State Supreme Court Data Tracker

Summary of Case Context & HoldingThe Minnesota Supreme Court granted the petition of Plaintiffs to assume jurisdiction over two consolidated suits filed in district court alleging that Minnesota's legislative election districts were unconstitutionally malapportioned and requesting that the Court appoint a special redistricting panel (Panel) to hear and decide the issues raised. The Panel determined that, based on 2020 census data, certain districts diverged materially from the statutory requirement that the populations of each district must be substantially equal in number. Citing two districts with populations that diverged from the ideal distribution by 11.5% and 21.2% respectively as examples, the Panel found that the population of Minnesota was unconstitutionally malapportioned among the state's legislative districts, which should be remedied so that the population of each diverged from an ideal distribution by no more than 2%. The Panel determined that state courts are authorized to rebalance districts to remedy constitutional defects if the legislature, which is primarily responsible for defining voting districts, fails to do so in a timely manner, noting that the legislature has sole authority to draw entirely new voting districts whereas courts may only modify existing districts. The Panel adopted the following politically neutral redistricting principles to govern the development of its redistricting plan: ensuring that the redrawn districts comply with the Voting Rights Act and Constitution (including requirements that they compromise approximately equal populations to afford every voter equivalent influence in electing representatives and safeguarding the equal opportunity of racial, ethnic, and language minorities to participate in the election process); respecting the sovereignty of federally recognized American Indian Tribes by maintaining the integrity of their contiguous reservation territories; designing districts as contiguous territories that are reasonably compact and convenient for both legislators and voters; preserving existing political subdivisions such as counties, cities, and townships to minimize electoral confusion and enhance the administration of elections; maintaining the integrity of communities by appropriately grouping rural, suburban, and urban areas; and ensuring the impartiality of the redistricting process by avoiding any design that protects, promotes, or undermines any incumbent, candidate, or political party. The Panel proposed a redistricting plan that incorporated extensive public comment solicited to ensure compliance with the redistricting principles, with modified districts that deviated from the ideal distribution by less than 1%. The Panel adopted the proposed new district boundaries and enjoined the use of the prior districts in the 2020 primary and general elections.

Summary of Case Context & HoldingPlaintiff filed a medical malpractice suit on behalf of her deceased husband and sought an injunction against a Florida statute mandating the ex-parte interview of her husband's healthcare providers by Defendant. The statute, which previously required pre-suit notice for medical malpractice claims, was amended in 2013 to require ex-parte interviews of Defendant's care providers by Defendant, Defendant's attorney, insurers, and experts. In assessing plaintiff's challenge, the trial court determined that the statute did not implicate the right to privacy, because such a right terminated with her husband's death, and further, that the statute did not burden access to the courts. The appeals court affirmed, holding that the statute, despite requiring pre-suit action, does not eliminate any substantive right, nor does the privacy right save Plaintiff's claim, which was waived upon filing the malpractice suit. In reversing the court of appeals, the Florida Supreme Court first recognized that even decedents are entitled to the right of privacy in all contexts under Florida's Constitution and that Plaintiff has standing to invoke the right on behalf of her deceased husband as his personal representative. The Court further rejected Defendant's arguments that Plaintiff waived the right to privacy by filing a malpractice suit, noting that while filing suit may waive the right regarding relevant information, it does not waive privacy rights in all medical information, including that which may be irrelevant to the claim. The Court then applied strict scrutiny in concluding that the ex-parte interview requirement does violate Florida's guarantee of privacy. In particular the statute fails to protect Florida citizens because it does not allow a representative of Plaintiff to monitor requests for or disclosure of irrelevant information which necessarily goes to Plaintiff's privacy right. The Court also determined the statute to violate the Constitution's guarantee of access to courts because it forces medical malpractice claimants to choose between their right to privacy and bringing their medical malpractice claim in court. The dissent argued that "medical malpractice claimants waive whatever constitutional privacy rights they may have in relevant medical information. Because the 2013 amendments do not in any way authorize the discussion of irrelevant medical information, medical malpractice claimants have no constitutional right to prevent the ex parte meetings." The dissent also argued that the statute does not burden access to courts because the court previously upheld the pre-suit requirements before the amendments and the amendments do not alter substantive rights.

Summary of Case Context & HoldingThis case arises from § 50-20-109(1)(a) (2005), MCA, which made it a felony for any licensed or competent health care provider, except physicians and physician assistants, to provide abortion care. Helen Weems and Jane Doe are licensed Advanced Practice Registered Nurses (APRNs). They challenged the constitutionality of the statute, claiming it violated a woman’s fundamental right to privacy to seek abortion care from qualified health care providers of their choosing. The parties presented extensive expert medical testimony to the district court concerning whether abortion care provided by APRNs presents an increased risk of harm to women. The district court concluded that abortion care provided by APRNs is safe and § 50-20-109(1)(a), MCA, is unconstitutional because it interferes with a woman’s right to seek abortion care from a qualified health provider. The district court relied on Armstrong v. State, 989 P.2d 364 (Mont. 1999), which held that the Montana Constitution guarantees a woman a fundamental right to privacy to seek abortion care from a qualified health care provider of her choosing, absent a clear demonstration of a medically acknowledged, bona fide health risk. On appeal, the Supreme Court affirmed the lower court's ruling and permanently struck down the law as well as reaffirmed that the state constitution guarantees the right to seek abortion care from the qualified healthcare provider of their choice. The Supreme Court concluded there was no genuine dispute of fact that APRNs are qualified health care providers of abortion care based on overwhelming evidence produced in the trial court record that APRNs provide safe and effective abortion care. The record was devoid of any evidence that APRNs providing abortion care would present a bona fide health risk acknowledged by the medical community. The Court concluded that § 50-20-109(1)(a), MCA, unconstitutionally interfered with a woman’s right to privacy, guaranteed by the Montana Constitution, to seek abortion care from a qualified provider.

