State Supreme Court Data Tracker

Summary of Case Context & HoldingThe Plaintiff-employee first filed a wrongful discharge suit against her employer, subsequently agreed to arbitration in connection with the wrongful discharge suit, and then amended her complaint to add a constitutional challenge to the Montana Wrongful Discharge from Employment Act (WDEA). Mont. Code Ann. § 39-2-901. Her constitutional argument was that she felt compelled to accept arbitration because the WDEA allows for an award of reasonable attorney fees against a party, thus depriving her of the right to a jury trial. Mont. Code Ann. § 39-2-914(5). The lower court dismissed her motion to amend due to a lack of subject matter jurisdiction under the WDEA, and found that the WDEA was constitutional. The Supreme Court affirmed the dismissal of the Plaintiff's motion and held that, under the WDEA, once the parties agree to arbitrate, arbitration becomes the exclusive remedy, and the courts lose subject matter jurisdiction. The Supreme Court then dismissed the Plaintiff-employee's lawsuit for lack of subject matter jurisdiction, since the constitutional challenge was only added after the employee had agreed to arbitrate.

Summary of Case Context & HoldingNatural gas well operator filed application for summary relief challenging DEP's interpretation of Clean Streams Law, which was granted by the commonwealth court. The Supreme Court affirmed in part and reversed in part lower court's decision. The Supreme Court found that Clean Streams Act civil penalty only applied when pollutants were discharged by the offender, not when previously-released contaminants "remained in the environment." This decision limits the DEP's ability to abate contamination by parties unwilling to remediate.

Summary of Case Context & HoldingThe Supreme Court reversed commonwealth court decision and concluded that Pennsylvania's Department of Environmental Protection's (DEP) authority to assess penalties against operator of natural gas wells under Clean Streams Law was properly subject to declaratory judgment action prior to enforcement of penalties, such that operator did not need to exhaust administrative remedies prior to bringing action. Because the effect of the challenged regulation was going to have a burdensome, immediate impact on the operator, the Court determined that it created a case or controversy justifying pre-enforcement judicial review. This decision allows violators of the Clean Streams Law to challenge the DEP's regulation of contaminants in water.

Summary of Case Context & HoldingThe Montana Department of Revenue (Department) sought to overturn an order granting summary judgment to Espinoza et. al. (Parents) and enjoining the implementation of a rule denying certain tuition-based tax credits to parents of children attending religiously-affiliated private schools. The Department was responsible for administering the new Tax Credit Program that provided taxpayers a dollar-for-dollar tax credit up to $150 based on the taxpayer's donation to a Student Scholarship Organization (SSO), which funded scholarships for students attending private schools meeting the definition of a Qualified Education Provider (QEP). The Department determined that under the Legislature's definition of QEP's, most were religiously-affiliated private schools. Worried that the Tax Credit Program aided sectarian schools in violation of Montana's Constitution, which barred any direct or indirect aid to sectarian schools, the Department adopted Rule 1 which excluded religiously-affiliated private schools from the Legislature's definition of QEPs. Plaintiffs, parents of children who attended religiously-affiliated private schools in Montana, successfully challenged Rule 1's implementation at the district court level as that court determined the credits did not involve the expenditure of money in the state's treasury and thus were not in violation of aiding sectarian schools. The Montana Supreme Court overturned the district court's decision and held that the Tax Credit Program aided sectarian schools in violation of the broad and strict prohibition in the Montana Constitution, and Rule 1 was unnecessary as the underlying legislation was unconstitutional and the Department exceeded its rulemaking authority by enacting the rule because it was inconsistent with the Legislature's broad definition of QEPs, which included religiously-affiliated schools. The Court reasoned that the Program indirectly pays tuition at religiously affiliated private schools by allowing parents to claim a tax credit instead of paying that amount of tuition to the QEP, even though parents cannot directly designate the scholarship funds to their own child or their school. Furthermore, under the Legislature's broad definition of QEPs, the majority of QEPs are private schools controlled by churches and these "[g]eneral tuition payments fund the sectarian school as a whole" in violation of the Montana Constitution's prohibition on aiding sectarian schools. The Department could not constitutionally implement the Tax Credit Program based on the Legislature's definition of QEPs, so the Court severed the Program from the remainder of the bill. The Court went on to hold that the Department's adoption of Rule 1 was futile as the underlying legislation was unconstitutional and the Department exceeded its rulemaking authority by significantly narrowing the scope of schools qualifying as QEPs in conflict with the Legislature's broad definition. The Supreme Court of the United States overruled the Montana Supreme Court's decision on the grounds that the application of the no-aid provision discriminated against religious schools and families whose children attend them in violation of the Free Exercise Clause of the U.S. Constitution. The Court determined that strict scrutiny applied because this application of the Montana Constitution's no-aid provision excluded religious schools from public benefits solely because of religious status, Montana's interest in creating greater separation of church and State protections than required by the U.S. Constitution did not qualify as a compelling interest under strict scrutiny, and thus, the Free Exercise Clause barred the application of the no-aid provision here.

Summary of Case Context & HoldingPlaintiff sought a writ of mandamus with the Supreme Court to request that Roger Roots, a Libertarian candidate for the office of Secretary of State, be removed from the general election ballot in light of his failure to comply with Mont. Code Ann. §§ 2-2-106, 13-37-225 and 13-37-226. Plaintiff claims that Roots violated Mont. Code Ann. § 13-37-226(1) when Roots failed to file several forms with the Commissioner of Political Practices (such as campaign finance disclosure reports). While affidavits submitted by the different parties reflect that Roots submitted one form late (but timely submitted the others), the Supreme Court found that "a delayed filing does not constitute a failure to file," and that because the requisite forms had now been filed, Plaintiff and members of the general public are not deprived of the right to examine such forms. The Supreme Court further stated that ruling otherwise would have been impractical because this would have required the court to enjoin the Secretary of State to direct each election administrator around the Montana to keep Roots' name from appearing on ballots that are already being processed and printed ("It is too late to take this action, as only ten days remain before printed ballots are due at the election administrator offices for mailing.") Plaintiff's petition was denied.

Summary of Case Context & HoldingRicardo Brenes’ family brought a wrongful death action on Brenes’ behalf against the Las Vegas police department alleging that Officer Sean Miller had used excessive force against Brenes by shooting and killing Brenes during an arrest. The trial court granted the police department’s motion for summary judgment, ruling that Officer Miller’s use of force was objectively reasonable under the law. In reviewing the trial court’s ruling, the Court applied the Lal v. California, 746 F.3d 1112, 1117 (9th Cir. 2014) factors where the use of force by a police officer will be considered objectively reasonable if (1) the decedent’s crime was severe; (2) the decedent posed an immediate threat to the officer’s safety; and (3) the decedent was in striking range of the officer. The Court found that there were still issues of material facts as to factors (1) and (2), and reversed the trial court.

