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Decision levers
AI-measured from their own opinions — each lever cites its cases
PurposivismTextualism
In Knight [2], court holds policy language 'capable of but one interpretation' and adopts defendant's reading without resort to purpose or extrinsic sources. Knight v. American National Fire… ↗
Deference to government powerSkepticism of government power
In Hall [0] court finds school district violated teacher's First Amendment rights; in Phillips [4] court defers to school officials' judgment on disruption; mixed signals but net skepticism in constitutional challenges. Hall v. Marion School District N… ↗ Phillips v. Anderson County Scho… ↗
This case involved abortion providers in South Carolina challenging the constitutionality of a state regulation, S.C. Code Ann. Regs. 61-12, that imposed licensure and operational requirements on physicians' offices and clinics performing five or more first-trimester abortions per month. The court held that the regulation was facially invalid under the Due Process and Equal Protection Clauses of the Fourteenth Amendment. It determined that the regulation imposed numerous unnecessary requirements that unduly burdened the constitutional right to abortion, despite evidence that the clinics had operated safely for over two decades. The court also found no rational basis for the regulation's differential treatment of abortion providers compared to other medical practices performing similar procedures, and concluded that the pervasive issues prevented severing invalid provisions to save the regulation.
This case arose from a lease-purchase agreement for a sandwich production business between Carriage Town and LandCo, which included a non-compete clause that became unenforceable upon Carriage Town's uncured default. After Carriage Town missed a payment, LandCo violated the clause by hiring employees and competing, leading Carriage Town to obtain a preliminary injunction backed by a $250,000 surety bond from Reliance; the parties later settled, amended the lease terms including a liquidated damages provision, and obtained a consent permanent injunction that continued the bond without notifying Reliance. LandCo then sought $100,000 in liquidated damages from the bond proceeds after another default, along with repossession of equipment. The court denied the bond payment request but granted the unopposed repossession motion. It reasoned that the unnotified amendments materially increased Reliance's risk and that the claimed damages fell outside the scope of the original preliminary injunction bond, discharging the surety.
The case involved a lawsuit by Lisa Ann Phillips on behalf of her minor son, James Kinley, against Anderson County School District Five, claiming that school officials conspired to violate Kinley's constitutional rights by prohibiting him from wearing a jacket resembling the Confederate Battle Flag to Lakeside Middle School and suspending him for refusing to remove it. The court granted the school district's motion for summary judgment, holding that the suspension did not violate Kinley's rights. The decision rested on evidence of prior racial tensions and disruptions at the school linked to Confederate Flag garments, including altercations and fights in 1991-1995, which provided a reasonable basis for officials to anticipate substantial interference with the educational process. The court also found no due process violations in the suspension procedures or review process.
Polly Hindman sued Greenville Hospital Systems and Greenville Memorial Hospital under Title VII and the ADA, claiming retaliation for filing administrative complaints with the SCHAC and EEOC, as well as disability discrimination and failure to accommodate her depression and post-traumatic stress disorder; she also brought a state-law claim for breach of the implied covenant of good faith and fair dealing. The defendants moved for summary judgment, which the court granted. The court held that judicial estoppel prevented Hindman from establishing a prima facie case on her federal claims because her sworn statements to the SSA that she was totally disabled and unable to work as of July 1994 contradicted the requirement that she be a qualified individual, and alternatively that she could not prove causation on the retaliation claim. On the state claim, the court concluded that no such covenant is recognized under South Carolina law for at-will employees, and Hindman had no employment contract altering that status.
In this case, Trident Regional Health System sued Candace Polin in state court to recover $82,638.45 in unpaid medical expenses from services rendered under her employee health plan. Polin filed a third-party claim against her employer Life Cycle Engineering, the ERISA plan fiduciary and administrator, seeking payment of those expenses; Life Cycle removed the action to federal court and moved for summary judgment, arguing that Polin had breached the plan's subrogation and notification provisions by settling a related tort claim without notice or approval and refusing to execute required repayment agreements. The court granted summary judgment to Life Cycle, holding that the plan's plain language permitted the administrator to withhold benefits until Polin complied with those terms and that Life Cycle's interpretation was reasonable and not arbitrary or capricious under ERISA standards. The decision rested on undisputed facts that Polin had failed to notify the plan or obtain approval before settling and had declined to sign subrogation instruments despite the plan's explicit requirements. No material facts were in dispute, and the court declined to impose additional federal common-law "made whole" rules beyond the plan's terms.
This case involved a contract dispute between Laidlaw Environmental Services and Honeywell over the purchase of a computer control system for a hazardous waste facility, after Laidlaw experienced operational issues leading to EPA penalties and other losses. The court granted Honeywell's motion for summary judgment on all claims. It held that the parties' negotiated written contract, rather than Laidlaw's earlier purchase order, governed the transaction, and that the contract's terms validly disclaimed warranties and limited Laidlaw's remedies to repair or replacement. The court further reasoned that the limited remedy did not fail of its essential purpose, that the contract exclusively governed the parties' duties so as to bar negligence claims, and that indemnification was unavailable for Laidlaw's direct losses.