Summary of Case Context & HoldingWeems was an Advanced Practice Registered Nurse (APRN) and the owner of a sexual and reproductive health clinic. As amended, § 50-20-109(1)(a), MCA, made it a felony for any licensed or competent provider, except physicians and physician assistants (PAs), to provide early abortion care. Weems argued that limiting the scope of qualified health care providers to physicians and PAs conflicted with Article II, Section 10 of the Montana Constitution and the Armstrong v. State, 989 P.2d 364 (Mont. 1999) case precedent (holding that a statute which prohibited PAs from performing abortions violated the Montana Constitution because there lacked a compelling state interest), because APRNs are qualified to perform early abortion care. Weems argued the restriction in § 50-20-109(1)(a), MCA, interfered with a woman's right to choose by making it a crime for qualified clinicians who are not physicians or PAs to provide abortion care. The Court noted that the State's ability to restrict the pool of health care providers and a woman's choice of who provides her health care, must be tethered to a medically acknowledged, bona fide health risk associated with those providers. The Court found that based on review of the evidentiary record, there is no medically recognized bona fide health risk of APRNs performing abortion care, and limiting the pool of qualified abortion providers would significantly interfere with a patient's right of privacy because of significant cost and travel required to access a provider. Accordingly, the Court held that § 50-20-109(1)(a), MCA, is an unconstitutional interference with a woman's right of privacy to seek medical care from a qualified provider of her choice.

Summary of Case Context & HoldingA Georgia law, O.C.G.A. § 20-2-1182, criminalized upbraiding, insulting, or abusing a public school teacher, administrator, or bus driver in the presence of a pupil while on the premises of a public school or school bus. In this instance, the Appellant was arrested and charged under the law and filed a general demurrer. He contended that the statute is unconstitutionally overbroad in violation of the right to free speech under the First Amendment. The trial court denied the Appellant's demurrer but granted a certificate of immediate review. Appellant then filed an application for an interlocutory appeal and the Supreme Court granted the application to review the substance of the constitutional challenge. It was found by the Supreme Court unconstitutionally overbroad because words which merely offended, disgraced, angered, or frustrated could not be prohibited in violation of one's right to freedom of speech under the First Amendment of the U.S. Constitution. The law itself was part of a collection of laws designed to address loitering or disrupting schools. The statute as written did not tie prohibited expression to the disruption of normal school activities or fixed times such as when school is in session. The Supreme Court also found it concerning that the statute prohibits speech only directed at public school officials that could be perceived as negative or unfavorable and not based on substantive content or the message. The Supreme Court viewed that as overbroad because as written, the plain language of the statute suggests that any person who speaks critically to school officials at any time in the presence of minors would be forced to leave the premises when ordered by a school official or face arrest. This was seen as silencing the speaker. The Supreme Court reversed the judgment of the trial court. The Supreme Court noted that while it has the authority to narrow a statute to avoid unconstitutional infirmities, it does not have the authority to rewrite statutes. The statute does not regulate unprotected speech nor is it appropriately tailored to meet its intended objective and is overbroad.

Summary of Case Context & HoldingPlaintiff, an employee, suffered a severe work-related injury. He received temporary total disability benefits under Florida's worker compensation law for the maximum statutory period allowed, 104 weeks. Plaintiff was not fully healed prior to the expiration of the 104-week limit. He filed a petition for continuation of disability benefits, but was denied by a lower court because his doctors determined that his health may continue to improve and as such, the Jude of Compensation determined Plaintiff was not eligible for permanent disability benefits. Plaintiff appealed, challenging the constitutionality of the law as applied to him as an unconstitutional denial of access to courts. The Florida Supreme Court sided with Plaintiff and held the Florida state law unconstitutional, as applied to Plaintiff and similarly disabled people, because its application created a statutory gap in benefits in violation of the constitutional right of access to courts for employers since it cut employees off from receiving benefits at a time when they are still totally disabled but the worker's doctors, chosen by the employer, deem that the worker may still continue to medically improve and is, therefore, not entitled to permanent disability benefits.

Summary of Case Context & HoldingAfter White Bear Lake's water levels reached historic lows, two associations sued the Minnesota Department of Natural Resources (DNR) for pollution and impairment of the lake, primarily arising out of alleged mismanagement of the groundwater-appropriation permitting process. Both associations brought claims under Minn. Stat. § 116B.03 (2018), part of the Minnesota Environmental Rights Act (MERA), and one association brought a claim under the common-law public trust doctrine. The Court held that both Appellant associations had stated a claim under MERA and that the principle of agency deference did not apply, reversing the Appeals Court decision. The Court further held that the Appellant homeowners association did not state a claim under the common-law public trust doctrine. The Court declined to extend the doctrine in the absence of allegations that the DNR had violated its duty as a trustee to protect public use from "private interruption and encroachment," or that water had been diverted outside the state.

Summary of Case Context & HoldingEmployers, home health services providers, brought separate actions against employees for allegedly violating the non-compete clauses of their employment contracts with home health care companies. The cases were eventually consolidated. The Florida Supreme Court was asked to determine whether, under Florida law, home health service referral sources can qualify as a "legitimate business interest" such that they justify a non-compete clause in an employment agreement. The Florida Supreme Court ruled that home referrals to home health services, which are extremely important to the home health care industry, can be a "legitimate business interest" under Florida law depending upon the context and proof adduced. The cases were remanded to the relevant district courts for a determination as to whether the referrals at issue constituted a "legitimate business interest."

Summary of Case Context & HoldingIn 2021, the Texas Legislature passed and the Texas Governor signed into law Senate Bill 8, known as the “Texas Heartbeat Act.” This Act prohibited physicians from performing abortions if a fetal heartbeat could be detected. To enforce the Act’s requirements, the Act provided a private civil action that permitted any private individual who was not a state official to bring an action against those performing abortions or anyone who aids them in performing an abortion for injunctive relief, as well as a statutory damages award of at least $10,000. Whole Woman’s Health was an abortion provider who sued in federal court seeking a declaration that the Heartbeat Act unconstitutionally restricted their rights, as well as an injunction prohibiting Defendants from enforcing the requirements of the Act. Defendants to the case included state officials and executive directors of the Texas Medical Board, Board of Nursing, and the Board of Pharmacy, as well as the executive commissioner of the Texas Health and Human Services Commission. The state-agency executives moved to dismiss the lawsuit primarily on grounds of sovereign immunity and lack of standing, arguing that the Heartbeat Act itself does not permit them to enforce it. After the district court denied the motion to dismiss, the Fifth Circuit certified a question to the Texas Supreme Court to determine whether Texas authorized state officials to directly or indirectly enforce the Heartbeat Act. The Court first considered whether the Heartbeat Act authorizes the state-agency executives to have direct enforcement authority. The Court reviewed the text of the law, and held that the text “unambiguously confirm[s]” that the executives did not have authority to bring a direct civil action, as the text specifically carved-out from those able to bring a civil action any “officer or employee of a state or local governmental entity in this state.” Further, the text of the Act prevents the State, any state official, or any district or county attorney from intervening as a party to an action brought under the Act. As a result, the state-agency executives sued did not have any direct enforcement authority. The Court then turned to the Plaintiffs’ argument that the Heartbeat Act authorizes the agency executives to indirectly enforce the requirements. As an example, the Texas Medical Board is required to take disciplinary action or deny a license to anyone who violates any state or federal law in the practice of medicine, while other agencies had similar provisions. The Court held that because the Act included language stating that its requirements “shall be enforced exclusively through” the civil action scheme it provided, state-agency executives were explicitly deprived of any authority to enforce the requirements of the Act through disciplinary actions. As a result, the Court held that Texas law did not grant any of the state-agency executives named in the case authority to enforce the requirements of the Act.