Summary of Case Context & HoldingPlaintiff's estate (including decedent's parents and infant son) brought a medical malpractice action against the United States pursuant to the Federal Tort Claims act after decedent died of blood loss shortly after giving birth at an Air Force operated hospital. The U.S. District Court for the Northern District of Florida found the United States liable, but capped the damages available to plaintiff pursuant to Florida's statutory $1 million cap (no matter how many victims had a claim) on noneconomic damages arising from a wrongful death attributable to a medical malpractice claim. See Fla. Stat. Ann. § 766.118(2)(b) (2020). On appeal, the Eleventh Circuit affirmed the damages cap, but granted a motion to certify the question to the Florida Supreme Court of whether the damages cap violated the Florida Constitution. The Florida Supreme Court struck down the damages cap as violative of the Equal Protection Clause of the Florida Constitution. The Court applied rational basis review in concluding that the cap "imposes unfair and illogical burdens on injured parties" in medical malpractice suits with multiple claimants, such as the instant case, and that such "claimants do not receive the same rights to full compensation because of arbitrability diminished compensation for legally cognizable claims." The Court relied on precedent established in St. Mary's Hospital, Inc. v. Phillipe, 769 So. 2d 961 (Fla. 2000), which established a categorical rule that aggregate caps on noneconomic damages violate equal protection when applied without regard to the number of claimants entitled to recovery. Further, the Court determined that the statutory cap does not bear a rational relationship to the "medical malpractice insurance crisis," which it was imposed to remedy. The Court determined that the underlying report relied upon by the legislature in imposing the damages cap, which warned of skyrocketing malpractice insurance rates and fleeing doctors, was not entirely accurate. After reviewing alternative sources of data, the Court determined that such an insurance crisis did not exist, and that even if it did, it did not justify the discrimination. Finally, the Court attacked the correlation between the number of malpractice insurance providers and doctors with imposed damages caps, finding that such a relationship was minimal. The concurrence, while agreeing with the result, wrote separately to express disagreement with the plurality's failure to afford deference to the findings of the legislature. The dissent argued that the damages cap is rationally related to the legitimate state interest of decreasing malpractice insurance rates and increasingly affordability of healthcare, and thus, argued the cap does not violate the Florida Constitution.

Summary of Case Context & HoldingPlaintiff-employee was diagnosed with a medical condition that he alleged prevented him from performing his job as a night shift production supervisor. The Plaintiff was later let go by his employer and sued the employer for disability discrimination under the Montana Human Rights Act (MHRA). Mont. Code Ann. § 49-2-303. A Hearing Officer from the Montana Department of Labor issued a finding that the employee overstated the severity of his condition to his employer, and thus the employer's termination did not constitute discrimination against the employee on the basis of disability. The lower court affirmed the findings of the Hearing Officer, and Plaintiff appealed. The Supreme Court agreed with the Hearing Officer's findings, stating that the Plaintiff was not considered handicapped under the MHRA because the Plaintiff was only found to be precluded from the specific job of production supervisor by his handicap. To belong to a protected class of handicapped persons under the MHRA, a person would have to be generally precluded from a class of jobs rather than a specific position. Mont. Code Ann. § 49-2-101(19).

Summary of Case Context & HoldingEstrada was a hotel laundry assistant employed by the Mandalay Bay Resort and Casino who injured her lower back in April 2009. Although Estrada's workers' compensation claim was accepted and she received treatment, she continued to work, and her claim was eventually closed without an award for a permanent partial disability. In February 2010, Estrada underwent back surgery due to an increase in back pain. Her August 2010 request to reopen her workers' compensation claim was then denied, which an appeals officer affirmed. In their denial, the officer noted Estrada had presented insufficient evidence that her lower back condition had changed to warrant reopening the claim or that the surgery had been necessary on an emergency basis. The officer further noted that Estrada's back condition had changed so significantly due to the surgery that she could no longer demonstrate an objective change caused by the original injury. Estrada petitioned for judicial review, which was also denied. On appeal, the Supreme Court considered (1) the applicable standard of review that the officer should have utilized; (2) whether the facts of the appeal supported reopening the claim; and (3) whether the February 2010 surgery was performed on an emergency basis. The Supreme Court first held that the appeals officer in the case had applied the incorrect standard, as the Plaintiff had only needed to show "a change warranting additional compensation, primarily caused by her industrial injury." The Supreme Court further explained that the evidence, including a physician's certificate, a physician's letter, and an independent medical exam, supported a finding of changed circumstances required to reopen the claim. Accordingly, the Supreme Court reversed the portion of the district court's order supporting the officer's decision to deny reopening of the claim. Finally, the Supreme Court also held that Estrada failed to demonstrate that the surgery was performed on an emergency basis, as none of the medical reports mentioned any emergency basis, nor did she propose any reasons why it was impracticable to delay the surgery until the case had been reopened. As a result, the Supreme Court held that Estrada's employer was not liable for the costs of the February 2010 surgery.

Summary of Case Context & HoldingSadler Ranch, a vested senior water rights holder asked the district court to order the State Engineer to curtail junior water rights in the Diamond Valley Hydrographic Basin. Sadler Ranch had filed a petition requesting that the district court direct the State Engineer to begin curtailment proceedings or issue an order curtailing pumping. The district court granted an alternative writ of mandamus directing the State Engineer to begin curtailment proceedings. The State Engineer argued Sadler Ranch must provide notice to all Diamond Valley appropriators who may be affected by the district court's decision for a show cause hearing. Sadler Ranch argued that the State Engineer was the proper party to give notice. The District Court held that due process was not required until a future proceeding. The Nevada Supreme Court held that to comply with due process, notice to junior water rights holders is required before an upcoming show cause hearing. Junior water rights holders were required to be given notice and an opportunity to be heard before the district court conducted the hearing.

Summary of Case Context & HoldingMount Hope Mine sought to pump groundwater from the Kobeh Valley and Diamond Valley groundwater basins, both of which had many existing water rightsholders. The State Engineer approved Mount Hope Mine's application under a management plan that would mitigate the impact to existing rights. The Court held that while the State Engineer does have the power to reject applications that conflict with existing rights or are against the public interest, in this case the State Engineer did not have substantial evidence that the mine owners would be able to fully mitigate the new groundwater appropriations. The approval would be in conflict with the Legislature's directive that the State Engineer must deny or change applications when the use or change would conflict with existing rights.

