening act of assaulting and resisting the arresting officer sufficiently “purge[d] the primary taint” of any prior unconstitutional conduct and permitted admission of evidence of his criminal conduct. Brito also argued that the officer had used excessive force, which justified Brito’s resistance, and therefore, warranted suppression of the evidence collected in Brito’s home. The Court rejected this argument, reasoning that Brito had offered no authority holding that excessive force per se warrants suppression.

Summary of Case Context & HoldingFive candidates for Broward County Commissioner for District 2, all Democrats, qualified to have their names printed on the ballot for the August 2014 primary election. No Republican or Independent candidates filed qualifying papers. The Defendant, a sixth Democrat candidate, filed qualifying paperwork to run as a write-in candidate. Plaintiff, a resident voter in District 2, filed a complaint alleging that the write-in candidate for the county commissioner's office did not meet the statutory residency requirements because he did not physically live within the district's boundaries. The Defendant conceded that he did not live in the district when the papers were filed but contended that the statute requiring residency in the district was unconstitutional and violated the equal protection clause. The Supreme Court of Florida held that the statute requiring write-in candidates to reside within the district at the time of qualification was unconstitutional because statutes may not impose qualification requirements for public office over and above those outlined in the Florida Constitution. According to the Florida Constitution, the candidate must only live within the district at the time of the election, not at the time of registration. The Court additionally found that the primary was to be open only to voters of the political party with which candidates were affiliated, even though one candidate was a write-in candidate.

Summary of Case Context & HoldingPlaintiff, borrower, sought declaration that Defendant, lender and servicer of borrower’s mortgage loan, was barred from foreclosing on borrower’s property because the statute of limitations had run. Specifically, Plaintiff argued that that the six-year statute of limitations, which it said ran from the date that the borrower’s former lender recorded its notice of trustee’s sale of the property and accelerated the debt, had expired. The Supreme Court vacated the court of appeals' decision and reversed the trial court decision, holding that because the applicable Arizona statute allows a borrower, after a notice of trustee’s sale is recorded, to reinstate the mortgage by paying the amount due, the recording of the notice of trustee’s sale does not accelerate the debt. As a result, the Supreme Court found that the statute of limitations to foreclose on borrower's property had not run.

Summary of Case Context & HoldingA Rockford Firefighter was unable to perform his duties due to heart disease caused by his service as a firefighter. The city paid for his health insurance premiums as required by state ordinance. The firefighter sought continuing health benefits for his family that are designated when an employee is catastrophically injured in the line of duty. The city determined that the firefighter did not qualify for this coverage because he did not suffer a catastrophic injury. The Supreme Court held that the firefighter’s heart disease was a catastrophic injury, reasoning that the illness was contracted while performing in the line of duty, and it prevented him from performing his duties, thus entitling him to continuing health benefits.

Summary of Case Context & HoldingBreland purchased land to build a housing subdivision. The subdivision he planned to construct required filling approximately 10.5 acres of wetlands in the City of Fairhope (the City). Breland and Breland Corporation (collectively, Breland) sued the City, seeking (1) a temporary restraining order and a preliminary injunction against the City's attempts to stop them from filling the wetlands; (2) a judgment declaring that Breland had obtained a vested right to fill the wetlands; (3) a judgment declaring that the City's ordinances are preempted by state law; (4) a judgment declaring that the City's ordinances are improper de facto zoning regulations; (5) a verdict of negligence against the City for allegedly mishandling Breland's 2008 permit application; and (6) expungement of the 2011 criminal citation issued against Breland. The trial court entered summary judgment in the City's favor, holding that the statute of limitations barred most of Breland’s claims. Breland appealed to the Alabama Supreme Court, which reversed and remanded, holding that “each time Fairhope enforced its ordinances to stop Breland from filling activity on his property Fairhope committed a new act that serves as a basis for a new claim.” Breland v. City of Fairhope, 229 So. 3d 1078, 1090 (Ala. 2016). On remand, the trial court held that Breland had not obtained a vested right to fill the wetlands, that state law did not preempt Fairhope's ordinances, and that Fairhope's ordinances were not improper zoning ordinances. Therefore, it held that the Breland’s negligence and expungement claims were moot. The Breland parties again appealed to the Alabama Supreme Court, which affirmed each of the trial court’s holdings. Specifically, the Court held that Breland lacked a vested right to fill wetlands on property when it first obtained a land-disturbance permit, state legislation did not preempt the field of wetlands regulation, and the city ordinances at issue were not de facto zoning regulations. Accordingly, Breland’s request for expungement was moot.

Summary of Case Context & HoldingAn electric company that had installed heat recovery steam generators at its two power plants challenged the determination of the Texas Commission on Environmental Quality (TCEQ) regarding the electric company's entitlement to an ad valorem tax exemption for “pollution control property." At issue in the case was whether Texas Tax Code Section 11.31 gives the TCEQ discretion to deny an ad valorem tax exemption for heat recovery steam generators (HRSGs), devices the Legislature has deemed “pollution control property.” The court of appeals held that the TCEQ has discretion and the Texas Supreme Court reversed and remanded the case to the TCEQ for further proceedings. The Texas Supreme Court held that the TCEQ has no discretion to issue a negative use determination for compliant HRSGs. As such, the plain meaning of Texas Tax Code Section 11.31 is that HRSGs, qualify, in part, as “pollution control property” and the TCEQ may not determine otherwise, if the HSRG otherwise complies with the statute’s requirements.

Summary of Case Context & HoldingIn 1994, Defendant, who was 17 at the time of committing the crimes, was indicted for malice murder, felony murder, armed robbery, and four other crimes, all stemming from theft of a vehicle that defendant used to drive to a convenience store where he shot and killed a woman. In 1996, the State filed a notice of intent to seek the death penalty for malice murder. In 1999, Defendant, who was represented by counsel, entered into a negotiated plea agreement with the State that provided that the State waived the death penalty and agreed to recommend that the trial court sentence defendant to life without parole. The plea agreement also expressly provided that Defendant waived all rights to appeal and waived and agreed not to seek any post-conviction relief from the sentence imposed pursuant to the plea agreement. Defendant argued that his plea contract was involuntary because he agreed to the plea contract to avoid the possibility of receiving the death penalty, a sentence for which he was eligible in 1999, but for which he was determined to be ineligible after the U.S. Supreme Court's 2005 opinion in Roper v. Simmons, 543 U.S. 551 (2005) (invalidating the death penalty for juvenile offenders). The Supreme Court noted that the U.S. Supreme Court and other courts have held that where a defendant is eligible for the death penalty under existing law and enters into a plea agreement to avoid the possibility of receiving a sentence of death, his guilty plea is not rendered involuntary by subsequent legal developments that make him ineligible for the death penalty. The Supreme Court held that Defendant juvenile's plea agreement precluded him from appealing the trial court's orders as his appeal waiver was valid because it was knowingly, voluntarily, and intelligently made as he acknowledged that, after consultation and advice from his attorneys, he knowingly, intelligently and voluntarily stipulated and agreed to the appeal waiver; he acknowledged in the written agreement that he was entering into the contract with full awareness of what he was doing; and the plea hearing transcript showed that both the district attorney and the trial court asked defendant if he understood that he was waiving his rights of appeal, and he said that he understood. The Supreme Court concluded that dismissal of Defendant's appeal based on his waiver of his right to appellate review in his plea contract was proper.

