Justia North Carolina Supreme Court Opinion Summaries

Cherry Oil is a closely held corporation in eastern North Carolina, primarily owned and managed by members of the Cherry and Mauck families. Armistead and Louise Mauck, who together own 34% of the company’s shares, became involved in the business after Armistead was invited to join during a period of financial difficulty. In 1998, the families formalized their relationship through a Shareholder Agreement, which included provisions allowing either party to force a buyout of shares at fair market value. Over time, disputes arose regarding management and succession, culminating in the Maucks’ removal from the board and Cherry Oil’s attempt to buy out their shares. The buyout process stalled, leaving the Maucks as minority shareholders no longer employed by the company.The Maucks filed suit in Superior Court, Lenoir County, asserting claims for judicial dissolution under N.C.G.S. § 55-14-30, breach of fiduciary duty, constructive fraud, and breach of the Shareholder Agreement. The case was designated a mandatory complex business case and assigned to the North Carolina Business Court. The Business Court dismissed most claims, including the judicial dissolution claim for lack of standing, finding that the Shareholder Agreement’s buyout provision provided an adequate remedy. It also dismissed other claims for reasons such as untimeliness and insufficient factual allegations. The court later granted summary judgment to defendants on the remaining claims, concluding that the actions taken by the Cherry family were valid corporate acts and that the Maucks had not demonstrated breach of duty or contract.On appeal, the Supreme Court of North Carolina held that the Maucks did have standing to seek judicial dissolution but affirmed the dismissal of that claim under Rule 12(b)(6), finding that the Shareholder Agreement’s buyout provision provided a sufficient remedy and that the complaint did not allege facts showing dissolution was reasonably necessary. The Supreme Court otherwise affirmed the Business Court’s rulings. View "Mauck v. Cherry Oil Co." on Justia Law

In 2023, Charlotte Chemuti was arrested by officers from the Mooresville Police Department for resisting a public officer. To prepare for her trial, Chemuti served a subpoena on the police department requesting body camera footage related to her arrest. The Town of Mooresville responded, arguing that the requested recordings were confidential under North Carolina General Statute § 132-1.4A and could only be released through the procedure outlined in that statute, not by subpoena.Chemuti subsequently filed a motion in the District Court of Iredell County, without notice to the town, seeking release of the recordings. The district court granted her request, finding that while the statutory petition in superior court was the generally accepted practice, it was not the exclusive method for obtaining such evidence, and ordered the town to comply with the subpoena. The town appealed to the North Carolina Court of Appeals, which dismissed the appeal for lack of appellate jurisdiction, concluding that the order did not affect a substantial right. The town then petitioned the Supreme Court of North Carolina for review.The Supreme Court of North Carolina held that orders compelling disclosure of information protected by statutory confidentiality are immediately appealable, and the Court of Appeals erred in dismissing the appeal. On the merits, the Supreme Court determined that N.C.G.S. § 132-1.4A provides the exclusive procedure for obtaining law enforcement recordings in criminal cases, requiring a petition in superior court, and that district court subpoenas cannot be used to compel their release. The Court further held that this procedure does not violate constitutional rights to present a complete defense, as courts must still ensure defendants’ constitutional protections. The Supreme Court vacated the district court’s order and remanded for further proceedings. View "State v. Chemuti" on Justia Law