Summary of Case Context & HoldingWater user brought action against the City of Tallassee (the City) utilities board, disposal company that operated a landfill and that sent leachate from the landfill to be treated by the City, and fictitiously named Defendants for monetary damages and injunctive relief regarding exposure to allegedly contaminated water that had been discharged into a river and ultimately sold by utilities board for consumption. After the Alabama Supreme Court determined that the City was a necessary party, water user filed an amended complaint that specifically stated that he was asserting no claims against the City. The trial court dismissed the City from the action based on improper venue and denied disposal company's motion to dismiss for failure to join the City as an indispensable party. Disposal company petitioned for a writ of mandamus and the Alabama Supreme Court denied relief, finding that the action could proceed in equity and good conscience without the City.

Summary of Case Context & HoldingCristian Aguilar, a Honduran national lawfully present in the United States with temporary protected status, pled guilty to the “state-jail felony” of attempting to evade arrest in a motor vehicle. He was sentenced to six months imprisonment. Aguilar applied for habeas corpus, on the grounds that he received ineffective assistance of counsel and that his plea was involuntary because his plea counsel gave him incorrect advice regarding the immigration consequences of the guilty plea. Aguilar had an immigration attorney who spoke to Aguilar’s plea counsel three times and told plea counsel that Aguilar would lose lawful status if convicted of a felony and would be ineligible for lawful permanent residency if sentenced to more than six months imprisonment. The plea counsel indicated to Aguilar and the immigration attorney that he understood and could negotiate a plea bargain allowing Aguilar to retain lawful status and eligibility for permanent residency. However, plea counsel then negotiated and advised Aguilar to accept a plea agreement that did not conform with the immigration attorney’s advice and that rendered Aguilar ineligible to maintain his lawful status. The habeas judge recommended that the Texas Criminal Appeals Court grant relief and entered the following findings of fact: (1) Aguilar's primary concern was to avoid deportation consequences and not lose his right to remain in the United States; (2) plea counsel was informed by an immigration attorney that a felony conviction would cause Aguilar to lose his temporary protected status; (3) Aguilar relied on plea counsel's incorrect advice that pleading guilty to a state-jail felony would not affect his immigration status; and (4) Aguilar "would not have pled guilty but would have insisted on going to trial but for [plea counsel's] incorrect counsel." The Texas Criminal Appeals Court noted that defendants are entitled to post-conviction relief on an ineffective-assistance-of-counsel claim if they demonstrate that “ (1) counsel’s performance was deficient and (2) the applicant was prejudiced as a result of that deficient performance.” Performance is “deficient” if it falls “below an objective standard of reasonableness." Under Padilla v. Kentucky, 559 U.S. 356 (2010), counsel have a duty to correctly advise a defendant of the removal consequences of a guilty plea when those consequences are clear. The government argued that Padilla did not apply because the immediate consequence of Aguilar’s plea was not removal, but loss of lawful status. The Court rejected this argument, finding that “loss of temporary protected status and presumptive removal necessarily follow the conviction” and holding that Padilla applies when a conviction automatically triggers a loss of status that renders a defendant presumptively removable. The Court found that deficiency was “easy to find” in Aguilar’s case, as plea counsel provided incorrect advice to Aguilar despite clear and correct instructions from an immigration attorney, upon whom plea counsel assured his client he would rely. On the prejudice prong, the Court noted that the defendant has to demonstrate a reasonable probability that, but for counsel’s errors, they would not have pleaded guilty and would have insisted on going to trial. Based on “several affidavits” attached to Aguilar’s habeas application, including plea counsel’s affidavit that Aguilar’s primary concern was not to lose his right to remain in the U.S. or not to be deported, as well as Aguilar’s own affidavit on similar lines, the Court found that the evidence supported the habeas judge’s recommendation in favor of Aguilar, which was thus entitled to “almost total deference.” Accordingly, the Court vacated Aguilar’s plea.

Summary of Case Context & HoldingMining company received a surface-coal-mining permit from the Alabama Surface Mining Commission that gave the company the right to mine on a piece of property. The property owners sued and challenged the Commission’s decision in Jefferson Circuit Court. The mining company and the Commission each filed a motion to dismiss, or, alternatively, to transfer the appeal to the Walker Circuit Court, where the Commission maintained its principal place of business. The Circuit Court denied the motions, as did the Court of Civil Appeals after the mining company and the Commission separately petitioned for a writ of mandamus. The mining company and the Commission each then separately petitioned the Supreme Court for a writ of mandamus, which consequently granted a change of venue, holding that proper venue for judicial review of issuance of surface-coal mining permit was where the Commission maintained its principal office, per the Alabama Surface Mining Control and Reclamation Act.

Summary of Case Context & HoldingWater works and sewer boards brought action against out-of-state carpet and chemical companies in which boards sought injunctive relief and damages based on claims of negligence, wantonness, nuisance, and trespass. The claims that arose were from allegations that the companies discharged toxic chemicals into industrial wastewater from their out-of-state plants, which subsequently contaminated downstream water sources in Alabama. Trial courts denied companies' motions to dismiss for lack of personal jurisdiction, and Defendants appealed. The Alabama Supreme Court held that for certain Defendants, the boards failed to rebut prima facie showings that the trial court lacked personal jurisdiction, and consequently dismissed the case for those Defendants. For the other Defendants, the Court held that (1) the alleged tort took place in Alabama for purposes of Alabama's long-arm statute; (2) the boards sufficiently alleged that remaining Defendants had sufficient minimum contacts with Alabama to support trial court's exercise of personal jurisdiction; and (3) the trial court's exercise of personal jurisdiction over those remaining Defendants comported with traditional notions of fair play and substantial justice. Accordingly, these Defendants’ petitions for a writ of mandamus were denied.