Summary of Case Context & HoldingFollowing a bench trial, the Defendant was found guilty of malice murder, felony murder, aggravated assaults and other related crimes, and was sentenced to life without the possibility of parole plus an additional 25 years in prison. Appellant contended the trial court's implicit denial, without inquiry or hearing, of his pre-trial request to represent himself was in error. The Supreme Court found that the trial court erred by failing to hold a hearing to determine whether Appellant's request to proceed pro se was knowingly and intelligently made and reversed his convictions. Both the U.S. and Georgia constitutions guarantee a criminal defendant the right to counsel and the right to self-representation. When a defendant asserts the right to self-representation, it is the responsibility of the trial judge to ensure that the decision to dismiss counsel and proceed pro se has been knowingly and intelligently made and that the defendant has made the choice to proceed without the benefit of counsel with “eyes open.” The Supreme Court held that the trial court's finding that Appellant failed to re-assert his right to self-representation at the start of trial was insufficient, by itself, to establish a proper waiver. Without affirmative evidence that Appellant wavered or equivocated in his desire to proceed pro se, the Supreme Court found that Appellant's mere silence was insufficient to establish a knowing and intelligent waiver of his already invoked right to self-representation. The trial court's failure to engage in the required Faretta v. California, 422 U.S. 806 (1975) colloquy (if trial court fails to fulfill its obligation to inform the defendant of the dangers and disadvantages of self-representation and then denies his request to represent himself, it violates the defendant's Sixth Amendment right of self-representation) and failure to rule on Defendant's unequivocal request amount to a violation of his constitutional right to self-representation, and as a result his convictions were reversed.

Summary of Case Context & HoldingWilbros, LLC operated a solid waste, recycling, composting, and waste water processing facility. Wilbros had entered into a civil consent order with the state Environmental Protection Division of the Department of Natural Resources for violating the Georgia Comprehensive Solid Waste Management Act due to ongoing odor nuisance conduct. Wilbros was charged with criminal charges for the same behavior after the consent order. The Supreme Court held that double jeopardy is an available, potential defense to LLCs; however, this case was not barred by double jeopardy because the consent order was civil in nature and differed from the penalties associated with criminal proceedings.

Summary of Case Context & HoldingThe Supreme Court found that where Plaintiff-employee sustained significant physical injuries as a result of an automobile accident that occurred during the course and scope of his employment, and Defendant-employer filed a Form 60 (Employer's Admission of Employee's Right to Compensation) accepting that Plaintiff had suffered compensable injuries by accident and began paying temporary total compensation and medical compensation for his injuries, the Industrial Commission (an agency of the state of North Carolina that administers among other things the state's Workers’ Compensation Act) erred by failing to give Plaintiff the benefit of a presumption that the additional medical treatment he sought was for conditions related to his compensable injuries. Plaintiff was entitled to a presumption that additional medical treatment for tinnitus (a ringing or buzzing noise in one or both ears that may be constant or come and go, often associated with hearing loss), anxiety, and depression were related to his compensable conditions. Additionally, the Supreme Court found the Industrial Commission erred by failing to address the effects of Plaintiff's tinnitus in determining whether he lost wage-earning capacity. The case was remanded to the Industrial Commission for findings addressing Plaintiff's wage-earning capacity, considering Plaintiff's compensable tinnitus in the context of all the preexisting and coexisting conditions bearing upon his wage-earning capacity.

Summary of Case Context & HoldingPlaintiff voters sought to invalidate the Montana Districting and Apportionment Commission's (Commission) assignment of two "holdover senators" in its final 2013 redistricting plan, and sued the State of Montana and the Secretary of State to void the plan. A "holdover senator" is a senator elected under the old districting system who must be assigned to a redrawn district to serve the final two years of his or her term. A "holdover senator" is, therefore, not required to seek election at the general election held immediately following implementation of the districting plan. In 2010, Llew Jones (Jones) was elected to the Montana Senate in District 14, but after the districts were redrawn, his residence was in District 9. The Commission then assigned another Senator, Senator Ripley, to District 9, such that Jones would not be able to run for re-election until 2016. Government and community leaders sent letters to the Commission asking it to assign Jones to a senate district in which he could run in 2014. Prior to the Commission's final meeting on February 12, 2013, the Commissioners talked one-on-one about these public requests, and voted to assign Ripley to Senate District 10 and Senator Hamlett to Senate District 15. Because of these assignments, District 9 had no "holdover senator," and Jones would be able to run there in 2014. The Commission gave an opportunity for public comment at this final meeting, of which there was none, and then adopted and submitted the final redistricting plan. Plaintiff sought injunctive and declaratory relief, alleging in relevant part that the State of Montana had violated their right of suffrage and participation under the Montana Constitution, and had failed to permit public observation of the Commission's deliberations. The district court granted the State's motion for summary judgment. On appeal, the Supreme Court agreed, finding that Montana's open-meeting statute, Mont. Code Ann. § 2-3-201, applies to "meetings" and does not include "serial one-on-one discussions," such that the Commissioners' one-on-one discussions prior to the February 12 meeting were not subject to these requirements, absent evidence that a majority of Commissioners had reached an agreement during that time. The Supreme Court also held that voters’ right of participation, protected under Article 8 of the Montana Constitution, was not violated because the Commission was not a "governmental agency," and thus, was not subject to the requirements of Article 8. Lastly, the Supreme Court dismissed Plaintiff's right of suffrage claim under Article 13 of the Montana Constitution, pursuant to which Plaintiffs alleged that their right of suffrage was violated because 95% of District 15's population will have to wait six years between senate elections. Recognizing that "the shuffling of legislators is a necessary byproduct of the redistricting process when senators serve staggered four-year terms," the Supreme Court held that striking the Commission's plan would not cure Plaintiff's claims and would merely shift the purported violation to another set of voters.