Law enforcement officers investigated a breaking and entering at a market in Fletcher, North Carolina, where cash, cigarettes, and lottery tickets were stolen. Days later, someone attempted to redeem one of the stolen lottery tickets at a store in Edneyville. Security footage showed a woman leaving the store and entering a black Dodge Durango with distinctive features. Detective Diaz traced the vehicle to a nearby residence, discovered it had a fictitious license plate, and observed items inside the vehicle that appeared related to the theft. Officers later conducted a search of the vehicle and the residence, recovering stolen property and tools linked to the crime.The Superior Court of Henderson County denied the defendant’s motion to suppress evidence, which argued that law enforcement’s observations at the residence and of the vehicle were improper without a warrant. The defendant subsequently pled guilty to several charges but reserved the right to appeal the suppression ruling. The North Carolina Court of Appeals affirmed the trial court’s decision, holding that probable cause existed for the search warrant and that officers acted lawfully at the scene. The majority also found that the inevitable discovery doctrine would apply, while a dissenting judge disagreed on both points.The Supreme Court of North Carolina reviewed the case and held that, even excluding information obtained during the contested “knock and talk,” the remaining facts in the warrant affidavit established probable cause to search the vehicle. The Court did not decide whether the officers’ conduct during the knock and talk was unconstitutional, nor did it address the inevitable discovery doctrine. The Court modified and affirmed the decision of the Court of Appeals, holding that the search warrant was properly issued based on probable cause supported by untainted evidence. View "State v. Norman" on Justia Law

During the early months of the COVID-19 pandemic, a patient received medical care that included a hysterectomy performed by a physician at a local medical center. Following the procedure, the patient experienced significant complications, including infection, sepsis, and additional surgeries, which led to prolonged recovery and ongoing health issues. The patient and her husband filed a lawsuit against the physician, the medical practice, and the hospital, alleging negligence and gross negligence in the performance of the surgery and subsequent care.The defendants moved to dismiss the lawsuit, arguing that they were immune from civil liability under North Carolina’s Emergency or Disaster Treatment Protection Act, which was enacted in response to the pandemic. They asserted that the Act provided them with immunity because the care was rendered during the pandemic and was impacted by it, and that the complaint did not allege bad faith. The Superior Court in Pitt County denied the motions to dismiss. The defendants appealed, and the North Carolina Court of Appeals affirmed the trial court’s order, holding that the requirements for statutory immunity under the Emergency Act were not met on the face of the complaint and that the denial of the motions to dismiss was not immediately appealable as a matter of right.The Supreme Court of North Carolina reviewed the case and held that the trial court’s denial of the motions to dismiss was an interlocutory order and not immediately appealable. The Court concluded that the Emergency Act provides immunity from liability, not from suit, and therefore does not create a substantial right warranting immediate appeal. The Court also found that the denial of the motions did not implicate personal jurisdiction under the relevant statute. As a result, the Supreme Court vacated the Court of Appeals’ judgment and remanded the case for further proceedings. View "Land v. Whitley" on Justia Law

The case concerns the North Carolina Department of Environmental Quality (DEQ), which is responsible for issuing permits for animal waste management systems. In 2019, the DEQ added three new conditions to its general permits for swine, poultry, and cattle operations: requirements for monitoring wells in floodplains, a Phosphorous Loss Assessment Tool analysis with mitigation, and annual reporting. These conditions were not present in the previous 2014 permits but were included in a draft permit as part of a 2018 settlement with environmental groups. The North Carolina Farm Bureau Federation challenged the new conditions, arguing that the DEQ had not followed the rulemaking procedures required by the North Carolina Administrative Procedure Act (APA).The Office of Administrative Hearings (OAH) granted summary judgment to the Farm Bureau, finding that the new conditions were “rules” under the APA and thus invalid because they had not been adopted through the required rulemaking process. The Superior Court, Wake County, reversed the OAH, holding that the conditions were not “rules” because they only applied to those who opted for general permits, not all permittees, and thus lacked general applicability. The court also cited legislative history and statutory language to support its conclusion.The North Carolina Court of Appeals reversed the Superior Court, holding that the conditions were generally applicable regulations and thus “rules” under the APA, requiring formal rulemaking. The Supreme Court of North Carolina affirmed the Court of Appeals, holding that the three general permit conditions are “rules” within the meaning of the APA and are invalid until adopted through the APA’s rulemaking process. The court clarified that while general permits themselves need not be adopted as rules, generally applicable conditions within them must be. View "N.C. Dep't of Env't Quality v. N.C. Farm Bureau Fed'n, Inc." on Justia Law

