Carrigan v. Nev. Comm'n on Ethics
Annotate this CaseIn Carrigan I, the Nevada Supreme Court held that city councilman Michael Carrigan's vote on the Lazy 8 hotel/casino project constituted protected speech under the First Amendment. The U.S. Supreme Court held that Carrigan's vote on the Lazy 8 project did not constitute protected speech, thus reversing the Nevada Supreme Court decision that the First Amendment overbreadth doctrine invalidated the conflict-of-interest recusal provision in Nevada's Ethics in Government Law. On remand, Carrigan challenged the constitutional validity of the core conflict-of-interest recusal provisions in Nevada's Ethics in Government Law. The Supreme Court affirmed, holding (1) the conflict-of-interest recusal provision in Nevada's Ethics in Government Law is not unconstitutionally vague; and (2) the conflict-of-interest recusal provision does not unconstitutionally burden the First Amendment freedom-of-association rights shared by Nevada's elected officials and their supporters.
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