Summary of Case Context & HoldingSchool districts, individuals, and public education interest groups brought suit alleging that the state's public education financing scheme was unconstitutional under the state constitution's education clause. The clause reads that the General Assembly must "provide for the maintenance and support of a thorough and efficient system of public education." Petitioners argued that Pennsylvania's hybrid state-local approach created funding disparities between wealthier and poorer districts. Petitioners further argued this approach violated Pennsylvania's Equal Protection clause. The commonwealth court granted a motion to dismiss at the pleading stage, ruling that petitioners' claims were non-justiciable political questions. The Supreme Court reversed and remanded, finding each to be justiciable claims under the political questions doctrine outlined in the U.S. Supreme Court's decisions in Nixon v. United States, 506 U.S. 224 (1993) and Baker v. Carr, 369 U.S. 186 (1962), as there are judicially manageable standards to resolve the claim, there is not a textually demonstrable commitment to a coordinate branch to handle the claims, and no unusual need for adherence to a political decision already made or the potential for embarrassment that may arise out of two different answers from various departments on one question.

Summary of Case Context & HoldingAmy Elizabeth Williams filed a wrongful death lawsuit individually and as the personal representative of her deceased minor child’s estate, against Quest Diagnostics, Inc., Athena Diagnostics, Inc., and ADI Holdings, Inc. (Defendants), alleging that the Defendants' genetic testing laboratory failed to properly diagnose her child's genetic condition. Williams's child suffered from seizures, prompting the treating physician to send DNA samples to Defendants’ genetic testing laboratory to diagnose the child’s disorder. Williams alleged that due to Defendants’ inaccurate genetic testing, the child’s condition was improperly diagnosed, resulting in the child’s death. The case was initially filed in the United States District Court for the District of South Carolina. The federal court then certified to the South Carolina Supreme Court the following question: whether a federally licensed genetic testing laboratory performing diagnostic tests at the request of a treating physician qualifies as a "licensed health care provider" under South Carolina Code § 38-79-410. The South Carolina Supreme Court answered the certified question affirmatively, holding that a federally licensed genetic testing laboratory performing genetic tests at a treating physician's request for diagnostic purposes qualifies as a "licensed health care provider" under South Carolina law. The Court reasoned that such laboratories provide essential diagnostic services for the purpose of diagnosis and treatment, which is a core function of hospitals in diagnosing and treating patients, thereby falling within the statute's category of "hospital." Justice Hearn dissented, arguing that genetic testing laboratories differ fundamentally from traditional health care providers, as they do not provide direct patient care or make conclusive treatment decisions and thus should not be classified as "licensed health care providers."

Summary of Case Context & HoldingFollowing a drug dispute that led to a murder, Williams was convicted of first-degree murder. The jury "verdict form did not require the jury to specify the theory upon which it found Williams guilty of first-degree murder." The trial court sentenced Williams to life in prison with the possibility of parole in twenty-five years. Williams was sixteen at the time of the murder. The Supreme Court addressed the question of whether Alleyne v. United States, 570 U.S. 99 (2013) (holding that any fact that increases the mandatory minimum sentence must be found by a jury beyond a reasonable doubt), requires the jury and not the trial court to make the factual finding under Section 775.082(1)(b), Florida Statutes (2016), as to whether a juvenile offender actually killed, intended to kill, or attempted to kill the victim. In Florida, if the jury is to find that a juvenile offender actually killed, attempted to kill, or intended to kill, then there is a forty-year minimum sentence with a sentence review in twenty-five years. Without this finding, there is no minimum, and the juvenile is entitled to a sentence review in fifteen years if the sentence is greater than that. In this case, it is unclear whether the jury found Williams guilty of premeditated murder, felony murder, or both. As such, it cannot be determined whether the jury found beyond a reasonable doubt that Williams actually killed, intended to kill, or attempted to kill. The Supreme Court held that Alleyne requires the jury to make the factual finding under Section 775.082(1)(b) as to whether a juvenile offender actually killed, intended to kill, or attempted to kill the victim. The Supreme Court also concluded that although Alleyne violations are subject to harmless error review, the violation at issue is not harmless, and therefore, Williams is entitled to resentencing under Section 775.082(1)(b)2.

Summary of Case Context & HoldingWilliams was found guilty of first-degree murder and attempted first-degree murder following an altercation involving Williams, his cousin, and two men (Brown and Johnson) from a nearby neighborhood. Williams alleged that he acted in self-defense after the two men followed him and his cousin and appeared to be carrying a weapon. The State’s theory of the case was that Williams and Felton attempted to rob Brown and therefore could not claim self-defense because the altercation was a result of the robbery. The jury did not convict Williams of robbery but did find that he was guilty of the lesser included offense of theft. The district court therefore affirmed Williams’ convictions and sentences. On appeal to the Supreme Court, Williams argued that the trial court erred in denying his motion for a judgment of acquittal. In a case where a defendant alleges self-defense, the State must prove that the defendant did not act in self-defense beyond a reasonable doubt. A trial court must grant a judgment of acquittal when the State’s case is legally insufficient to rebut a defendant’s prima facie case establishing self-defense. In order to establish a prima facie case of self-defense, a defendant must show that he (1) was attacked in a place where he had a right to be; (2) was not engaged in any unlawful activity; and (3) reasonably believed it was necessary to use force to prevent death or great bodily harm. Here, the Supreme Court determined that the evidence found at the scene supports Williams’ version of events and that Williams had presented a prima facie case of self-defense. Because the State failed to rebut this theory, the trial court improperly denied Williams' motion for a judgment of acquittal as to the charge of first-degree premeditated murder. Williams’ self-defense theory was only applicable if the jury did not find that the altercation began because of a robbery attempt. Once the jury entered its verdict finding Williams guilty of the lesser included offense of theft, logic dictates that the jury did not believe that the altercation began because of the robbery attempt. However, viewing the evidence in a light most favorable to the State, the trial court did not err in denying the motion as to a charge of attempted murder because the evidence and testimony provided at trial demonstrated that Williams hesitated before turning to shoot Johnson. A reasonable jury could have concluded that the shot fired at Johnson was not fired in self-defense.