Summary of Case Context & HoldingAppellant and Co-Defendant were jointly indicted for malice murder and other crimes in connection with the shooting deaths of two victims during a drug transaction. The State offered evidence of a prior similar crime in Ohio, which the trial court admitted for the limited purpose of proving identity, intent, and motive. Appellant appealed, contending that the trial court erred by admitting evidence of a prior murder. The Supreme Court found that there was ample corroboration of the accomplice's testimony. The evidence of a prior murder by Defendant was relevant to motive because it demonstrated Defendant's willingness to use violence when cheated in a drug deal. The Supreme Court held that the trial court did not abuse its discretion in determining that the probative value of evidence of the Ohio crime, which was factually similar to the Georgia crimes and which was needed by the State to help establish that Appellant and not the accomplice was the shooter, was not substantially outweighed by its prejudicial effect.

Summary of Case Context & HoldingDefendant Julius Bradford appealed his death penalty conviction because the district court dismissed members of the jury pool before resolving Bradford's objection that the State used its peremptory challenge to dismiss a potential juror on the basis of race, ethnicity, or sex under the U.S. Supreme Court decision in Batson v. Kentucky, 476 U.S. 79 (1986). The State did not dispute that Bradford attempted to make two Batson challenges but was not permitted to be heard until after the challenged prospective jurors were dismissed. Under the Court's precedent in Brass v. State, 291 P.3d 145, 149 (Nev. 2012), this premature dismissal resulted in structural error. Thus, the Court reversed Bradford's conviction.

Summary of Case Context & HoldingBraden's Folly, LLC (Braden) owned two small, contiguous, developed coastal properties on the northeast end of Folly Beach, South Carolina. The City of Folly Beach amended an ordinance to require certain contiguous properties under common ownership—like those owned by Braden—to be merged into a single, larger property. The ordinance did not impact the existing uses of Braden's contiguous lots. Nevertheless, Braden challenged the merger ordinance, claiming it had planned to sell one of the developed properties separate from the other, and that the merger ordinance interfered with its investment-backed expectation under the United States Supreme Court's Penn Central Test, which determines when a taking has occurred and therefore whether a landowner should receive reasonable compensation. See generally Penn Cent. Transp. Co. v. City of New York, 438 U.S. 104, 124 (1978) (stating in regulatory takings cases, courts must examine (1) the economic impact of the regulation on the claimant; (2) the extent to which the regulation has interfered with distinct investment-backed expectations; and (3) the character of the governmental action). The circuit court held a property owner's reasonable investment-backed expectations are defined at the time the investment is made, and Braden intended to sell one of the lots when it constructed the houses in 2006 and 2007. Likewise, the circuit court found the merger ordinance had an impermissibly detrimental economic impact on the value of the properties, citing an alleged $508,000 market value loss calculated by an appraiser hired by Braden during litigation. Lastly, the circuit court found the character of the merger ordinance was akin to a classic taking, explaining that, while merging undeveloped or partially developed properties may not amount to a regulatory taking, forcing two single-family residential houses to be merged into one property amounts to a taking. The City of Folly Beach directly appealed to the South Carolina Supreme Court because the case involves a constitutional challenge to the merger ordinance. After applying the Penn Central test, the South Carolina Supreme Court determined that two factors strongly favor Folly Beach: the economic impact of the merger ordinance and the character of the government action. The Court found the third factor—whether the merger ordinance interfered with Braden's Folly's reasonable, investment-backed expectations—to be neutral. Regarding the first factor, the Court noted that the 23% economic impact resulting from the merger ordinance is significantly less than reductions in value previously deemed constitutional by the Supreme Court. Moreover, the merger ordinance imposed no physical restrictions on the lots, and Braden's retained the ability to rent out the houses on the lots separately, continuing to generate revenue. As for the second factor, the Court acknowledged some evidence suggesting that Braden's had an investment-backed expectation in selling Lot B separately. However, several objective indicators refuted this expectation. Specifically, the merger doctrine did not interfere with Braden's "primary expectation" of using the lots as family vacation and rental properties. Additionally, Braden's delayed attempting to sell the lots after redevelopment, and the size, shape, and orientation of the lots suggested that selling Lot B independently was an unreasonable expectation. Lastly, on the third factor, the Court recognized competing evidence regarding whether the merger ordinance interfered with Braden's reasonable, investment-backed expectations. The Court found that although Braden's faced a slight burden due to the merger ordinance, it stood to benefit significantly from the continued availability of federal funding for beach renourishment, which depended on similar restrictions. Consequently, the Court concluded that the Penn Central balancing test overall weighs in favor of Folly Beach, and the merger ordinance does not constitute an unconstitutional taking of Braden's lots.

Summary of Case Context & HoldingPetitioner Marion Bowman sought post-conviction relief (PCR) from his sentence of death for the murder of Kandee Martin in February 2001. The essence of Petitioner's claim was that trial counsel was deficient in failing to object to the State's cross-examination of their prison-adaptability expert, James Aiken. The PCR court denied Petitioner's application. The South Carolina Supreme Court affirmed, finding evidence supported the PCR court’s conclusion that defense counsel was not deficient, and Petitioner was not prejudiced, by counsel’s failure to object to the State’s cross-examination of the prison-adaptability expert. This decision, although risky by trial Counsel, was deemed reasonable given the legal landscape at the time of the trial, including recent developments requiring juries to understand the true nature of a life sentence. While the defense's approach opened the door to the prosecution’s proportional response as it was confined to the topics to which counsel had opened the door, the court found counsel’s actions were neither deficient nor prejudicial under Strickland v. Washington, 466 U.S. 668 (1984) (establishing a two-pronged test for ineffective assistance of counsel: (1) whether counsel’s performance was deficient; and (2) whether the deficiency prejudiced the defense). The Court clarified that even where statutory violations in capital sentencing procedures occur, a harmless error analysis may apply, particularly in the context of PCR, where prejudice must be demonstrated. Because of the overwhelming evidence of guilt and aggravating factors, the Court concluded that the limited questioning on prison conditions had no reasonable probability of altering the outcome, affirming the death sentence.

