In this case from the Supreme Court of North Dakota, Daynen Hoover contested a district court judgment that affirmed a decision by the North Dakota Department of Transportation (Department) to suspend his driving privileges for 91 days. This penalty was the result of Hoover being arrested for being in control of a motor vehicle while under the influence of alcohol, with a blood alcohol concentration of .085 percent by weight. The Department conducted an administrative hearing by video conference, during which they introduced eight foundational exhibits from the State Crime Laboratory. Hoover objected to this on the grounds that he and his counsel did not have copies of these exhibits to review and analyze. Despite these objections, the hearing officer admitted the exhibits and the Department subsequently suspended Hoover's driving privileges for 91 days.On appeal, the Supreme Court of North Dakota reversed the district court's decision. The court concluded that the procedure used by the Department, which admitted exhibits into evidence without providing Hoover a meaningful opportunity to examine them, deprived him of a fair hearing. The court noted that the Department's notice of information did not offer copies of the exhibits or specifically identify which documents maintained by the Department or available on the attorney general's website would be introduced at the hearing. The court found that this violated the requirement for parties to be afforded an opportunity to examine exhibits before they are admitted into evidence. Therefore, the court ruled that the Department's procedures did not comply with state law and substantially prejudiced Hoover's procedural rights. The court's decision emphasized the importance of a party's ability to examine exhibits introduced against them as a critical procedural protection in adjudicative proceedings. View "Hoover v. NDDOT" on Justia Law

In the case before the Supreme Court of the State of Illinois, the City of Rock Falls filed a petition against Aims Industrial Services, LLC. The petition sought to enforce compliance with a City ordinance requiring the replacement of a private sewage disposal system with a connection to the City’s public sewage disposal system upon the sale or transfer of any property within the City limits. The trial court determined it would be inequitable to grant the City an injunction and denied the City’s petition. The appellate court reversed this decision, holding that the trial court erred in considering the equities when deciding whether to grant the injunction, as the City sought enforcement of an ordinance that specifically authorized injunctive relief.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court, stating that when a statute or ordinance expressly authorizes injunctive relief, the court has no discretion to refuse to grant the injunctive relief once a violation of the statute or ordinance has been established. The Supreme Court clarified that in such cases, balancing of the equities is not necessary since a violation of the statute or ordinance implies a harm to the public. Therefore, the trial court's refusal to grant the injunction based on its own balancing of the equities was an error. View "City of Rock Falls v. Aims Industrial Services, LLC" on Justia Law

In the state of Illinois, a group of active and retired members of local police and firefighter pension funds filed a complaint against the Governor and other officials, challenging the constitutionality of Public Act 101-610. This Act amended the Illinois Pension Code and consolidated all local police and firefighter pension fund assets into two statewide pension investment funds. The plaintiffs claimed the Act violated two provisions of the Illinois Constitution: the pension protection clause and the takings clause. They argued that the Act diminished their pension benefits by diluting their voting power and control over investment decisions, and by imposing costs associated with the Act's implementation, including repayment of any transition loans. The Supreme Court of Illinois disagreed with the plaintiffs, affirming the lower courts' decisions. The court ruled that the Act does not violate the pension protection clause because the ability to vote in local pension board elections and control local pension fund investments are not constitutionally protected benefits. They also ruled that the Act does not violate the takings clause because the plaintiffs do not have a private property right in the funds that are to be transferred to the new statewide funds. The Act only changes how local fund assets are managed and invested without affecting the ultimate use of those assets to pay the benefits of local fund members. Thus, the Act remains in effect. View "Arlington Heights Police Pension Fund v. Pritzker" on Justia Law

In the case before the Supreme Court of Alabama, Emma Louie, Garry Rice, and Toice Goodson, employees of the Greene County Board of Education, sought a writ of mandamus directing the Greene Circuit Court to enter a summary judgment in their favor, asserting that they are protected by State-agent immunity. The claims against them were brought by Ester Eaton and Anthony Eaton, who alleged negligence and loss of consortium after Ester Eaton, a substitute teacher, was attacked while supervising a classroom of students in the Alternative Program and in-school suspension (ISS). The defendants argued that their supposed violations of school policies were in fact based on discretionary decisions, not violations of specific, mandatory rules, thus entitling them to State-agent immunity.The Supreme Court of Alabama agreed with the defendants, ruling that the school guidelines in question were not specific, nondiscretionary rules, but rather allowed for administrative discretion. As such, the court found that the defendants' actions fell within the scope of their discretion as state agents, and they were therefore entitled to State-agent immunity. Consequently, the court granted the petition for a writ of mandamus and directed the trial court to enter a summary judgment in favor of the defendants. View "Ex parte Louie" on Justia Law