Summary of Case Context & HoldingA grand jury indicted Defendant for attempted second-degree murder and other crimes. Defendant subsequently filed a motion arguing that the State withheld clearly exculpatory evidence of a justification defense that it was obligated to present despite the evidence not being requested by the defense. The trial court denied the motion, reasoning that the testifying detective did not present false or misleading testimony nor exclude anything exculpatory before the grand jury. The Supreme Court reversed, holding (1) the Arizona Constitution guarantees a person under grand jury investigation a due process right to a fair and impartial presentation of clearly exculpatory evidence, and a prosecutor has a duty to present such evidence to a grand jury even in the absence of a specific request; (2) where there is evidence relevant to a justification defense that would deter a grand jury from finding probable cause the prosecutor has an obligation to present such evidence; and (3) the State failed to present clearly exculpatory evidence, denying Defendant a substantial procedural right.

Summary of Case Context & HoldingAs enacted, the South Carolina 2021-2022 Appropriations Act contained a variety of provisos prohibiting the use of appropriated funds to enforce mask mandates in public settings. Proviso 1.108 prohibited mask mandates funded by the Act in K-12 public schools. Following the enactment of the Act, the City of Columbia passed ordinances mandating face coverings in all K-12 public schools in the city. The Attorney General of South Carolina petitioned the Supreme Court to review the City ordinances and their legality in light of Proviso 1.108. On review, the Court considered whether 1.108 violated the "one-subject" rule of the South Carolina Constitution, which requires that every act or resolution of the General Assembly must only relate to one subject. Here, the City of Columbia argued that the imposition of a face covering mandate in schools was not related to the fiscal issues included in the Appropriations Act, making 1.108 in violation of the one-subject rule and, therefore, unconstitutional. The Court disagreed, finding that because 1.108 specifically prohibited the use of funds appropriated under the Act to impose such a mandate, the legislative construction of 1.108 was constitutional and solely confined to a single subject. The City alternatively argued that the ordinances would not conflict with state law as the City itself would fund and enforce any mask mandate. The Court disagreed with this proposition as well, finding that because the scope of the ordinances applied a legal obligation to enforce the mandate to all school employees, all of whom were connected to state-approved funds, it was impossible for the City to claim that there would be no conflict with a restriction against such a mandate. Finally, the Court held that the protections of the Home Rule Act, which grants municipalities plenary authority over the health, peace, and order of their citizens, did not apply, as the Home Rule doctrine did not permit a municipality to contradict the state legislature merely by declaring a state of emergency (as the City had). Justice James and Justice Hearn wrote concurrences, the latter only as to the result, taking issue with the majority's unnecessary opining beyond the legal challenge posed.

Summary of Case Context & HoldingA farm owners' insurer brought action against the insured, Robert and Jane Falk, their neighbors, and the Department of Natural Resources asserting that it owed no duty to defend or indemnify against neighbors' claims that manure from the farm polluted water wells. The Supreme Court held that manure was a "pollutant" within the meaning of the pollution exclusion in Wilson Mutual's General Farm Coverage Liability policy; that each well contamination was an "occurrence" of pollution; that the pollution exclusion in the "Farm Chemicals Limited Liability" endorsement of the insurance policy applied; and that the insurer owed a duty to defend under incidental coverage of $500 per occurrence of damage to the property of others. The Supreme Court relied on the three-step test provided in American Family Mutual Insurance Co. v. American Girl, Inc., 673 N.W.2d 65 (Wis. 2004) for determining whether coverage exists under an insurance policy. First, the Court will examine the facts of the insured's claim to determine whether the policy makes an initial grant of coverage. Second, if the claim triggers an initial grant of coverage the Court will examine whether any of the policy's exclusions preclude coverage. Third, if an exclusion precludes coverage, the Court will analyze exceptions to the exclusion to determine whether any exceptions reinstate coverage. In the Falks' case, they sought coverage for each instance where one of their water wells was contaminated by manure. The insurance coverage in this case hinged on whether manure could be considered a pollutant when it seeps into the well. The Supreme Court found "that manure is unambiguously a pollutant when it seeps into a well." Therefore, the insurance policy applied, and Wilson Mutual was required to cover the incidents of pollution.

Summary of Case Context & HoldingHappy Creek, Inc. (Happy Creek), a ranching and farming company that operated Happy Creek Ranch (Ranch) in the Pine Forest groundwater basin in northern Nevada, filed a petition for judicial review of the determination of the State Engineer after the State Engineer reset the effective dates of appropriation under permits following rescission of water rights permit cancellation. Happy Creek also sought equitable relief in restoring its groundwater rights' original senior priority dates. The lower court restored Happy Creek’s original senior priority dates and the State Engineer appealed. The Supreme Court held that the district court had authority to grant Happy Creek equitable relief from State Engineer's non-discretionary duty to reset priority dates, and that the lower court acted within its discretion in granting Happy Creek equitable relief by restoring original priority dates.

Summary of Case Context & HoldingThe State Engineer promulgated an order that prohibited the drilling of new domestic wells in the over-appropriated Pahrump Artesian Basin unless applicants could identify 2 acre-feet (units measuring volume of water) from an alternate source annually. The district court found that the State Engineer violated due process without first providing notice and a public hearing of the order and the State Engineer lacked authority to issue the order. The Supreme Court reversed, holding notice and public hearing were not required under the circumstances and that Nevada law authorized the 2 acre-feet requirement. The Court found that the State Engineer had statutory authority to promulgate the order and due process was not violated because water is a public resource, not private property.