Summary of Case Context & HoldingPlaintiff sued Defendant Ciripompa, a tenured high school teacher, who allegedly had been using his school-issued laptop and iPad to send nude photographs of himself and to engage in inappropriate conversations with others. Further allegations arose accusing Defendant of inappropriate behavior towards other colleagues, often in the presence of students. The school board sought to terminate Defendant based, in relevant part, upon the evidence of inappropriate behavior. Because Defendant was a tenured teacher, the request for dismissal was submitted to an arbitrator. The arbitrator found that the school board's allegations of inappropriate behavior constituted a claim for sexual harassment requiring a showing that a reasonable woman would consider the behaviors of the aggressor to create a hostile work environment. The arbitrator found that the teacher's conduct did not meet this standard. The school board appealed. The Supreme Court ruled that an arbitrator’s decision shall be final and binding upon the parties but remains subject to judicial review and enforcement, but also held that the arbitrator exceeded his authority by converting the charge of unbecoming conduct into one of sexual harassment, and tasking the board with substantiating the charge of sexual harassment.

Summary of Case Context & HoldingUnder Florida Statute Section 776.032, known as Florida's Stand Your Ground law, a person is generally "immune from criminal prosecution and civil action" when that person justifiably uses or threatens to use force under certain circumstances. By way of background, in Bretherick v. State, 170 So. 3d 766 (Fla. 2015), Supreme Court held that "the defendant bears the burden of proof, by a preponderance of the evidence, to demonstrate entitlement to Stand Your Ground immunity at the pretrial evidentiary hearing." In apparent response to Bretherick, the Legislature amended Section 776.032, effective June 9, 2017, to provide that a defendant is no longer required to prove that he or she acted in self-defense by a preponderance of the evidence at an immunity hearing. Rather, a defendant need only make a prima facie showing at that point. To defeat the claim of immunity, the State must prove by clear and convincing evidence that the defendant did not act in self-defense. Roy Boston was charged with aggravated battery with a deadly weapon, arising from a 2016 altercation in which he struck his former employer with a hammer. Boston filed a motion to dismiss, arguing that he was entitled to immunity under Section 776.032. The parties agreed that the trial court would hear Boston's immunity motion during trial. Before commencing the trial and immunity hearing on November 8, 2017, the trial court heard argument regarding whether to apply the 2017 burden-shifting amendment to Section 776.032 retroactively in Boston's case. The trial court ruled that the preamendment standard set forth in Bretherick would apply, and Boston would bear the burden of proof and be required to establish his entitlement to immunity by a preponderance of the evidence. After the immunity hearing was held during the trial, the trial court rejected Boston's claim of immunity. The jury also rejected Boston's self-defense claim, and ultimately convicted him of the lesser included offense of misdemeanor battery. The issue considered by the Supreme Court was whether a defendant convicted by jury verdict after raising a self-defense claim is entitled to a new immunity hearing if the trial court applied the incorrect standard at the immunity under Florida's Stand Your Ground law. The Supreme Court answered this question in the negative, holding that that a deficient self-defense immunity hearing that used the wrong standard can be cured by a jury verdict, which requires the highest standard of proof, beyond a reasonable doubt.

Summary of Case Context & HoldingA property owner (Bostco) sued the Milwaukee Metropolitan Sewage District (MMSD) to recover for damages sustained because of leaking sewage on the owner's property due to MMSD's negligent operation and maintenance of a sewage tunnel under the owner's property. The Supreme Court held that MMSD was required to abate the private nuisance caused by the sewage leakage because "a municipal entity has a duty to abate a known, private nuisance." The Supreme Court also held that the cap on damages for municipal liability did not limit the property owner's equitable relief nor did it violate the equal protection clause of the Wisconsin Constitution (Article 1, Section 1). In the majority opinion, the Supreme Court found that Bostco did not assert it was a member of a protected class, or that recovery in tort (negligence) from a governmental entity is a fundamental right. Therefore, the Supreme Court upheld the damage limitations in Wis. Stat. Sect. 893.80(3). Finally, the Supreme Court also concluded that the trial court erred in its proposed solution for the leakage without hearing testimony. The Supreme Court remanded this matter to the circuit court to hear testimony on whether lining the sewage tunnel was required for abatement, or if MMSD could pursue an alternate method to stop the leak.

Summary of Case Context & HoldingThe employee-Plaintiff alleges that his employer failed to provide reasonable accommodations for his hypersensitivity to fragrances in the workplace. The employer instead claimed that they had made reasonable accommodations by setting new rules for fragrances within the workplace, and that any further accommodations were impracticable and unreasonable. The lower court agreed with the employer and that the employer did not retaliate by placing the employee on administrative leave. On appeal by Plaintiff, the Supreme Court found that the lower court properly granted summary judgment to the employer as the Plaintiff failed to show that the employer did not make good faith attempts to accommodate him, and also failed to show that an alternative accommodation existed that would have allowed him to continue to perform essential job functions. The Supreme Court held that the employer satisfied its burden under Montana administrative law by making changes to its workplace fragrance policy and opening up multiple avenues of communication with the employee. Admin. R. 24.9.606(4)-(5) (2018).

Summary of Case Context & HoldingEmployee-Plaintiff alleges that she was terminated by employer-Defendant due to a disability accommodation and prior labor complaints, while the employer alleges the firing was due to the employee lying during an internal investigation. The lower court upheld the appointed Hearing Officer's conclusion that the employee was properly terminated for cause due to dishonesty. The Supreme Court upheld the lower court's decision for the employer, finding that the adverse employment action was appropriately related to a legitimate, non-retaliatory reason arising from the employee's untrue statements. The Supreme Court found that the employee was being reasonably accommodated for her disability, and that the termination was related to her retention of confidential information and subsequent lying, rather than retaliation for engaging in protected activity.

Summary of Case Context & HoldingOn November 30, 2020, Georgia voter Paul Andrew Boland sued Secretary Brad Raffensperger and other state election officials seeking decertification of the election results alleging voters were illegally cast by non-Georgia residents and data showed counties were not properly verifying signatures. Plaintiff sought equitable relief in the form of a voter roll audit, ballot audit, and verification. On December 8, 2020 the trial court dismissed the case on the grounds that (1) the state defendants were improper parties to the action because they were not candidates for office; (2) the equitable doctrine of laches barred Plaintiffs' claims because the 2020 general election had already been conducted based on preexisting procedures that voters and election officials relied upon; (3) Plaintiff lacked standing; (4) Plaintiff failed to state a claim upon which relief could be granted; and (5) Plaintiff's complaint was moot because the election results had been certified. On December 14, 2020, Plaintiff filed an emergency appeal with the state Supreme Court which the Supreme Court denied that same day.