The defendant, Tristan T. Horne, was charged with attempted possession of a firearm by a prohibited person. As part of a plea agreement, Horne was admitted into a problem-solving court program (Wellness Court) designed to assist defendants with mental health diagnoses. The program defers sentencing and provides treatment, supervision, and judicial oversight. Successful completion of the program may result in the defendant being allowed to withdraw their plea and have their charges dismissed. However, if the participant is removed from the program or withdraws before successful completion, the conviction stands and the case proceeds to sentencing.Throughout Horne's participation in the program, he repeatedly violated program requirements. These violations included missed drug tests, dishonesty with probation officers, not completing community service hours ordered by the District Court, failing to successfully complete multiple residential treatment programs, testing positive for marijuana, removing his court-ordered GPS monitoring device, and failing to report to jail as ordered after leaving a treatment program. Following these violations, the State moved to remove Horne from the program. The District Court accepted Horne's admission to the violations and removed him from the program. Subsequently, Horne was sentenced to a term of imprisonment.On appeal, Horne challenged his removal from the program, the fact that the District Court did not order a presentence investigation before sentencing him, and the length of his sentence. The Nebraska Supreme Court affirmed the District Court's decision, finding no reversible error. It held that the District Court did not abuse its discretion in removing Horne from the program given his multiple failures to comply with program requirements. The Supreme Court also held that the District Court did not plainly err in not ordering a presentence investigation before sentencing Horne. Lastly, the Supreme Court found that the District Court did not abuse its discretion in sentencing Horne. View "State v. Horne" on Justia Law

The Supreme Court of Mississippi examined whether a school district was entitled to funds recovered by a county from the bankruptcy proceedings of a delinquent taxpayer. The taxes, if collected normally, would have been used to fund the school district. However, the county board of supervisors had anticipated the delinquency and adjusted the levy of ad valorem taxes to compensate, ensuring the school district did not experience a shortfall. The school district argued it was entitled to its original portion of the recovered bankruptcy funds, but the county claimed that this would result in a double recovery outside the statutory scheme for public school funding. The Supreme Court of Mississippi found in favor of the county, ruling that the recovery of delinquent taxes through bankruptcy proceedings is outside the statutory funding scheme for public school districts in Mississippi. The court found that the school district was not entitled to receive delinquent taxes recovered years later in bankruptcy proceedings and reversed and remanded the lower court's award to the school district. View "Clarke County, Mississippi v. Quitman School District" on Justia Law

The Court of Appeals of the State of California, Second Appellate District, Division Six, ruled in favor of the Ventura County Employees’ Retirement Association (VCERA) in a dispute over the calculation of retirement benefits for county employees. VCERA had adopted a resolution excluding compensation for accrued but unused annual leave hours exceeding a calendar year allowance from the calculation of retirement benefits, following a Supreme Court decision in a similar case (Alameda County Deputy Sheriff’s Assn. v. Alameda County Employees’ Retirement Assn.). VCERA sought a judicial declaration that its resolution was legal, which was granted by the trial court. The Criminal Justice Attorneys Association of Ventura and Ventura County Professional Peace Officers’ Association appealed this decision, arguing that the resolution was not mandated by the Supreme Court decision or the relevant statutes. The Court of Appeals affirmed the lower court's decision, concluding that VCERA was required to comply with the Supreme Court decision and the relevant statutes, which were designed to prevent pension spiking by excluding income designed to artificially inflate a pension benefit. View "Ventura County Employees' Retirement Association v. Criminal Justice Attorneys Association of Ventura County" on Justia Law