Summary of Case Context & HoldingLance Windrum was admitted to the North Cypress Medical Center following a period of disorientation and confusion that resulted in a head injury. Following tests, doctors diagnosed Windrum’s symptoms as relating to issues of fluid build-up and pressure in the brain. Though a shunt was originally recommended, a neurosurgeon instead chose to insert a drain to monitor intracranial pressure. Windrum’s condition worsened, and he died in his sleep three months later. An autopsy found that the issues originally found in Windrum’s original admittance to the hospital were also the cause of his death. Windrum’s wife (Plaintiff) sued the neurosurgeon and the originally presiding doctor, among others, alleging claims of medical malpractice. The jury ruled in favor of the Plaintiff and awarded $1.9 million in damages to her and her children. The neurosurgeon appealed, and the court of appeals held that the Plaintiff’s expert witness had presented conclusory testimony and that the Plaintiff had presented insufficient evidence otherwise to support a claim of malpractice. The Supreme Court first reviewed in detail the provided expert testimony to consider whether it was conclusory. The Court noted that the expert had repeatedly walked the jury through key medical issues at hand, discussed and provided sources that supported his viewpoint, and suggested his own analysis of the facts. Throughout the trial, the expert had relied on data from Windrum’s treatment, and did not simply ask the jurors to take his analysis as fact. The Court ultimately held that the court of appeals erred in reversing the trial court, as the expert testimony presented by the Plaintiff sufficiently supplied the jury with facts and analysis to support the jury's decision.

Summary of Case Context & HoldingDefendant pled guilty to six counts of violating Georgia’s Street Gang Terrorism Prevention Act in connection with a drive-by shooting and was sentenced to 10 years in prison and 10 years of probation. Defendant appealed, arguing that the trial judge improperly participated in plea negotiations in violation of Uniform Superior Court Rule 33.5(A), which states that“[j]udicial participation in plea negotiations is prohibited as a constitutional matter when it is so great as to render a guilty plea involuntary” and that his plea was involuntary on the basis of that participation. The Supreme Court held that the trial court’s repeated comments communicated to Defendant, whereby the trial judge indicated that if Defendant rejected the plea offer and was found guilty by a jury he would receive a harsher sentence, made his guilty plea involuntary. The Supreme Court reversed Defendant's convictions.

Summary of Case Context & HoldingA student, diagnosed with dyslexia, sued a private Catholic school in Michigan, under the Persons With Disabilities Civil Rights Act because they were denied admission to the school. The school argued that the court did not have subject matter jurisdiction because the ecclesiastical abstention doctrine prohibited a court from reviewing admissions decisions of religious institutions because the decisions of the school were too entangled with matters of religion. The Supreme Court held that, while the ecclesiastical abstention doctrine informs how civil courts must exercise jurisdiction over claims with ecclesiastical questions, it does not deprive courts of subject matter jurisdiction altogether. The Supreme Court reasoned that, under the doctrine, the question a court must answer is whether the actual adjudication of a particular legal claim would require the resolution of ecclesiastical questions. Therefore, the doctrine is a case specific inquiry about how a court should adjudicate claims that are within its subject matter jurisdiction and is not a matter of whether the court has jurisdiction in the first place. Further, the Supreme Court found that the circuit court had subject matter jurisdiction over the claim at the religious institution and had the power to consider whether it should be decided by the court under the ecclesiastical doctrine.

Summary of Case Context & HoldingPetitioner, Louis Michael Winker, was convicted of murder and originally sentenced to capital punishment. Following his conviction, Petitioner sought post-conviction relief (PCR) alleging ineffective counsel in his original trial and sentencing phase for (i) counsel’s failure to object to the trial court’s refusal to answer repeated questions from the jury about the consequences of a failure to reach a unanimous verdict in a case involving capital punishment; and (ii) counsel’s failure to investigate mitigating evidence related to Petitioner’s possible brain damage/mental incapacity. The PCR court found that Petitioner’s counsel was ineffective for failure to object to the trial court’s refusal to inform the jury of the consequences of a failure to reach a unanimous verdict, but denied Petitioner’s motion requesting additional time to bring evidence of his brain damage finding that Petitioner failed to meet his burden of proving ineffective counsel for failure to investigate mitigating evidence. The Supreme Court granted certiorari and (i) reversed the PCR court's holding that Petitioner's counsel was ineffective; and (ii) reversed the PCR Court's denial of Petitioner's second motion for additional time to bring evidence of his brain damage. On the question of the effectiveness of Petitioner's counsel, the Supreme Court reviewed the PCR Court's holding under a two-prong test set forth in Strickland v. Washington, 466 U.S. 668 (1984) which requires that an application show that (1) counsel's representation fell below an objective standard of reasonableness; and (2) but for counsel's error, there is a reasonable probability that the outcome of the proceeding would have been different. On appeal, Petitioner cited South Carolina Code subsection 16-3-20(C) (2015) ("If members of the jury after a reasonable deliberation cannot agree on a recommendation as to whether or not the death sentence should be imposed on a defendant found guilty of murder, the trial judge shall dismiss such jury and shall sentence the defendant to life imprisonment as provided in subsection (A)"), due process, and Eighth Amendment arguments to claim that counsel's failure to object to the trial court's refusal to answer the jury's questions fell below an objective standard of reasonableness in the representation of Petitioner. The PCR Court agreed with Petitioner, but the Supreme Court found instead that neither subsection 16-3-20(C) or any applicable South Carolina or federal precedent requires the trial judge to disclose the consequences of the jury failing to reach a unanimous verdict on sentencing. As a result, Petitioner's counsel was not ineffective, as there was no legal basis requiring the trial judge to inform the jury of the consequence of their failure to reach a unanimous verdict. Accordingly, the Supreme Court found the PCR court's holding to be an error of law, and that prong (1) of the Strickland test was not satisfied. Regarding Petitioner's motion for additional time to bring evidence of his brain damage, the Supreme Court found that while South Carolina code requires expediting the scheduling of PCR trials in death penalty cases, including scheduling PCR trials within 180 days from the date of the status conference, the code also provides an exception to the PCR trial scheduling timeline in cases where "good cause is shown to justify a continuance." See S.C. Code Ann. 17-27-160(C). Here, the Supreme Court found that Petitioner's counsel had properly demonstrated good cause by promptly informing the Court of the need and timeline for Petitioner's neuroimaging, which would be of relevance to the PCR trial, and that the PCR court's rejection of counsel's motion for additional time was an abuse of discretion.