Summary of Case Context & HoldingPlaintiffs, citizens of Montana, brought an action against BNSF Railway Company (BNSF) alleging that it was negligent and strictly liable for its handling of the transport of asbestos and the spillage of asbestos containing vermiculite along its tracks and railyard. The asbestos court, in which the case was originally brought, found that BNSF's handling of the asbestos constituted an "abnormally dangerous activity" and, therefore, under Section 519 of Restatement (Second) of Torts, that BNSF was strictly liable to the Plaintiffs. The Montana Supreme Court affirmed the decision, however, it went on to adopt Section 521 Restatement (Second) of Torts, which provided an exception to strict liability if the activity at issue was conducted in "pursuance of a public duty imposed on the actor . . . as a common carrier." The Supreme Court found that, when acting in its capacity as a common carrier, BNSF was entitled to the exception, but that BNSF could still be found liable under a theory of ordinary negligence for the manner in which it handled the transport of the asbestos and strictly liable for activities that were carried out for its own purposes, rather than for public purposes. The Supreme Court also addressed arguments related to preemption—rejecting BNSF's arguments that Plaintiffs claims (1) that BNSF failed to prevent asbestos dust from escaping from its railcars were preempted by Federal Railroad Safety Act (FRSA) regulations concerning train speed, because the Plaintiffs claims were not, in fact, about train speed; and (2) were preempted by the Hazardous Materials Transportation Act (HMTA) because the HMTA did not include asbestos as hazardous material it was meant to cover and, thus, was not relevant.

Summary of Case Context & HoldingBlumenthal and Brewer previously lived in a same-sex long-term domestic relationship but never married. Once they separated, Blumenthal brought a partition action for the family home. Brewer filed a five-count counterclaim asserting common law rights to the couple’s shared property, including an ownership interest in Blumenthal’s medical practice. The circuit court dismissed the counterclaims on the basis of Hewitt v. Hewitt, 394 N.E.2d 1204 (Ill. 1979), which held that as a matter of public policy, unmarried cohabitants were precluded from bringing common law claims for property rights upon dissolution of the relationship. The appellate court rejected Hewitt and held that Brewer’s counterclaims were proper given the changing nature of public considerations regarding domestic relationships. The Illinois Supreme Court vacated the appellate court’s decision and affirmed the circuit court. First, the Supreme Court determined that the appellate court lacked jurisdiction over four of the counterclaims because the circuit court’s dismissal of those claims was not a final judgment. Although Illinois Supreme Court Rule 304(a) provides for interlocutory appeals from final judgments that do not dispose of an entire proceeding, the Supreme Court determined that the trial court’s dismissal did not constitute a “final judgment or order.” But even if the dismissal were appealable and properly before the intermediate appellate court, the substantive basis on which that court resolved the appeal—i.e., by overruling the Supreme Court’s Hewitt decision—was improper. The Supreme Court determined that the appellate court entirely lacked jurisdiction and indeed the power to overturn a binding decision of the state’s highest court. The Supreme Court next determined that, while on these facts the normal course of action would be to remand the case for further proceedings, the parties had continued to litigate the merits of the partition act during the pendency of the appeals. By the time of the Supreme Court’s decision, the trial court had determined on a final basis the value of the home at issue and apportioned the proceeds thereof. Each of the parties had acted accordingly by undertaking financial transactions to effectuate a distribution and transfer of property between them. Because neither party then appealed the partition findings, this rendered the appeal moot. Brewer argued that the reinstatement of her counterclaims would “undo” the trial court’s partition determinations. But because Brewer had acted upon and failed to appeal the trial court’s ruling, the Supreme Court relied on res judicata and the law of the case doctrine to find that the partition findings below were final and unappealable. Unlike the other counterclaims, the Supreme Court determined that review of Count III was proper as a “separate and distinct claim” from the partition action. Through Count III, Brewer requested imposition of a constructive trust on Blumenthal’s medical practice, or in the alternative, restitution, because the couple had financed Blumenthal’s ownership interest in the practice from the commingled proceeds of a joint savings account to which both had contributed. During the relationship, Blumenthal and Brewer enjoyed the financial benefit of income earned from the medical practice. But once the relationship ended, those benefits to Brewer ceased. The Supreme Court first disposed of the constructive trust argument because the Medical Corporation Act and the Medical Practice Act of 1987 prohibited Brewer, who was not a licensed doctor, from having any part in “‘ownership, management, or control’ of a medical corporation.” In rejecting the common law claim for restitution, the Supreme Court undertook an extensive review of Hewitt and its progeny before reaffirming that under long-standing precedent unmarried long-term domestic partners have no common law property rights against each other upon dissolution of the relationship. First, the legislature prohibited common law marriage in the early 1900s via the Marriage and Dissolution Act. In Hewitt, the Supreme Court had previously conducted a thorough public policy analysis in determining that the legislature “intended marriage to be the only legally protected family relationship under Illinois law.” Even though LGBT rights organizations argued for a departure from Hewitt on Brewer’s behalf, the Supreme Court rejected this call and reinforced Hewitt’s holding. That the legislature had amended portions of the Marriage and Dissolution Act post-Hewitt indicated that if the legislature wanted to protect unmarried cohabitation based on changing societal norms, it could have done so.

Summary of Case Context & HoldingLicensed deer breeders brought an action against the State Department of Conservation and Natural Resources to obtain a judgment declaring that offspring produced by the artificial insemination of female whitetail deer with semen of a male mule deer were “protected game animals” under Ala. Code § 9-11-30 and that, as a result, they could be hunted and otherwise treated like whitetail deer. On a motion for a judgment on the pleadings, the trial court concluded that because the hybrid deer were the offspring of a female whitetail deer, they were "protected game animals," both by virtue of the inclusion in that definition of "whitetail deer ... and their offspring," and by virtue of an old legal doctrine called partus sequitur ventrem, which means "the offspring follows the condition of the mother." The trial court entered a judgment on the pleadings for the deer breeders and the Department appealed. The Alabama Supreme Court reversed and remanded because the modifier "and their offspring" in the statute did not reach back to the term "whitetail deer," and because partus sequitur ventrem (which historically applied to the ownership of livestock (and slaves) and persons) had no application in the case.

Summary of Case Context & HoldingDefendant Alfonso Manuel Blake was convicted of first-degree murder and sentenced to death. The Court affirmed. This case arose from Defendant's second petition for postconviction habeas relief based on alleged ineffective assistance of counsel in his first petition. Of note as to the death penalty, the Court rejected Blake's claim that his postconviction counsel was ineffective for failing to challenge the constitutionality of Nevada's lethal injection protocol. Citing McConnell v. State, 212 P.3d 307, 310-11 (Nev. 2009), the Court affirmed its holding that "challenges to the lethal injection protocol are not appropriately raised in a post-conviction petition." Thus, Blake's counsel was not ineffective for not raising a claim that entitled Blake to no relief. Additionally, the Court rejected Blake's argument that counsel "was ineffective for not challenging the constitutionality of this court's review of death sentences under Nev. Rev. Stat. § 177.055(2) on the ground that this court has not articulated standards for that review." The Court determined this argument lacked merit because the statutory requirements were clear, Blake did not assert any Justice on the court was biased against him, and because it was procedurally barred. Further, Blake argued that his counsel failed to show the "plethora" of mitigation evidence showing that he had a mental disorder and a "depraved childhood," such as mental health evaluations outlining his brain damage. The Court acknowledged that past counsel's failure to identify and present this kind of evidence demonstrated deficient performance. However, to prove ineffective counsel, Blake must also show that the deficient performance prejudiced him. The Court found that Blake was not prejudiced by counsel's failure to present mitigating evidence because Blake's crime was so heinous (i.e., execution style killing of three women), the mitigating evidence would not have swayed the jury's conclusion. Accordingly, the Court affirmed the district court's judgment. In dissent, Justices Cherry and Saitta would have found that Blake's postconviction counsel was ineffective as to their investigation and presentation of mitigation evidence.