Summary of Case Context & HoldingFollowing the March 2021 initiation of Operation Lone Star (OLS) and subsequent authorization to detain and arrest unauthorized migrants for state level offenses committed on or near the border, the Texas Department of Public Safety troopers detained and arrested appellant Luis Alfredo Aparicio for criminal trespass. While Aparicio was accompanied by four adults (two men and two women) and a child, only the three adult men were arrested for criminal trespass, and the women and child were transferred to U.S. Border Patrol custody because the jails were unable to accept them. Aparicio filed an application for pretrial writ of habeas corpus with the trial court seeking dismissal of the criminal trespass charge on the ground that his arrest and charge were based on sex and thus unconstitutionally selective under both the federal and Texas state constitutions. The trial court found that there was no sex discrimination and denied Aparicio’s pretrial writ and motion to dismiss. The San Antonio Court of Appeals, sitting en banc, reversed and remanded after finding Aparicio’s claim was cognizable on pretrial habeas writ and that Aparicio demonstrated a prima facie case that “his gender was a motivating factor in his arrest.” The State challenged the fourth court's holding that Appellant's claim is cognizable. To alleviate backlog and allow a full review, the Court of Criminal Appeals on its own motion granted review on the merits if the Court found the claim cognizable. The Court of Criminal Appeals found Aparicio’s claim cognizable. On the merits, while the Court found that the evidence showed some level of discriminatory effect, the Court did not find that OLS was motivated by a discriminatory purpose. The Court found that limited resources was more likely the motivation for any discriminatory effect. Accordingly, the Court of Criminal Appeals reversed the court of appeals and affirmed the trial court's denial of Appellant's pretrial writ of habeas corpus on the merits.

Summary of Case Context & HoldingThe Water Works and Sewer Board of the City of Gadsen (the Board) sued several corporations, alleging contamination of its raw-water intake from the Coosa River with perfluoroalkyl and polyfluoroalkyl substances (PFAS). Gadsden Water claimed that the Defendants' actions led to substantial economic and consequential damages, including costs for future filtration systems, monitoring contamination levels, and remediation of contaminated property. The trial court denied the Defendants’ motions to dismiss, leading the Defendants to file petitions for writs of mandamus with the Supreme Court of Alabama. For two Defendants (DuPont and Daikin), the Court found that Gadsden Water's claims were barred by the applicable statutes of limitations and directed the trial court to dismiss the claims against DuPont and Daikin. For Defendant INV Performance Surfaces, LLC, the Court determined that the corporation’s limited contacts with Alabama, including owning equipment in one or two Alabama carpet mills in 2006, were insufficient to establish personal jurisdiction and directed the trial court to dismiss the claims against INV for its alleged role in the contamination of the raw water intake of the Coosa River.

Summary of Case Context & HoldingGASP, an Alabama based nonprofit, sought judicial review of the county board of health's adoption of revised county air pollution control rules and regulations. The trial court dismissed and the Court of Civil Appeals affirmed, finding that the Alabama Administrative Procedures Act (AAPA) does not apply to the board when it is performing its rule-making function under the Air Control Act because “the Air Control Act preempts the field” of air-pollution control and that, therefore, the “specific rule-making procedures provided for in § 22-28-23(b)(2) of the Air Control Act . . . control.” GASP petitioned for a writ of certiorari and the Alabama Supreme Court affirmed, finding that although the Court of Civil Appeals erred in affirming the trial court's judgment on the basis of preemption, the case is nevertheless dismissed because the board is not an "agency" according to the definition established in the AAPA and is thus not subject to the procedural requirements of the AAPA.

Summary of Case Context & HoldingPlaintiff, a tenant of the Housing Authority of the City of Talladega, fell while going down the stairs of his apartment due to missing handrails. Relying on Daniels v. Wiley, 314 So. 3d 1213 (Ala. 2017) (which held that a landlord has no duty to a Plaintiff when the danger is "open and obvious"), Defendant asserted that the absence of the railing was an “open and obvious” danger that Plaintiff was aware of, and thus, the Defendant owed no duty to Plaintiff. The trial court entered summary judgment for the Defendant based on Daniels but the court of civil appeals reversed. The Supreme Court affirmed the reversal, holding that Daniels should not be interpreted as overruling Alabama’s liability law as established in §§ 360 and 361 of the First and Second Restatements of Torts. The Court determined that an exception to the "open and obvious" rule provided in the Restatement provided that the landlord owed Plaintiff a duty under the circumstances of the case. The Court distinguished the case from Daniels where it was undisputed that the muddy sidewalk created an "open and obvious" danger and plaintiff admitted that she appreciated the danger by "typically avoid[ing] the danger by hopping over the mud." The Court cautioned that the holding in Daniels should not be interpreted as rejecting the duties of landlords set forth in §§ 360 and 361. Thus, the Court held that there was no conflict between the court of civil appeals’ decision and the holding in Daniels.

Summary of Case Context & HoldingResidents of Tallapaloosa County sued the Alabama Department of Environmental Management for declaratory and injunctive relief in regard to its adopted rules allowing companies to use alternative materials to cover solid waste in violation of the Solid Wastes and Recyclable Materials Management Act. The Supreme Court held that (1) area residents, in order to have standing, were required to present substantial evidence that alternative-cover materials were less effective than earth or compacted earth in controlling odors and disease vectors; and that (2) area residents failed to present substantial evidence that alternative-cover materials were less effective than earth or compacted earth in controlling odors and disease vectors.

Summary of Case Context & HoldingIndividuals brought action against the Alabama Secretary of State and the director of elections for injunctive and declaratory relief and sought a temporary restraining order to have digital ballot images or files be preserved in a then-upcoming special election. The day before the election, the circuit court entered a preliminary injunction directing the Alabama Secretary of State and the director of elections to communicate with and to send all probate judges and election officials in the State an order to set voting machines to save all processed images in order to preserve all digital ballot images. The Alabama Secretary of State and the director of elections petitioned for a writ of mandamus (an order from a court to an inferior government official ordering the government official to properly fulfill their official duties or correct an abuse of discretion) to put the preliminary injunction aside. A writ of mandamus is an extraordinary remedy available only when the petitioner can demonstrate: (1) a clear legal right to the order sought; (2) an imperative duty upon the respondent to perform, accompanied by a refusal to do so; (3) the lack of another adequate remedy; and (4) the properly invoked jurisdiction of the court. Here, the Alabama Supreme Court found that the December 11 order was directed solely to the December 12 election. Since that election had already taken place, the Court reasoned that a reversal of the order on the merits would not affect the rights of the parties. To the extent that the Defendants challenged the propriety of the preliminary injunction, their challenge in the Court was moot. The writ also challenged the Plaintiffs' standing. To have standing, plaintiffs principally must demonstrate an actual, concrete and particularized "injury in fact," i.e., an invasion of a legally protected interest. To confer standing, an injury in fact must be (a) concrete and particularized; and (b) actual or imminent, not conjectural or hypothetical. In this case, the Court found that the Plaintiffs' allegations that failure to retain digital ballot images "infringes upon their right to a fair and accurate election" and that "[w]ithout the preservation of these digital ballot images, [their] rights to a fair and accurate election could be denied" were only "conclusory allegations" and speculative at that. The Court further found the Plaintiffs' allegations of injury were not particularized and they did not demonstrate how the challenged practices harmed the Plaintiffs in a concrete way and whether they would benefit in a tangible way by a judgment in their favor. Therefore, the Court held the Plaintiffs lacked standing. Since the Plaintiffs lacked standing, the trial court lacked jurisdiction, and thus, the case was dismissed.