Summary of Case Context & HoldingCharles Carlson was fired for actions taken while having a bipolar episode. He subsequently alleged that Wisconsin Bell, Inc. had terminated him with intentional discrimination. The Labor and Industry Review Commission sided with Carlson and found that Wisconsin Bell violated the Wisconsin Fair Employment Act. Wisconsin Bell appealed, and the Supreme Court held that Wisconsin's law against disability discrimination in employment requires proof of intent to establish liability—namely, an employer does not engage in illegal disability discrimination when an adverse action is based on employee conduct unless the employer knows that the disability caused the conduct. Employees must prove a discriminatory intent. Here, the Supreme Court held that Carlson was unable to prove discriminatory intent because he did not present sufficient evidence to show that Wisconsin Bell knew of the causal connection between the disability and the workplace conduct.

Summary of Case Context & HoldingWisconsin enacted a law in 2011 that allowed residents to carry concealed weapons with a license. The City of Madison, however, had a commission that prohibited guns on buses. Plaintiff, a gun rights organization filed suit to resolve the discrepancy (in favor of the state law). The Supreme Court held that state law preempts local law as applied to the regulation of weapons. The City of Madison's transit authority cannot bar concealed carry-license holders from bringing certain weapons on city buses.

Summary of Case Context & HoldingOn April 16, 2020, Andrea Palm, Department of Health Services (DHS) Secretary designee issued Executive Order (EO) 28, which commanded all individuals in Wisconsin to stay at home or at their place of residence with certain limited exceptions approved by Palm or risk punishment. This EO was not issued by the Governor, nor did it rely on the Governor's emergency declaration. Rather, it relied solely on the authority vested in Palm by the laws of the State, including but not limited to Wis. Stat. § 252.02(3), (4), and (6), which provided legislative authorities to DHS. The dispute in this case involved whether the Secretary-designee of DHS issued an EO in violation of the laws of Wisconsin. The Supreme Court held that EO 28 was a rule and therefore subject to statutory emergency rulemaking procedures established by the Legislature. The rulemaking procedures of Wis. Stat. § 227.24 were required to be followed but they were not, so EO 28 was unenforceable. Therefore, no criminal penalties for violations of EO 28 were to be upheld. Although the Secretary-designee was not without power to act in the face of the COVID-19 pandemic, her order confining all people to their homes, forbidding travel and closing businesses exceeded the statutory authority of Wis. Stat. § 252.02.

Summary of Case Context & HoldingThe Milwaukee Journal Sentinel made public records requests to Department of Health Services for certain documents related to the COVID-19 pandemic. After learning that DHS planned to respond by releasing a list of "all Wisconsin businesses with over 25 employees that have had at least two employees test positive for COVID-19 or that have had close case contacts that were investigated by contact tracers" and the number of such tests or contacts at each business, Wisconsin Manufacturers and Commerce and two other trade associations brought an action seeking declaratory and injunctive relief to stop the release. The Supreme Court held that trade associations could not maintain an action seeking declaratory and injunctive relief to prevent the Wisconsin's DHS from releasing information about positive COVID-19 tests or close contacts at identified businesses because the prohibition in Wis. Stat. § 19.356(1) against pre-release judicial review of decisions to provide access to public records eliminated the common-law right to pre-release judicial review. Pre-release judicial review is the ability of a judicial officer to review the conditions of release previously ordered and set new or additional conditions prior to release.

Summary of Case Context & HoldingTwo labor unions, the Service Employees International Union and the Wisconsin Association of State Prosecutors, sought a declaration that Wis. Admin. Code chs. ERC 70 and 80 were invalid. These two unions argued that the requirement that labor organizations file a petition for election as a condition precedent to holding a certification election irreconcilably conflicts with the statutory mandate under Wis. Stat. §§ 111.70(4)(d)3.b. and 111.83(3)(b) that the Wisconsin Employment Relations Commission (WERC) hold annual certification elections. Consequently, these two unions sought writs of prohibition preventing the WERC from enforcing those rules and refusing to conduct certification elections. The Supreme Court considered whether (1) WERC exceeded its statutory authority under Wis. Stat. ch. 111 when it promulgated Wis. Admin Code chs. ERC 70 and 80; and (2) whether WERC may decertify a current representative labor organization if that organization fails to file a petition by September 15, the deadline for a timely petition under Wis. Admin. Code §§ ERC 70.03(7)(a) and 80.03(7)(a). The Supreme Court held that WERC did not exceed its authority because it has express authority under Wis. Stat. ch. 111 to promulgate rules that require a demonstration of interest from labor organizations interested in representing collective bargaining units, and that WERC may decertify a current representative labor organization on September 15, or at the expiration of the collective bargaining agreement, whichever occurs later, where there are no timely petitions for election filed.

Summary of Case Context & HoldingValerie Beres was denied unemployment benefits by the Department of Workforce Development after being fired for violating an employer's absenteeism policy on the grounds that this violation constituted impermissible misconduct. Beres challenged that denial before the Labor and Industry Review Commission (LIRC), which held that Beres was improperly denied benefits because her absenteeism did not rise to the level of disqualifying misconduct. Specifically, while Beres violated her employer's policy, LIRC found that Beres did not violate the "2 in 120" standard of Wis. Stat. § 108.04(5)(e), which holds that only absenteeism on "more than 2 occasions within the 120-day period before the date of the employee's termination" is misconduct that can lead to the denial of unemployment benefits. The Department of Workforce Development appealed. The Supreme Court held that the plain language of Wis. Stat. § 108.04(5)(e) allowed employers to create standards more stringent than those of the statute, and thus termination of an employee stemming from the violation of an employer's absenteeism policy could result in disqualification for unemployment benefits even if the employer's policy was stricter than the statute.

Summary of Case Context & HoldingDefendant was indicted on two charges of malice murder and one charge of armed robbery and was sentenced to three consecutive life sentences. Defendant moved for a new trial and contended that the trial court erred when it determined that the State did not violate Batson v. Kentucky, 476 U.S. 79 (1986) when it struck an African-American female juror. Because the State sought the death penalty in this case, attorneys asked prospective jurors during voir dire to rate themselves with respect to their feelings about the death penalty. At the conclusion of voir dire, Appellant raised a violation of Batson based on race. The trial court determined a prima facie case had been made and the State was required to come forward with a nondiscriminatory rationale for its strikes, and found the State's rationale to be race-neutral. The Supreme Court found no error, noting that the "death penalty scale" questions were not the same from juror to juror, and there was no evidence that two Caucasian males who were not struck, but rated low on the scale of willingness to impose the death penalty, made a statement to the effect that all life was precious like the subject juror.