In the case before the United States Court of Appeals for the Sixth Circuit, Leslie Fisher sued officers Randall Jordan, Matthew Rice, and John Trefelet of the Michigan State Police for violating federal and state law by arresting her without probable cause. Fisher and her husband were arrested after the officers executed a search warrant and found marijuana growing in their garage. All charges against Fisher were eventually dismissed in state court. She then filed a federal lawsuit against the arresting officers.The officers moved for summary judgment, invoking qualified immunity in response to Fisher's federal claims of arrest and prosecution without probable cause under 42 U.S.C. § 1983, and governmental immunity for her state claims of false arrest, false imprisonment, and malicious prosecution. The district court granted summary judgment to the officers, concluding that they had probable cause to arrest Fisher.On appeal, the Sixth Circuit affirmed the district court's decision. The court found that the officers had probable cause to believe that Fisher had committed the crime of possession of at least 5,000 grams of marijuana with the intent to distribute, based on various pieces of evidence. This included the fact that Fisher lived at and owned the site of the marijuana cultivation operation, and that she admitted to using marijuana grown by her husband. The court also found that the large quantity of marijuana in the Fishers' garage supported probable cause to infer intent to distribute.The court further concluded that the officers were entitled to governmental immunity from Fisher's state law claims, as the probable cause analysis for federal Fourth Amendment claims is the same under Michigan law. Since the officers had probable cause to suspect that Fisher possessed an illegal quantity of marijuana with the intent to distribute, they were entitled to governmental immunity from Fisher's state law claims. View "Fisher v. Jordan" on Justia Law

In this case before the United States Court of Appeals for the Third Circuit, a US citizen, Abdoulai Bah, had his life savings of $71,613 seized by the U.S. Customs and Border Protection (CBP) under suspicion of being the proceeds of illegal activities. The CBP returned the money with interest two-and-a-half years later. Bah then sued the United States under the Federal Tort Claims Act (FTCA), seeking damages for personal injury and property damage, arguing that the seizure of his money prevented him from conducting business, caused him to lose his livelihood, and resulted in health problems.The District Court dismissed Bah's case, asserting that the United States was immune from Bah's claims. The court held that the FTCA did not permit Bah's claims as they were seeking prejudgment interest— a type of relief for which the United States has not waived sovereign immunity.Upon appeal, the United States Court of Appeals for the Third Circuit upheld the District Court's decision. The appellate court held that the Detention Exception of the FTCA, under which Bah's claim was filed, only waives sovereign immunity for "injury or loss of goods, merchandise, or other property while in the possession of any officer of customs or excise or any other law enforcement officer," but it does not waive immunity for personal "injury" or "loss" incurred due to the government's seizure of property. As such, the court concluded that Bah's cash was not injured or lost in the sense meant by the FTCA, and his personal injuries were not covered under the Act. Furthermore, the court determined that Bah's claim of "loss" was really a claim for "loss of use" of his cash, which is not covered under the FTCA. Thus, the court affirmed the dismissal of Bah's case. View "Bah v. USA" on Justia Law

The case was an appeal to the United States Court of Appeals for the Fifth Circuit against a lower court's decision that the structure of the Consumer Product Safety Commission (CPSC) was unconstitutional. The plaintiffs, By Two, L.P., and Consumers’ Research, argued that the CPSC's structure violated the separation-of-powers doctrine because the President could only remove the CPSC's commissioners for cause. The district court agreed with the plaintiffs, but the appellate court reversed this decision.The appellate court held that the CPSC's structure was constitutional and did not violate the separation-of-powers doctrine. The court based its decision on the Supreme Court's precedent in Humphrey’s Executor v. United States, which allowed for-cause removal protections for commissioners of independent agencies like the CPSC. The court noted that while the CPSC does exercise substantial executive power, this alone does not remove it from the protection of the Humphrey’s Executor exception. The court also pointed out that the CPSC's structure was not novel or lacking historical precedent, which further supported its constitutionality.The court emphasized that any changes to the Humphrey’s Executor exception would have to be made by the Supreme Court, not the lower courts. Until such a change occurred, the CPSC's structure remained constitutional. Thus, the court reversed the district court's decision and sent the case back to the lower court for further proceedings. View "Consumers’ Research v. Consumer Product Safety Commission" on Justia Law