Summary of Case Context & HoldingIn a general election for mayor and five counsel seats, the Town's governing body refused to declare the winners of the three council seats for District A. Two of the candidates for the seats (including Scrushy) filed an election contest challenging the eligibility of another candidate. The circuit court declared the election of the challenged candidate void. Electors then asked the circuit court to direct the Town's governing body to declare the winning candidates. The circuit court granted the motion declaring Payton and Tyson-Bailey winners of two of the three seats. After the candidates were sworn in, the governor and Payton refused to attend council meetings, which prevented a quorum and accordingly the Town's governing body from filling the third council seat. After the seat had been vacant for more than 90 days the governor directed the probate judge to hold a special election to fill the vacancy. The probate judge set a special election and declared only two candidates (Bell and Scrushy) could be on the ballot. A third candidate sought to be added to the ballot. The circuit determined that the special election was void as a matter of law because of defective notice requirements. The mayor provided a second special election date where Scrushy received the majority of the votes. Nonetheless, the Town's governing body did not meet to certify the results and declare the winner. Electors asked the circuit court to declare the special election void because the Town's governing body could not order the special election because the Mayor and council member Payton refused to attend the meetings preventing a quorum to order the election. The circuit court initially declared the special election void. After a probate judge entered an order purporting to void all the orders entered by the circuit court, the circuit court reaffirmed its previous order declaring the special election void. The circuit court reasoned that the electors' motion to enforce the circuit court's prior orders and declare invalid a special election for town council was not an “election contest,” and thus the circuit court could void the special election for failure to be held in strict compliance with state's election laws. The town and the apparently successful candidate in the special election, Scrushy, sought a writ of mandamus. At issue was not the special election's results but instead the circuit court orders stating the circuit court's jurisdiction over the elections, one of which made clear that the town's governing body had a duty to conduct the special election in accordance with state's election laws. The Alabama Supreme Court determined that the circuit court had the power to enforce its prior orders and declare the special election void because it had not been ordered in strict compliance with the election laws. Accordingly, the Court found that Scrushy and the Town are not entitled to the relief they seek—a writ directing the circuit court to dismiss its judgment enforcing its prior orders.

Summary of Case Context & HoldingManuel Torres obtained lawful permanent residence status in 2006. In 2011, he was charged with the felony offenses of robbery and possession of cocaine. Torres entered into a plea bargain with the State in which he pled guilty to both offenses. Several days after the plea hearing, Torres was re-arrested on separate charges. Immigration and Customs Enforcement (ICE) became aware of Torres’ plea to the robbery and possession offenses and placed a detainer on him that would prevent him from being released from law-enforcement custody. ICE subsequently transferred appellant to a federal immigration detention facility, and initiated removal proceedings against him. Torres filed an application for a post-conviction writ of habeas corpus, in which he challenged the validity of his guilty plea on the basis of ineffective assistance of counsel, alleging that his trial counsel was ineffective for having failed to properly advise him that "a plea of guilty on a charge involving a controlled substance would automatically place [him] in removal proceedings due to his lawful permanent residence status.” Torres further asserted that counsel's failure to properly advise him harmed him in that "he is facing deportation and is under removal proceedings[.]" The trial court denied relief, finding the legal representation was not deficient. On appeal, the court of appeals reversed and granted Torres relief, finding that trial counsel had failed to "clearly and properly warn him of the impending consequences of his plea, as required by the Sixth Amendment." Under Padilla v. Kentucky, 559 U.S. 356 (2010), as offenses to which appellant pled guilty were automatically deportable offenses, counsel "had a duty to stress that pleading guilty to those crimes and receiving deferred adjudication would absolutely result in appellant's imminent removal from the United States." On review, the Texas Court of Criminal Appeals agreed that trial counsel’s performance was deficient based on the failure to adequately advise appellant regarding the "presumptively mandatory" deportation consequence of his guilty plea to the felony offenses of robbery and possession of cocaine. However, the court of criminal appeals found that Torres did not make an adequate showing of prejudice, i.e., did not demonstrate a reasonable probability that but for counsel’s errors, he would have rejected the plea bargain and pursued trial. The Court observed that Torres failed to “expressly allege, either in his pleadings to the habeas court or in his sworn affidavits,” that he would have availed himself of a trial had he known the full immigration consequences of his guilty plea. For example, Torres’s statements in his affidavits made “no mention of any special concern for potential immigration consequences” and instead appeared to “focus on a desire to avoid conviction and jail time.” The Court held that under such circumstances, the pleadings and writ counsel’s arguments alone were an inadequate basis for relief and suggested that counsel’s arguments were not sworn pleadings based on personal knowledge. The Court further reasoned that the habeas court’s factual findings and conclusion that relief should be denied were supported by the facts that Torres had confessed to two felony offenses, that his primary concern was getting out of jail, and that Torres “disregarded counsel's advice to seek counsel from an immigration attorney for specific information about how his residency status would be impacted by his plea.” The Court concluded that the two felony offenses ranged from two to twenty years and two to ten years, respectively, and that the plea bargain was “very favorable” and allowed Torres to entirely avoid jail time, so that under the totality of the circumstances Torres had failed to adequately show he was prejudiced as a result of counsel’s erroneous advice.

Summary of Case Context & HoldingThe Turners purchased a home for which Wells Fargo ultimately came to hold the mortgage. Following a dispute, Wells Fargo sought to foreclose on the property. The Turners contended that Wells Fargo failed to give them adequate notice of foreclosure as required by their mortgage, and the lack of notice precluded Wells Fargo from foreclosing on the property and the subsequent sale was void. The Court held that Wells Fargo failed to provide adequate notice, thus not complying with the requirements of the mortgage, and that failure to comply with the mortgage meant the subsequent sale was invalid.