Summary of Case Context & HoldingBitterrooters for Planning Inc., and Bitterroot River Protective Association, Inc. (collectively Bitterrooters), both environmental organizations, sought review by the district court of an environmental assessment conducted by the Department of Environmental Quality (DEQ) in connection with a commercial developer’s request for a groundwater pollution control system permit, under the Montana Water Quality Act (MWQA). Bitterrooters alleged, and the district court agreed that by issuing the permit, the DEQ violated the Montana Environmental Policy Act (MEPA), because it failed to (1) adequately consider the secondary impacts of the construction and operation of the retail facility, which were unrelated to water quality; and (2) identify the operator of the retail facility being constructed. DEQ, and landowners of the contemplated commercial development site, appealed. On appeal, the Supreme Court reversed the district court’s decision granting Bitterooters’ motion for summary judgment on issue (1) above—concluding that the DEQ was not required to consider non-water quality related environmental impacts regarding the construction and operation of the contemplated retail facility because such were not secondary impacts of the MWQA permit. The Supreme Court, however, affirmed the district court’s decision to grant Bitterrooters’ motion for summary judgment on issue (2) above—concluding that DEQ was required, under the MWQA, to identify the actual owner and operator of a wastewater treatment facility prior to issuing a groundwater discharge permit.

Summary of Case Context & HoldingPlaintiff alleged that she was fired for organizing staff members against the elected Board of County Commissioners. The Defendant-employer instead pointed to performance reasons for the termination. The lower court held that since the Plaintiff held a sensitive managerial position as Human Resources Director, the Defendant had had greater discretion to terminate her for good cause. The Supreme Court agreed, affirming that the employer's decision to terminate her should be accorded great deference due to the Plaintiff's status as a manager. The Supreme Court added that the Plaintiff failed to sustain her burden of showing that the cause of termination was pretextual since the record contained adequate reasons for the termination, including the Plaintiff's own admissions that she had lacked understanding of some key aspects of her job and verbally abusing her own employees.

Summary of Case Context & HoldingIn 2010, Congress enacted the Patient Protection and Affordable Care Act (ACA), which provides federal funding to states that choose to expand eligibility under their state Medicaid programs to all "individuals under the age of 65 with incomes below 133 percent of the federal poverty level." In 2013, by a simple Majority vote, the Arizona legislature enacted H.B. 2010 to expand coverage under Arizona's indigent health care program, Arizona Health Care Cost Containment System (AHCCCS), with federal monies funding most of the costs. To fund the remaining costs, H.B. 2010 required the director of AHCCCS to levy an "assessment" on Arizona hospitals. A.R.S. § 36-2901.08(A). After the governor signed H.B. 2010, then-state-senator Andy Biggs, thirty-five other legislators who had voted against the bill and three citizens filed this action against AHCCCS Director Thomas Betlach and others (collectively the Director). The lawsuit sought to enjoin implementation of the hospital assessment, alleging that it violates Article 9, Section 22 of the Arizona Constitution because it was not approved by a two-thirds vote of the legislature. The Arizona superior court initially dismissed the case for lack of standing. The Arizona Supreme Court reversed and remanded for further proceedings. On remand, the parties filed cross-motions for summary judgment. The superior court ruled that § 36-2901.08 was properly enacted by a simple Majority because the law does not impose a tax but instead falls within an exception listed in Article 9, Section 22. The court of appeals affirmed. The Arizona Supreme Court granted review and held that the hospital assessment is not subject to Article 9, Section 22 of the Arizona Constitution, which generally requires that acts providing for a net increase in state revenue be approved by a two-thirds vote in each house of the legislature. The Court determined that the hospital assessment was not subject to the constitutional two-thirds vote requirement because (1) the hospital assessment was not a “tax” subject to supermajority vote requirement; and (2) the two third requirement does not apply to the hospital assessment because the hospital assessments were statutorily authorized assessments that "are not prescribed by formula, amount or limit, and are set by a state officer or agency." Ariz. Const. art. 9, § 22(C)(2). Citing May v. McNally, 55 P.3d 768 (Ariz. 2002), the Court applied a three-factor test and determined that the hospital assessment is not a “tax” subject to the two-thirds vote requirement because the assessment was imposed by Director of AHCCCS on hospitals, a narrow class, and directly benefited hospitals by expanding AHCCCS coverage for uninsured patients thereby increasing payments to the hospitals. The Court further found that the hospital assessment was authorized by statute and was not prescribed by formula, amount, or limit. In particular, the hospital assessment was statutorily authorized under the usual legislative process (i.e., by a simple Majority vote) and the legislature delegated the determination of a fee or assessment to a state officer or agency (i.e., Director of AHCCCS). Further, the hospital assessment was not established or administered in a manner that causes a reduction in federal financial participation. Finally, Arizona state law does not prescribe the formula, amount, or limit on hospital assessment. Accordingly, the Arizona Supreme Court rejected the constitutional challenge to the assessment.

Summary of Case Context & HoldingUnder Nevada law, hospitals must reduce charges by 30% for uninsured patients who lack other third-party contractual provisions of payment, and who pay their bill within 30 days of discharge. Bielar was injured in an automobile accident in 2002, and received treatment at a hospital operated by Washoe Health Systems (the Defendant) in April 2003, May 2003, and February 2005. By terms of a Conditions of Admission agreement with the Defendant, Bielar granted a statutory lien to the Defendant for any settlement proceeds she obtained from the tortfeasor of her injuries, later granting a second lien for her February 2005 admission. Bielar was uninsured at every point during her treatment and had intended to pay her hospital bills out of any settlement proceeds she recovered. In total the statutory liens amounted to approximately $126,000. Bielar then recovered $1.3 million from her tortfeasor's insurer, on the condition that Bielar indemnify the insurer against all liens by healthcare providers. Following the settlement, the Defendant then sued the tortfeasor's insurer for satisfaction of the liens, and Bielar tendered all money asserted then due. Bielar then sued the hospital, disputing the amount of medical charges incurred, and arguing that the Defendant had failed to properly reduce the charges by 30%. The district court ruled that Bielar lacked standing to bring her lawsuit, as the settlement agreement with the insurer qualified as a contractual provision of payment, therefore making Bielar ineligible for the 30% reduction. The Supreme Court held that due to the verb tense of the underlying statute, a patient's eligibility for the discount is determined upon initial admission and treatment, and that a later contractual provision of payment does not disqualify an uninsured patient from receiving a discount. Further, the Court also held that because the agreement merely provided money in release of claims, and did not directly provide for medical coverage, the agreement could not be considered a contractual provision of payment or coverage, and would not disqualify Bielar from receiving the discount.