The defendant was indicted on multiple charges, including two counts of first-degree murder, stemming from an armed robbery in which two victims were killed and another was left paralyzed. During jury selection at his trial in Cleveland County Superior Court, the State used peremptory challenges to excuse two black female prospective jurors. The defense objected, raising a Batson challenge and arguing that the State’s strikes were racially discriminatory. The trial court heard arguments from both sides, including the State’s race-neutral explanations for the strikes, and ultimately denied the Batson challenge, finding no prima facie case of discrimination.Following his conviction on all charges and sentencing to consecutive life terms plus additional imprisonment, the defendant appealed. The North Carolina Court of Appeals, in a divided decision, found that the trial court had moved past Batson’s first step by soliciting and hearing the State’s race-neutral reasons before ruling. The majority held that this rendered the first step moot and remanded the case for a new Batson hearing under the procedural requirements established in State v. Hobbs, 374 N.C. 345 (2020). The dissent argued that the trial court had not actually proceeded to Batson’s third step and that the first step was not moot.The Supreme Court of North Carolina reviewed whether the Court of Appeals erred in holding Batson’s first step moot and remanding for a new hearing. The Supreme Court held that the mootness exception to Batson’s three-step process is to be applied cautiously and only when the trial court has fully completed all three steps. Because the trial court had clearly ruled at step one and had not proceeded to step three, the Supreme Court reversed the Court of Appeals and remanded for consideration of whether the trial court’s step-one determination was clearly erroneous. View "State v. Wilson" on Justia Law

A health care provider operating imaging centers in Wake County, North Carolina, and a major hospital system both applied for a Certificate of Need (CON) to acquire a new fixed MRI scanner, as required by state law. The state’s 2021 plan determined that only one additional scanner could be approved in the county. The provider sought to place the scanner in Wake Forest, while the hospital system proposed a location in Raleigh. After a competitive review, the North Carolina Department of Health and Human Services awarded the CON to the hospital system, finding its application more effective under certain comparative factors.The provider challenged this decision in the Office of Administrative Hearings, alleging the agency’s review was flawed and prejudicial. The administrative law judge (ALJ) found that the agency’s comparative analysis contained errors, deviated from established practices, and was based on subjective judgment rather than expertise or proper procedure. The ALJ reversed the agency’s decision and awarded the CON to the provider, also finding that the provider suffered substantial prejudice from the denial.On appeal, the North Carolina Court of Appeals affirmed the ALJ’s decision, holding that the appellants failed to challenge specific findings of fact, which made those findings binding on appeal. The court applied the whole record review standard, focusing on whether substantial evidence supported the ALJ’s decision.The Supreme Court of North Carolina reviewed the case and held that, under current law, the ALJ’s final decision—not the agency’s—is the focus of judicial review, and a high degree of deference is owed to the ALJ’s findings. The Court affirmed the lower court’s judgment regarding the comparative analysis but reversed on the issue of substantial prejudice, finding that the provider, as a denied applicant, was inherently prejudiced by the agency’s decision. The award of the CON to the provider was affirmed. View "Pinnacle Health Servs. of N.C. LLC v. N.C. Dep't of Health & Hum. Servs" on Justia Law