Summary of Case Context & HoldingKrista Gilmore was employed by Excellence Community Management (ECM) as a community association manager. Gilmore signed an employment agreement that prohibited her from revealing trade secrets and disclosing ECM's confidential information for a period of 24 months after termination of her employment. The employment agreement did not include an assignment clause. At the time Gilmore signed the employment agreement, ECM was owned and operated by Jamie and Warren McCafferty (McCafferty). In May 2011, 90 percent of the McCaffertys' membership interest in ECM was purchased by First Service Residential Management Nevada (FSRM). One year later, the McCaffertys sold or relinquished their remaining membership interest in ECM to FSRM. In early June 2012, Gilmore left ECM and three weeks later, ECM sent Gilmore a cease-and-desist letter, which alleged that Gilmore violated her 2011 employment agreement by contacting ECM's clients to inform them she was no longer employed by ECM and soliciting them to hire Gilmore's new employer, Mesa Management, LLC. ECM sought a preliminary injunction to enforce the employment agreement. The district court denied ECM's motion for preliminary injunction, concluding that the employment agreement was not assignable to FSRM absent a clause permitting the assignment or an agreement with the employee consenting to the assignment. The Supreme Court held that the sale of 100% of the membership interest in a limited liability company did not affect the enforcement of an employee's employment contract containing a restrictive covenant, since such a sale did not create a new entity but instead was similar to a sale of stock of a corporation rather than an asset sale, which would have required an assignment of the contract to a new entity. Accordingly, the employer limited liability company was entitled to enforce the restrictive covenant in the employment contract without its employee's consent of assignment.

Summary of Case Context & HoldingThe Exeter Township sought review of a determination by the Labor Relations Board that the position of "zoning officer" was not a management-level employee subject to exclusion from the collective bargaining unit under the Public Employee Relations Act (PERA). The Supreme Court noted that nothing in the provisions of the Municipalities Planning Code addressing a zoning officer's powers established that the officer was responsible for directing the implementation of policy (as a management-level employee would be). Thus, the Supreme Court held that the Municipalities Planning Code did not provide a sufficient basis to determine, absent evidence of actual job duties, if a zoning officer was a management-level employee under the PERA, and thus the township, without presenting evidence of actual job duties, could not prevail on its claim that its zoning officers were not management-level employees subject to exclusion from the collective bargaining unit under PERA.

Summary of Case Context & HoldingWis. Stat. § 323.10 specified that no state of emergency may last longer than 60 days unless it "is extended by joint resolution of the legislature," and that the legislature may cut short a state of emergency by joint resolution. After declaring a state of emergency related to COVID-19 in March 2020, Governor Evers issued executive orders declaring additional states of emergency in July and again in September 2020. In the original action, petitioner Fabick asked the Supreme Court to declare the second and third additional COVID-19-related emergencies unlawful under Wis. Stat. § 323.10. The Supreme Court held that Wis. Stat. § 323.10's duration-limiting language forbade the governor from declaring successive states of emergency on the same basis as a prior state of emergency, and that the governor may not reissue a new emergency declaration following legislative revocation of a state of emergency declared on the same basis.

Summary of Case Context & HoldingThe Ohio Environmental Protection Agency (EPA) issued a renewed water-discharge permit to the Tussing Road Water Reclamation Facility, owned by Fairfield County. The Tussing Road plant's new permit contained new conditions limiting the discharge of phosphorous. The Ohio EPA based the new condition on a total maximum daily loads (TMDL) report for the area that was submitted to the U.S. EPA. The Supreme Court held that phosphorous limitation should be vacated because a TMDL limit established by the Ohio EPA is subject to formal rule making requirements. The correct procedures would have allowed Fairfield County a chance to challenge the TMDL before it was submitted to the U.S. EPA.

Summary of Case Context & HoldingIn 2020, Arizona voters passed Proposition 208, an initiative imposing an income tax surcharge on "high-income" Arizona taxpayers in order to provide direct funding to schools. Petitioners sued to challenge the constitutionality of the tax and the initiative's characterization of the direct funding to schools as "grants" exempt from the expenditure limitations provided in Article 9, Section 21 of the Arizona Constitution (Education Expenditure clause). The Court held that the direct funding provision did not fall within the constitutional definition of grants and accordingly Proposition 208 was unconstitutional by mandating expending tax revenues in violation of the Education Expenditure Clause. The Court's rationale for its determination was that a statute cannot circumvent or modify constitutional requirements by providing self-exemption language. By interpreting words in Proposition 208 by their ordinary meaning, the Court determined that the most plausible reading is that Proposition 208 revenues are not grants but are local revenues. The Court then analyzed whether it would be possible to sever the unconstitutional component of Proposition 208 from the rest of the voter initiative, which required a determination of whether the valid portion, considered separately, can operate independently and is enforceable and workable. The Court concluded that if the unconstitutional provisions were struck, there would be no statutory authority to spend the funding raised by the tax, thus the Proposition could not operate or stand on its own. Accordingly, the Court affirmed the trial court's denial of the preliminary injunction enjoining Proposition 208. The Court nonetheless affirmed the trial court's denial of a preliminary injunction enjoining Proposition 208, as there was a factual question of whether Proposition 208 revenues would exceed the expenditure limitation on local revenues. If the revenues were found to exceed the expenditures, then the Proposition could possibly be found to be constitutional. The dissenting opinion agreed that the trial court's denial of the temporary injunction should be affirmed, but disagreed with the majority's constitutional analysis. The dissent contended that it is not necessarily true that just because Proposition 208 is facially unworkable it does not mean that it could not become workable in the future, and accordingly the majority applied too exacting of a standard.

Summary of Case Context & HoldingTroy University, a state-run nonprofit based in Alabama, has an office in North Carolina to recruit students for their online program. An employee in the North Carolina Office claimed that he was subjected to sexual harassment, wrongful discharge, and negligent supervision. The Supreme Court found that Troy University could not invoke sovereign immunity because, although it is a state entity, the state-run university consented to engaging in suits when it enjoyed the benefit of conducting business in North Carolina. The school waived sovereign immunity by registering in North Carolina as a foreign nonprofit corporation and engaging in business in North Carolina.