Summary of Case Context & HoldingA records requester brought an action against the Illinois High School Association (IHSA), which governs interscholastic athletic competitions for schools in Illinois. In 2014, the Better Government Association (BGA) submitted an Illinois Freedom of Information Act (FOIA) request to the IHSA and one of its underlying school districts for various categories of contracts. IHSA responded that it was a not-for-profit organization not subject to the state FOIA, while the school district denied holding any responsive documents, and that such requests were not allowable under the state FOIA as they were not adequately applicable to the district's public business. The BGA brought a complaint against the IHSA and the district seeking a declaratory judgment that the Defendants had violated FOIA by refusing to produce the documents as the IHSA performed governmental functions on behalf of public school districts. The circuit court granted motions to dismiss filed by the IHSA and the school district, ruling that the IHSA is not a public body and that it was not performing governmental functions on behalf of the school districts. The appellate court affirmed, finding that the IHSA has an independent existence separate from the member schools, and that it does not perform a public function. The Supreme Court affirmed, holding that the IHSA was an independent legal entity enjoying a separate legal existence from any public body, that the IHSA's governing documents and practices indicated little direct government control, and that the IHSA had not been contracted to perform governmental function on behalf of any district. As a result, the IHSA was not required to provide the requested records.

Summary of Case Context & HoldingThe city of Chicago decided to replace many of its lead water pipes. However, the replacement exposed residents to greater danger from lead pipes that carry water from the main system to their homes. A group of residents whose pipes were replaced sued on negligence as well as inverse condemnation grounds for the government’s actions. The Court held that both claims should be dismissed. The negligence claim alleged that the government had increased the risk of harm to the residents. However, the Court found that an increased risk is not cognizable as an injury. As a result, it does not justify a remedy through tort law. The inverse condemnation claim arises from the city’s use of copper pipes as a replacement which creates a consistent increase in lead erosion where the copper pipes meet the individual homes’ pipes, depriving the homeowners of a benefit. The Court found that the increased risk does not harm the residents' ability to use their pipes because water filters can remedy the harm. In addition, the replacement did not decrease the value of the pipes. As a result, it cannot give rise to an inverse condemnation.

Summary of Case Context & HoldingDefendant was convicted of malice murder and other crimes in connection with a shooting death and the wounding of several others. Defendant's motion for a new trial was denied, and he appealed, arguing the trial court erred when it refused to suppress incriminating statements he made while in police custody. A police officer arrested Defendant and read him the Miranda rights, which Defendant did not understand. The officer attempted to explain the Miranda rights in layman's terms, but the Supreme Court held that "[b]ecause the interrogating officer’s subsequent explanation of those warnings was incomplete," the Supreme Court could not find that Defendant knowingly and intelligently waived his rights. The Supreme Court concluded Defendant’s custodial statements were obtained in violation of his Miranda rights and reversed the judgment of the trial court.

Summary of Case Context & HoldingJoseph Rand received a water permit for property in Eureka County in 1960. Following his death in 2008, the trust that managed the property applied for a water permit for a new well head to compensate for the old well's insufficient water. The State Engineer authorized the new permit. The trust was unable to finish drilling the well and was granted an extension. When Rand's daughter Patti Benson took over the property in 2013, she did not renew the permit and it was cancelled. Benson challenged the cancellation in district court, arguing that the State Engineer had not provided enough time to file a report of conveyance and barred her presenting record evidence. The State argued that she had failed to exhaust administrative remedies, and the district court granted the State Engineer's motion to dismiss. The Supreme Court held that the state statute required a party aggrieved by the cancellation of a water permit to exhaust all administrative remedies related to a State Engineer's permit prior to filing a petition for judicial review with the court.

Summary of Case Context & HoldingA homeowners association denied a property owners' application to install solar panels on their roof, citing aesthetic concerns. The property owners challenged the denial, contending that it violated Section 22B-20 of the North Carolina General Statute, which generally prohibit restrictions on the installation and use of solar panels unless the restriction (i) does not prevent the reasonable use of the solar panels; or (ii) expressly prohibits the location of the solar panels as specified in the statute. The Supreme Court ruled in favor of the property owners, holding that the denial had the effect of restricting the installation and use of solar panels and that neither exception applied.

Summary of Case Context & HoldingThe Wilkinsburg school district changed mode of transportation for its charter school students from school buses to public transportation (with free passes). The charter schools and the grandmother of two charter school students sued the school district seeking declarative and injunctive relief, claiming that the bus passes did not constitute the provision of "free transportation" as required under Pennsylvania's Charter School Law (24 P.S. § 17-1726-A(a)). The commonwealth court ruled that the school district was required to seek approval from the Pennsylvania Department of Education prior to making the change. The Supreme Court reversed, holding that the school district was not obligated to submit its plan to the Pennsylvania Department of Education before implementation. The Supreme Court found that the regulation governing the Department of Education's approval of transportation plans to be ambiguous, and thus the school district's interpretation that pre-approval was not required was reasonable.

Summary of Case Context & HoldingBelcher got into a disagreement with a man over a drug transaction. Sometime later that day, Belcher went to the man's home with a gun. Belcher kicked in the door, and ended up shooting and killing the man's daughter and then stealing items from the home. Belcher was convicted of murder and sentenced to death. He later appealed his sentence, arguing, among other things, that the evidence did not support the finding of aggravating circumstances, which are required to sentence someone to death. The Court found that sufficient evidence supported four of five aggravating circumstances found by the jury, which was sufficient to impose the death penalty: (1) Belcher had a prior conviction for involuntary manslaughter and attempted murder (2 aggravating circumstances); and (2) Belcher committed the murder with a deadly weapon and in the course of a robbery (2 additional aggravating circumstances).

Summary of Case Context & HoldingPlaintiff was a tenured teacher who was dismissed from her job because of her alleged poor teaching performance. Plaintiff had a close family member with dwindling health and Plaintiff was the primary caretaker. The school board allegedly warned Plaintiff multiple times about her performance and ultimately dismissed her with cause. Plaintiff requested an administrative hearing related to her dismissal, and the hearing officer recommended that she be reinstated in her position with back pay and benefits because the board failed to prove by a preponderance of the evidence that Plaintiff had violated the warnings or engaged in irremediable conduct. The school board still dismissed the Plaintiff from her position, and Plaintiff brought suit seeking additional review of her dismissal. The circuit court ruled that deference should be given to the official who oversaw the administrative hearing, considering their experience and impartiality, reversing the Board's decision. On appeal, the appellate court ruled that instead a balance of deference should be afforded to both the board and the administrative officer, but that the board had not adequately presented evidence detailing its reasons for firing the Plaintiff. The Supreme Court reviewed the school board's decision and held that the Plaintiff's discharge was arbitrary, unreasonable, and unrelated to the requirements of service. The school board's evidence did not constitute a clear and material breach of the warning notices that the Plaintiff received. Therefore, the Board's decision to discharge the Plaintiff was held to be erroneous.