Summary of Case Context & HoldingWright was a candidate for Mayor of Miami Gardens. One day before the qualifying period for candidacy ended, Wright tendered to the City Clerk of the City of Miami Gardens a check for $620.00, which was the required qualifying fee amount. The City Clerk accepted the check and issued Wright a receipt. The City Clerk was later notified by the City's Finance Department that Wright's check had been returned due to a banking error. Wright then received an e-mail informing him that he had been disqualified from the election because the check was not received within the time period required by a provision of the Florida Election Code. The Florida Supreme Court concluded that the Code unambiguously required disqualifying Wright, but also struck down the statute as inconsistent with the Florida Constitution. It held that disqualifying a candidate solely because of an error of a third-party bank was "unreasonable and unnecessary, as well as plainly irrational," and that it was an "unnecessary restraint on one's right to seek elective office." The Court reopened the period for Wright's qualification and, assuming he qualified, that his name be placed on the ballot for the next election.

Summary of Case Context & HoldingPetitioner WVMF Funding's predecessor brought an action against Respondent Luisa Palmero (Mrs. Palmero) to foreclose on a reverse mortgage taken out by Respondent's late husband. Mrs. Palmero defended against the foreclosure action by "arguing that Mrs. Palmero, who continued to principally reside in the mortgaged property, was a co-borrower under the mortgage[,]" and thus, that the foreclosure was inappropriate. Her status as a co-borrower was critical because the debt could only be enforced if a borrower dies and the mortgaged property was not the principal residence of a surviving borrower. The circuit court denied foreclosure and the Third District Court of Appeals affirmed, finding that the location of Mrs. Palmero's signature on the mortgage unambiguously and as a matter of law made her a co-borrower under the mortgage, and thus, precluded foreclosure. The Supreme Court reversed, finding Mr. Palmero was the sole borrower. The Supreme Court reasoned that the general rule in foreclosure actions is that a mortgage should be construed together with the note that it secures. Here, both the mortgage and note expressly defined Mr. Palmero as the "Borrower[,]" and because the note resolves any conflict created by Mrs. Palmero's signing her name in the “Borrower” signature block of the mortgage, the Supreme Court concluded no further inquiry was required.

Summary of Case Context & HoldingThe Wynn Las Vegas, implemented a tip-pooling policy for its table-games employees under which all tips were gathered and divided among the dealers, boxpersons, and casino service team leads. Several employees filed a class-action complaint with the Labor Commissioner claiming that Wynn's tip-pooling policy violated NRS 608.160, NRS 608.100, and NRS 613.120, because it required the dealers to share their tips with employees of different ranks. The Supreme Court held that Nevada law permits the tip-pooling policy since the Wynn distributed all the tips to its employees and NRS 608.160 prohibits an employer from taking and keeping his or her employees' tips, but does not prohibit a tip policy that splits the tips among employees.

Summary of Case Context & HoldingXcel Energy Services sought review of the Labor and Industry Review Commission's (LIRC) decision that an employee who claimed workers' compensation benefits for sustaining permanent. LIRC had utilized the "odd lots" doctrine, which allows workers to be deemed totally and permanently disabled even if they are occasionally capable of earning an income. The Supreme Court affirmed LIRC's decision in favor of total permanent disability and ratified an evidentiary standard based on whether there was "credible and substantial evidence" of the permanent disability on which a reasonable person could rely. The Supreme Court further held that LIRC was within its authority to depart from an administrative law judge's order, who had ruled that the employee was only partially disabled.

Summary of Case Context & HoldingPlaintiff was a Deputy Sheriff who brought suit against the Sheriff for wrongful termination, alleging that she was fired because she had not contributed to the Sheriff's campaign for reelection. In return, the defendant Sheriff argued he would have terminated Plaintiff regardless. The Supreme Court held that Plaintiff was not a county employee as it was defined in NCGS section 153A-99 and therefore was not entitled to the statute's protections and was not terminated in violation of public policy. The Court additionally held that the Defendant Sheriff's action did not violate the Plaintiff's freedom of speech rights. By standing in the elected sheriff's shoes, a deputy sheriff fills a role in which loyalty to the elected sheriff is necessary to ensure that the sheriff's policies are carried out. Mutual confidence and loyalty between a sheriff and a deputy are crucial to accomplishing the sheriff's policies and duties, and thus the dismissal of Plaintiff based on political considerations was permissible.

Summary of Case Context & HoldingHamza Zalyaul pled guilty to attempted sexual assault of his 11-year-old family friend several times when Zalyaul was 14 years old. The assaults were reported, but the police could not take action because Zalyaul and his family had relocated to Morocco. After the State learned Zalyaul had returned to Nevada and was living in Las Vegas, the State charged Zalyaul (then 21 years old) with six counts of sexual assault with a minor under 14 years of age. The state recommended probation, but the Court sentenced Zalyaul to 48 to 120 months in prison. Zalyaul appealed, arguing that the district court lacked subject matter jurisdiction. On appeal, the Court held that "when a child under the age of 16 commits a delinquent act but is not charged until after turning 21, no court has jurisdiction to hear the case" under Nev. Rev. Stat. § 62B.335(1)(a). Accordingly, the Court vacated the judgment of conviction for lack of subject matter jurisdiction.

Summary of Case Context & HoldingA mother and her 16-month-old child sued a hospital and various members of the staff over treatment, and inadequate follow-up treatment, that the child had received in the hospital's emergency room following a parrot bite sustained on his finger. When dressings were removed, it was discovered that improper changing of bandages and attention to the wound by staff had caused the condition of the finger to suffer, requiring partial amputation. Following the amputation, Plaintiffs brought suit under a claim of medical malpractice and professional negligence against the treating doctor and nurse, as well as vicarious liability against the care facilities. In support of their claim, the Plaintiffs filed an expert affidavit stating that the medical staff breached the standard of care by dressing the wounded finger too tightly. The affidavit never mentioned any treating professionals or the care facilities by name. The district granted a motion to dismiss filed by the Defendants, finding the expert affidavit deficient for not naming the Defendants, and denied the Plaintiffs' request to amend the complaint and expert affidavit. On appeal, the Supreme Court held that a complaint for medical malpractice and an expert affidavit must be read together when determining the affidavit's adequacy. As such, the district court had erred in finding that the expert affidavit was inadequate, and should have instead read the complaint and affidavit together to determine that any unnamed parties were the parties named in the complaint.