Summary of Case Context & HoldingIn this case, the Court was asked to consider the appropriate allocation of costs for environmental contamination property cleanup when one of two insurers on the risk became insolvent. Two residential homes were initially insured by an insurer, Newark Insurance Company (Newark) for up to $300K before being insured up to $500K by Farmers Mutual Fire Insurance Company (Farmers Mutual). Subsequently, in 2003, within the first year of coverage by Farmers Mutual, both properties were found to have soil and groundwater contamination caused by fuel oil leaks from underground storage tanks. In 2007, Newark was declared insolvent and the New Jersey Property-Liability Insurance Guaranty Association (the Association) took over the administration of Newark's claims pursuant to the New Jersey Property-Liability Insurance Guaranty Association Act (the Act). Although it is undisputed that the environmental contamination on the properties began during periods insured by Newark, Farmers Mutual paid all remediation costs: $112,165.13 for the first property and $25,958.39 for the second and sought reimbursement from the Association for the remediation costs expended on the properties, claiming that, in accordance with the allocation scheme adopted in Owens-Illinois, Inc. v. United Insurance Co., 650 A.2d 974 (N.J. 1994), the Association was responsible for Newark's share of liability. The Association moved for summary judgment, arguing that the Act required the insureds to exhaust their claims through solvent insurance companies prior to applying for statutory benefits. The trial court rejected that argument, finding that the Spill Compensation and Control Act (Spill Act), N.J.S.A. 58:10-23.11, provided Farmers Mutual with a right to contribution from the Guaranty Association. The Association appealed and the appellate division reversed finding that a 2004 amendment to the Act, N.J.S.A. 17:30A-5, requires exhaustion of benefits from solvent insurers before the Guaranty Association must pay statutory benefits and Farmers Mutual did not exhaust its policy limits in either case and, therefore, it could not seek contribution from the Association for the remediation costs it expended. The Supreme Court affirmed the appellate court's decision and held that since the legislative enactments are never subservient to the common law, the 2004 amendments to the Act take precedence over the common-law proration scheme enunciated in Owens-Illinois, reasoning that the definition of "exhaust" in N.J.S.A. 17:30A-5 as applied to N.J.S.A. 17:30A-12(b) is clearly intended to make the Association the insurer of last resort in continuous-trigger cases involving progressive injury and property damage arising from environmental contamination. Insureds must therefore exhaust the policy limits of solvent insurers prior to applying to the Association for statutory benefits.

Summary of Case Context & HoldingAt the same time that the Plaintiff worked for Hewlett-Packard as a quality control specialist, he sustained a minor injury to his knee while volunteering on a Douglas County search and rescue team. Following his injury, Plaintiff filed a claim seeking insurance benefits from Douglas County and its workers' compensation insurance carrier, the Public Agency Compensation Trust (PACT). The third-party claims adjustor, Alternative Service Concepts (ASC), notified Plaintiff that it had calculated his average monthly wage (AMW) for the purpose of determining the amount of benefits to which he would be entitled under his claim and based its calculations pursuant to the statutorily deemed wage of a search and rescue volunteer as set forth in NRS 616A.157 and awarded Plaintiff a one-percent permanent partial disability (PPD) impairment. Plaintiff disputed the ASC award as to both his AMW and PPD, arguing that his deemed wage and his earned wage at Hewlett-Packard should be aggregated. The Supreme Court held that under NAC 616C.447 (which provides specific directions regarding the calculation of AMW using the deemed wages provided by statutes when a claimant has concurrent private employment), the employee's average monthly wage should have been based on the aggregation of his deemed wage for his volunteer work and his concurrent privately earned wage from working at Hewlett-Packard, subject to the maximum amount set forth in NRS 616A.065(1)(b), since the plain language of the relevant workers' compensation statutes and regulations requires the aggregation of concurrently earned wages.

Summary of Case Context & HoldingReynaldo Figueroa-Sanabria was convicted of two counts of first-degree murder after stabbing John Travlos and Germana Morin to death on their houseboat. At the end of the penalty phase, he was sentenced to death for each murder. During the penalty phase, the trial court informed Figueroa-Sanabria that "if [Figueroa-Sanabria's court appointed lawyer] represents [Figueroa-Sanabria], he's going to present mitigation on [his] behalf," effectively telling Figueroa-Sanabria that his right to the assistance of counsel was conditioned on the presentation of mitigation. Faced with this choice, Figueroa-Sanabria decided to proceed pro se. Finding that Figueroa-Sanabria was deprived of his right to "have the Assistance of Counsel for his defen[s]e" based on the trial court's fundamental error in forcing him to abandon counsel during the penalty phase, the Supreme Court set aside Figueroa-Sanabria's sentences of death and remanded his case for a new penalty phase.

Summary of Case Context & HoldingPlaintiff One West Bank, N.A., (the Bank), filed an action against Standard Bank and Trust Company as Trustee (Standard) to foreclose on a mortgage on a property held by Standard. Standard filed a counterclaim alleging that the Bank violated the federal Truth in Lending Act (TILA) by failing to provide Standard with certain disclosures, required under TILA, at the time the mortgage transaction was consummated. Failure to provide such disclosures gives a consumer the right to rescind the transaction for up to three years. Specifically, TILA provides that "each consumer whose ownership interest is or will be subject to the security interest shall have the right to rescind the transaction." The Illinois Supreme Court found that land trustees, like Standard, were “natural person[s],” therefore, were consumers for purposes of TILA requirements. As a result, it determined that Standard was entitled to TILA disclosures and had a right to rescind the mortgage transaction if, as it alleged, it did not get such disclosures. The Illinois Supreme Court, therefore, reversed the appellate court's holding to the contrary.

Summary of Case Context & HoldingThe Florida State Bar (Bar) was considering an application from a law school graduate who was an undocumented immigrant. The Bar asked the Supreme Court to answer the question of whether the Bar could accept undocumented immigrants. The Court held that undocumented immigrants are not eligible for admission to the Florida Bar. In an amicus brief, the U.S. Department of Justice (DOJ) argued that federal statutes prohibit an undocumented immigrant from obtaining a professional license in the U.S. The Court agreed with the DOJ and explained that, although states may provide a state public benefit to undocumented immigrants, they must pass statutes to do so, and there is no Florida statute that permits the issuance of a law license to an undocumented immigrant. Administrative policies, such as the federal immigration policy Deferred Action for Childhood Arrivals (DACA), are not enough to overcome this bar because they do not have the force of law. In fact, those policies explicitly state that they do not provide individuals with lawful status or confer any substantive right to undocumented immigrants. Thus, unauthorized immigrants are ineligible for admission to the Florida bar.