Summary of Case Context & HoldingUnder the Texas Human Resources Code (THRC), individuals with disabilities have an equal right to individuals without disabilities to fully use and enjoy any public facility. The THRC goes on to define “public facility” as “a public building maintained by any unit or subdivision of government,” and considers the failure to make “reasonable accommodations” or “provide auxiliary aids and services” as prohibited discrimination. Two inmates housed at the Texas Department of Criminal Justice (TDCJ) Lane Murray Unit, each of whom were deaf, sued the executive director of TDCJ, claiming that TDCJ violated the THRC. The inmates claimed that the TDCJ had failed to make reasonable accommodations to provide them with access to the telephone system, and failed to provide sign language interpreter to allow them to participate in various programs occurring at the prison. Before trial, the trial court granted a temporary injunction directing the executive director to provide services to allow the inmates to make telephone calls. Following a bench trial, the trial court determined that the prison was a “public facility” under the THRC, and that the executive director had illegally discriminated against the inmates by failing to make reasonable accommodations. As a result, the executive director was ordered to provide sign language interpreters at numerous events and processes occurring at the prison, and accommodations relating to phone calls. On appeal, the appellate court reversed the ruling and held that the TDCJ was not a public facility, as it was not open and accessible to the public. On further appeal, the Supreme Court reviewed the examples of public facilities included in the THRC, such as highways, hotels, restaurants, and general buildings where the public is invited, and determined that the Legislature intended a public facility to be one that is “open and accessible to the public.” The inmates further argued that providing accommodations for the prison’s programs promoting reintegration and participation in social life would further the TDCJ’s stated purpose of enabling those with disabilities to “participate fully” in the state’s society and economy. However, the Court noted that prisoners are already unable to participate in the social and economic life of the state by way of their imprisonment, and therefore excluding prisons from the definition of “public facilities” did not frustrate the purpose of the THRC.

Summary of Case Context & HoldingTwo Dane County residents challenged the authority of Janel Heinrich, the local health officer and director of Public Health Madison & Dane County, regarding the issuance of public health orders to prevent, suppress, and control COVID-19. The challenge raised more general statutory and constitutional questions about Heinreich's authority to issue an order at all, regardless of the measures it promulgated. The Supreme Court held that Wis. Stat. § 252.03 granted local health officers the authority to issue the subject orders. They held that a local health officer's authority to issue enforceable public health orders pursuant to Wis. Stat. § 252.03 and Dane County Ordinance § 46.40 did not conflict with the constitutional separation of powers.

Summary of Case Context & HoldingPlaintiffs, over thirty landowners, entered into separate oil and gas leases with Victory Energy Corporation under which Plaintiffs leased drilling rights to Victory. Victory shared its leasehold interests with Megaenergy Inc. Inflection Energy LLC then assumed from Megaenergy the operational rights and responsibilities under most of the leases. Each of these leases contained a force majeure clause which provided that nonperformance may be excused under certain circumstances. The leases also contained identical "habendum clauses," clauses which are typically found in standard oil and gas leases used to fix the lease duration, establishing the period during which the energy companies could exercise the drilling rights granted by the leases. Then-Governor of New York David Paterson ordered a formal public environmental review to address the impact of combined use of high-volume hydraulic fracturing (fracking) and horizontal drilling. As a result, the state Department of Environmental Conservation (DEC) informed the public that no permits for fracking would be issued until the DEC issued its required findings statement. After the primary term of the leases had expired, Plaintiffs commenced a declaratory judgment action against Inflection, Victory, and Megaenergy, seeking a declaration that the leases had expired by their own terms. The energy companies counterclaimed for a declaration that each lease was extended by operation of the force majeure clause, arguing the New York moratorium on the use of horizonal drilling and high-volume hydraulic fracking triggered this clause. The Court of Appeals held that the force majeure clause did not modify the habendum clause, and therefore the leases terminated at the conclusion of their primary terms.

Summary of Case Context & HoldingThe all-African American Mitford Elementary School was closed following a 1970 federal desegregation order. Following the closure, students in Mitford were given the choice between attending schools in other parts of the Fairfield County School District (FCSD), or schools in the neighboring Chester County School District (CCSD) that were closer to them. Under an agreement between FCSD and CCSD, the students attended school in the neighboring district at no costs to the students or their families, while FCSD made an annual payment of $25,000 to CCSD for educational expenses. In 2009-10, this structure ended, resulting in the General Assembly passing Act No. 294 to provide an arrangement between the districts. Under this Act, codified as S.C. Code Ann. § 59-63-485, FCSD would pay CCSD 103% of CCSD's per pupil revenue for each student that elected to attend CCSD. CCSD then invoiced the Fairfield County Treasurer for $1.8 million for the previous three years' expenses. FCSD filed suit against the State, CCSD, the Fairfield County Treasurer, and the State Department of Education seeking a declaratory judgment that Act No. 294 violated the South Carolina Constitution protections against special legislation. The circuit court granted motions for summary judgment filed by the Defendants, and FCSD appealed. On appeal, the Supreme Court reviewed South Carolina precedent allowing for special legislation in situations where such special legislation "best meet[s] the exigencies of a particular situation," and namely where the legislature has a logical basis or sound reasoning in its legislating. Here, the Supreme Court held that FCSD had failed to present evidence as to why there was neither a logical basis nor sound reasoning for enacting Act No. 294, and instead had relied purely on baseless allegations. Justice Beatty dissented, writing that the majority had unjustly and "myopically" focused on the procedural posture of the case, and not given any proper consideration to the Act itself. The dissent framed Act No. 294 as disrupting the application of the existing general laws, therefore, requiring some explicit justification for this disruption. The dissent further reviewed the legislative history and found that nothing supported that this transfer of students required a special framework allowing for the payments created under the Act (when no other transfers of students in the state require a similar payment).

Summary of Case Context & HoldingThe Montana Board of Regents of Higher Education filed suit for declaratory relief to challenge a newly enacted state law that would curtail its ability to regulate firearms on university campuses. While the Board had previously exercised exclusive authority over firearms on campuses and had limited carrying firearms to police or security officers, the new law would extend open and concealed carry policies to college campuses. The district court determined that the new law violated the Board’s constitutional authority and therefore any application to the Board or university campuses would be unconstitutional. The Supreme Court upheld the district court’s decision, interpreting the state constitution as a limit on legislative power, and looked to the plain language of the original grant of powers to the Board. While the Board’s power is not limitless, and it still must fall under certain powers of the legislature (such as auditing), it nonetheless has broad purview over all aspects of the university system.