A tenured professor at Winston-Salem State University was terminated in 2017 for failing to fulfill essential job duties, including grading and teaching, and for sending a letter to a colleague containing offensive racial slurs. The professor challenged his dismissal through the university’s administrative process, arguing, among other things, that the university did not follow its own rules and regulations regarding the termination of tenured faculty.The case proceeded from the university’s Board of Trustees to the University of North Carolina Board of Governors, then to the Superior Court in Forsyth County, and finally to the North Carolina Court of Appeals. At each stage, the professor’s claims were rejected. The Court of Appeals held that courts must defer to an agency’s interpretation of its own regulations unless that interpretation is plainly erroneous, relying on federal law principles.The Supreme Court of North Carolina reviewed the case to clarify the standard for judicial review of state agency interpretations of their own regulations. The court held that, under North Carolina law, courts must apply de novo review to state agency interpretations of state rules and regulations, meaning courts are not bound by the agency’s interpretation but may consider it as informative. The court expressly rejected any rule requiring judicial deference to state agencies’ interpretations of their own regulations and overruled contrary lower court precedent. On a separate issue, the court determined that the Court of Appeals dissent erred in suggesting a remand was necessary for further First Amendment analysis, holding that appellate courts may resolve such legal questions de novo without remand if the issue was preserved. The Supreme Court modified and affirmed the judgment of the Court of Appeals. View "Mitchell v. Univ. of N.C. Bd. of Governors" on Justia Law

Law enforcement in New Hanover County received information from a confidential source that the defendant was trafficking and distributing large quantities of cocaine. Based on this tip, Detective Wenk applied for a court order to obtain cell-site location information (CSLI) for the defendant’s phone, along with other investigative tools. The trial court found probable cause and granted the order, allowing law enforcement to monitor the defendant’s CSLI. This data showed the defendant’s phone traveling from Wilmington, North Carolina, to Hayward, California, and back, coinciding with suspected drug trafficking activity. Officers later stopped and searched the defendant’s vehicle, discovering trafficking amounts of cocaine. The defendant was indicted on multiple drug-related charges and moved to suppress the evidence obtained from the CSLI and subsequent searches.The Superior Court of New Hanover County denied the motion to suppress, finding reasonable suspicion supported the order and the vehicle stop. The defendant entered an Alford plea but appealed the suppression ruling. The North Carolina Court of Appeals reversed the trial court’s decision, holding that the order for CSLI was not supported by probable cause as required by the Fourth Amendment, and that the evidence should be suppressed. The appellate court rejected the State’s argument that a statutory good faith exception applied, citing prior precedent that the North Carolina Constitution did not recognize such an exception.The Supreme Court of North Carolina reviewed the case and held that the statutory good faith exception in N.C.G.S. § 15A-974 applies only to evidence obtained in substantial violation of Chapter 15A, not to evidence obtained in violation of constitutional rights. However, the court further held that neither the United States Constitution nor the North Carolina Constitution required exclusion of the CSLI in this case, and formally adopted a good faith exception under the state constitution equivalent to the federal standard. The Supreme Court reversed the Court of Appeals, upholding the trial court’s denial of the suppression motion. View "State v. Rogers" on Justia Law

Melvin Joseph Long was fatally injured while working on an industrial chiller at North Carolina State University. The chiller, which had been improperly winterized by university maintenance employees, developed internal pressure after water left in its tubes froze and caused the tubes to burst, allowing refrigerant to enter and pressurize the system. When Long, an OSHA-certified pipefitter, attempted to remove a flange from the chiller, the pressurized component caused the flange to detach explosively, striking him and resulting in his death.After the incident, Long’s estate filed a wrongful death action in the Superior Court of Person County against the university employees involved. The trial court granted summary judgment for the defendants, finding no genuine issue of material fact and concluding that the defendants were entitled to judgment as a matter of law. The estate appealed, arguing that issues of foreseeability and contributory negligence should have precluded summary judgment. The North Carolina Court of Appeals affirmed the trial court’s decision, holding that the accident was not a foreseeable result of the defendants’ actions and, alternatively, that contributory negligence barred recovery.The Supreme Court of North Carolina reviewed the case de novo. It held that the uncontradicted evidence demonstrated the accident resulted from an unforeseeable sequence of events, and that foreseeability is a necessary element of proximate cause for actionable negligence. The Court found that neither the defendants’ training nor the equipment manuals provided any basis to reasonably foresee the type of injury that occurred. Accordingly, the Supreme Court of North Carolina affirmed the decision of the Court of Appeals, upholding summary judgment for the defendants. View "Long v. Fowler" on Justia Law