Summary of Case Context & HoldingPlaintiff medical marijuana provider sought an injunction prohibiting enforcement of certain statutory provisions related to regulation of medical marijuana treatment centers (MMTC). Plaintiff claimed that two provisions of the statute were inconsistent with the recent medical marijuana amendment to the Florida Constitution and argued that three such provisions were special laws granting privileges to private corporations. The trial court was persuaded by Plaintiff's arguments and issued the injunction. On appeal, the injunction was partially upheld with the appeals court concluding "it was affirming 'that portion of the injunction that precludes [the Department] from enforcing the [preliminarily] unconstitutional provisions but allows the Department a reasonable period of time to exercise its duties under the constitutional amendment.'" The Supreme Court overturned the appeals court ruling and rescinded the injunction, determining that Plaintiff was unlikely to succeed on the merits of any of its claims. First, the Court rejected Plaintiff's argument that certain regulatory requirements conflicted with the Constitution's definition of a "medical marijuana treatment center," by noting that the plain language of the amendment leaves the establishment of policies related to treatment centers to the legislature. The Court further disagreed that caps on the number of licenses for treatment centers undermined the amendment by restricting access to medical marijuana because not all licenses had been applied for, and even if they had, the legislature had explicitly contemplated raising the cap with changes in population and participation in the program. In determining whether the provisions constituted "special laws" granting privileges to private corporations, the court "conclude[d] that the statute at issue creates an open class of entities that may be eligible for MMTC licensure and, within that open class, creates subclassifications 'based upon proper distinctions and differences that inhere in or are peculiar or appropriate to the class,'" making it a general law. Thus, the Court held that Plaintiff was not likely to succeed on the merits of their claims and therefore were not entitled to an injunction. The partial concurrence agreed with the majority that the regulatory provisions do not conflict with the amendment, and therefore Plaintiff has little chance of success on those claims. However, it disagreed with the majority that the provisions cited by Plaintiff did not constitute "special laws" because those provisions allow some providers to become licensed without the restriction of the caps.

Summary of Case Context & HoldingThe Montana Supreme Court affirmed the district court's holding that a Beneficial Water Use Permit, under the Montana Water Use Act (MWUA), issued to Artesian Water Company (Artesian), which sought to operate a water bottling facility in Montana, was inappropriately granted. Artesian sought a water use permit, under the MWUA, from the Department of Natural Resources and Conservation (DNRC). Objectors to issuance of the permit, including Flathead Lakers Inc., alleged that the DNRC failed to properly assess the physical and legal availability of water, as required by Section 85-2-311 of the MWUA, in granting the permit. Both the district court and the Supreme Court agreed, finding that (1) with respect to physical availability of water, omissions within Artesian's permit application impacted the DNRC's ability to conduct a full assessment and, also, that the required assessment of the impact of groundwater appropriations had not been performed under the usual hydrostatic conditions and therefore was compromised; and (2) with respect to legal availability, the DNRC failed to fully analyze legal availability of the water rights that Artesian sought to appropriate because it only evaluated Flathead River and Flathead Lake when other surface waters may have been affected.

Summary of Case Context & HoldingAn employee alleged that while working for her employer, an equestrian facility, she was sexually assaulted by a co-worker and the president and owner of the facility knew about the assailant's behavior but failed to act. The employee sued her employer under common law tort theories, asserting nine claims for relief: negligence; negligent hiring; negligent training, supervision, and retention; assault; battery; negligent infliction of emotional distress; intentional infliction of emotional distress; respondent superior; and tortious constructive discharge. The employer argued that the employee failed to state a claim for relief because her injury was work-related, and thus that the Nevada Industrial Insurance Act (NIIA) provided her exclusive legal remedy. The district court agreed and dismissed the employee's lawsuit entirely relying on Nev. Rev. Stat. Ann. § 616A.020 1 (provides exclusive remedy for an employee on account of an injury by accident sustained arising out of and in the course of the employment) and Wood v. Safeway, Inc., 12o P.3d 1026 (Nev. 2005) (employer was not liable for intentional torts committed by its employee). The Supreme Court held that while the NIIA was the employee's exclusive remedy with respect to the negligence and intentional tort claims because of Nevada statutory immunity, it did not expressly extend to a tortious constructive discharge claim since NIIA immunity does not expressly extend to wrongful termination claims, and thus the district court erred when it dismissed the employee's tortious discharge claim without first analyzing whether the facts alleged in the complaint, if presumed true, would entitle the employee to relief. The Supreme Court remanded for further proceedings.

Summary of Case Context & HoldingFlorida Industrial Power Users Group (FIPUG) appealed a decision of the Florida Public Service Commission (Commission) approving Florida Power and Light’s (FPL) request to recover costs for the building of eight solar energy centers by increasing base rates. When FPL petitioned for a rate increase, nine parties intervened including FIPUG. A settlement was reached between FPL and three intervenors. FIPUG was not a party to this settlement agreement and did not challenge the settlement when it was before the Commission or by appeal. The settlement agreement provided that FPL could recover costs for solar projects that met certain requirements and were demonstrated to be cost effective. FIPUG appealed the Commission’s grant of FPL’s request under this provision of the settlement, arguing that (1) the Commission failed to conduct a prudence review of the request; (2) the Commission based its finding of cost-effectiveness on uncorroborated hearsay; and (3) the Commission’s decision utilized the wrong Florida statutes. The Supreme Court rejected each of FIPUG’s arguments and upheld the Commission’s decision. The first and third issues were foreclosed by the settlement order which had already allowed for review of the solar energy centers and expressly outlined what Florida law applied to petitions for cost recovery. As to the second issue, the Supreme Court found that FIPUG failed to properly lodge objections against any FPL witnesses or testimony. To the contrary, FIPUG had only submitted a general objection to the recognition of FPL's witnesses as experts. However, according to the Commission's order establishing procedure, FIPUG should have identified each witness it wished to voir dire and explicitly outlined any pre-filed testimony to which it objected. Additionally, the Supreme Court emphasized that hearsay evidence is allowed where it supplements or explains overall testimony (here, the hearsay supplemented overall testimony about cost-effectiveness, customer savings, and noneconomic benefits).

Summary of Case Context & HoldingAppellant, Zane Floyd is a death row inmate who challenged his sentence on the theory that Nevada's statute providing that an execution must be effectuated by a lethal injection unconstitutionally delegated lawmaking authority to the Nevada Department of Corrections ("Department"). Case law interpreting Nevada's Constitution holds that Nevada's legislature cannot delegate its lawmaking authority to the Executive Branch, unless the Legislature establishes suitable standards to govern the manner and circumstances under which an executive agency can exercise its delegated authority. Floyd argued that the statute did not provide the Department with "suitable standards" when delegating the authority to conduct lethal injections to the Department because the statute did not specify the process by which a lethal injection had to be administered, and instead left that for the Department to determine along with its Chief Medical Officer. The Court rejected this argument and held that the lethal injection statute was constitutional, reasoning that the statute did in fact provide a guiding standard to the Department. Specifically, the Department was required to consult with its Chief Medical Officer in determining the specific injection—this was enough of a suitable standard.

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

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

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

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

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

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

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

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

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

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