Summary of Case Context & HoldingThe Board of Education of Springfield School District (Board) met in several closed sessions to discuss potentially entering into a separation agreement with the then-superintendent of schools. The superintendent signed the proposed agreement at a closed meeting, and the board members also voted on the agreement at a later closed session but did not date their signatures. At the Board attorney's urging, the Board later held a public meeting where they separately voted to approve the agreement, and dated their signatures. The Illinois Attorney General opened an investigation into the Board's process, which led the Board to hold another meeting, with limited advanced notice to the public, where they once again voted to approve the agreement, redating their signatures. Upon the conclusion of the investigation, the Attorney General found four violations of the Open Meetings Act, which governs when and how certain public bodies in Illinois hold meetings and approve agreements. These violations concerned the initial closed-door signing of the agreement, the later ratification at a meeting that the public was not informed of, the failure to record any of the meetings, and the failure to summarize discussions held in five separate closed meetings. The Board sought administrative review of the Attorney General's conclusion, and the decision was overturned by the circuit court who determined that the final action was not taken by the Board until the final meeting where signatures were redated. On remand, the Attorney General issued a new opinion finding that the Board had violated the Open Meetings Act in the final meeting by again inadequately informing the public. The Circuit Court sided with the Board, and the appellate court affirmed, both finding no violations of the Act. The Supreme Court held that the Board had adequately conformed with the requirements of the Act by reciting the general nature of the matter under consideration and providing specific detail to the public sufficient to identify the particular transaction in its final meeting approving and redating the agreement. It was not necessary for the Board president to delve into the key points of the agreement at an open meeting. Therefore, the public recitation requirement of the Open Meetings Act was met, and the public vote thereafter validly approved the separation agreement.

Summary of Case Context & HoldingDaphne Moore was a tenured teacher working at the Charles W. Earle STEM Academy during the 2016-2017 academic year. Moore was in her classroom when she learned that a student had ingested pills, and other school personnel responded to the incident and helped the student. The Board sent a dismissal letter to Moore stating that she failed to appropriately respond to a student's medical issue and did not supervise the students adequately. Moore was suspended without pay and subjected to a dismissal hearing. The hearing officer recommended that Moore be reinstated, and the Board adopted this recommendation, but issued a warning resolution with a 90-day time-served suspension with a deduction from Moore's net back pay. Moore appealed and argued that her suspension and reduction in pay were unlawful. The appellate court ruled that the Board could only dismiss Moore completely or reinstate her with full back pay, claiming that it was outside of the Board's power to suspend a teacher without pay following a dismissal hearing. The Supreme Court disagreed, concluding that Section 34-85 of the School Code, which governs dismissals, allows the Board to issue a suspension once a determination is made that the conduct does not constitute cause for dismissal. The Court determined that the Board acted within the scope of its power in reducing Moore's net back pay.

Summary of Case Context & HoldingBCCA Appeal Group members, who operate integrated chemical manufacturing plants and refineries, brought an action against the City of Houston (City or Houston) seeking injunctive relief and a declaratory judgment that an air-quality ordinance was invalid and unenforceable under the Texas Clean Air Act (TCAA), the Texas Water Code, and the state constitution. At issue is whether the TCAA and its enforcement mechanisms in the Texas Water Code preempt a Houston air-quality ordinance, and whether the Houston ordinance can incorporate Texas Commission on Environmental Quality (TCEQ) rules in their current form and as amended in the future. By way of background, in 1992, the City enacted an air-quality ordinance to regulate air pollution from facilities that were not already regulated under the TCAA. In 2007, the City amended the 1992 ordinance to establish its own air-quality regulatory-compliance program and adopted a fee schedule to fund the program. BCCA Appeal Group members operate integrated chemical manufacturing plants and refineries in the Houston area and filed suit seeking a declaratory judgment that the 2007 amendment is invalid and unenforceable under the TCAA, the Texas Water Code, and the Texas Constitution. The Texas Supreme Court held Houston's ordinance enforcement provisions were inconsistent with the statutory enforcement requirements. The Texas Supreme Court found that the enforcement provisions of the ordinance ultimately moot the TCEQ’s discretion by authorizing criminal prosecution even when the TCEQ determines that an administrative remedy is the appropriate remedy and therefore the provisions do not promote uniformity between the ordinance and the statutory enforcement requirements of the TCAA. In addition, the ordinance’s registration requirement conflicts with the TCEQ’s authority to issue permits such that a facility with a TCEQ-issued permit but that is not registered under the ordinance, would not be operating lawfully. As such, the Texas Supreme Court further held the ordinance's registration requirement makes unlawful what the TCAA approves and is thus preempted and unenforceable. Finally, the Texas Supreme Court held that the incorporation of the TCEQ rules does not violate the nondelegation doctrine of the Texas Constitution because the City’s incorporation of the TCEQ rules into the ordinance as they exist is not limited by any statutory or constitutional provisions.

Summary of Case Context & HoldingThe Plaintiff, Weems, sued a hospital alleging that a nurse had falsified a medical record of an admitted patient to indicate that the patient had sustained a gunshot wound to the head. Weems was indicted for aggravated assault of the patient, with the only evidence being, as Weems claimed, the medical record at issue. Weems claimed that the attending nurse had been coerced into falsifying the report to cover-up what would have been an otherwise illegal entry and search of Weems’s hotel room. In the medical report, the nurse indicated that the patient had managed to brush away a gun pointed at his head immediately prior to firing. The report also included that the only injury sustained was an injury to the patient's forehead, which the report indicated was a gunshot wound. Weems claimed that the nurse was aware that information included in the report would be used in a criminal investigation and that the police relied on the report to (1) search Weems's hotel; (2) seize Weems; and (3) charge Weems with attempted murder and set bond at $100,000. Weems sued the hospital for intentional infliction of emotional distress, claiming that the nurse had intentionally falsified information in the medical report. The trial court ruled that the action was a health care liability claim, regulated by the Texas Medical Liability Act (TMLA). Under the TMLA, any healthcare liability claim must be supported by an expert report within 120 days following the defendant’s original answer. Weems failed to serve such a report, and the case was dismissed with prejudice. On appeal, the appellate court reversed and remanded, holding that claims of alteration and fabrication of medical records are not considered healthcare liability claims. A state appellate circuit split existed on this issue, however, and the hospital further appealed to the Supreme Court. The Supreme Court reviewed the definition of a health care liability claim under the TMLA, noting that it includes a “claimed departure from accepted standards of medical care . . . or administrative services directly related to health care.” The Court held that medical records are a requisite part of the patient care process and that treatment, as well as future treatment, is based on the proper maintenance of records. As a result, the records at issue here, and their maintenance, would be considered “directly related to health care” under the TMLA. Further, falsification of records would be considered a “departure from accepted standards of medical care.” Accordingly, Weems’s claims were correctly considered health care liability claims, requiring an expert report.