Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals that Respondent's due process rights were not violated in the proceedings which led to the trial court's conclusion that Respondent had a mental illness and was dangerous to himself, holding that there was no error.At the end of a hearing, the trial court concluded that Respondent had a mental illness and was a danger to himself and entering a thirty-day commitment order. At issue was whether the trial court, in the absence of counsel for the state, called witnesses and elicited testimony during the hearing. The Supreme Court affirmed, holding that the trial court did not violate Respondent's due process right to an impartial tribunal. View "In re J.R." on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that the trial court complied with the procedure implemented in N.C. Gen. Stat. 15A-1201(d)(1) by the legislature for the trial court to consent to Defendant's waiver of his right to a jury trial for the status offense of habitual felon, holding that the court of appeals did not err.After a colloquy on the record, in which Defendant gave notice in open court of his waiver of a jury trial, the trial court proceeded with a bench trial and found Defendant guilty of multiple drug-related offenses. Before the court proceeded with the phase of the trial addressing the habitual felon status offense, Defendant signed and acknowledged under oath another waiver of jury trial form. On appeal, Defendant argued that the trial court abused its discretion in how it personally addressed him and in determining that he fully understood and appreciated the consequences of his decision to waive the right to trial by jury. The Supreme Court affirmed, holding that that the court of appeals did not err by concluding that the trial court complied with the procedure set forth in N.C. Gen. Stat. 15A-1201(d)(1) for the court to consent to Defendant's waiver of his right to a jury trial for the habitual felon offense. View "State v. Rollinson" on Justia Law

The Supreme Court affirmed in part and reversed in part the court of appeals' decision affirming in part and dismissing in part the judgment of the trial court determining that Insurers were obligated to defend and indemnify Radiator Specialty Company (RSC) under its policies by reimbursing $1.8 million of RSC's past costs, holding that the court erred in part.RSC sought compensation from the three insurers (Insurers) remaining in this action for liabilities it incurred as a result of litigation occasioned by bodily injury caused by repeated exposure to benzene, which RSC manufactured. At issue was which insurers were obligated to pay which costs arising from RSC's benzene liabilities pursuant to the terms of the Insurers' liability insurance policies. The Supreme Court held that the trial court (1) correctly applied an exposure-based approach in determining at what point Insurers' coverage was triggered; (2) properly applied pro rata allocation based on the policies; and (3) in finding that horizontal exhaustion - rather than vertical exhaustion - applied to one insurer's duty to defend. View "Radiator Specialty Co. v. Arrowood Indemnity Co." on Justia Law

The Supreme Court affirmed the judgment of the trial court finding that Senate Bill 824 (S.B. 824), the statute enacted to require that every voter present one of a few specific forms of photo identification, was enacted with a racially discriminatory purpose, holding that the trial court's findings of fact were supported by competent evidence showing that the statute was motivated by a racially discriminatory purpose.In challenging S.B. 824, Plaintiffs alleged that the law was enacted at least in part with the intent to discriminate against African-American voters. The Supreme Court affirmed, holding (1) the trial court's finding that S.B. 824 was motivated by racial discrimination was supported by competent evidence in the record; and (2) the trial court correctly applied the factors set forth in Village of Arlington Heights v. Metropolitan Housing Development Corp., 429 U.S. 252 (1977) when it found that the law was enacted at least in part with racially discriminatory intent. View "Holmes v. Moore" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating Defendant's conviction of second-degree murder on the grounds that the trial court committed prejudicial error by declining to deliver Defendant's proffered jury instruction on involuntary manslaughter, holding that Defendant was entitled to a new trial.Defendant was convicted of the murder of his wife. On appeal, Defendant argued that the trial court erred in failing to submit his requested jury instruction on involuntary manslaughter because the jury could have found that he assaulted his wife in a culpably negligent manner or that his failure to render aid was a culpably negligent omission. The court of appeals agreed and vacated the conviction. The Supreme Court affirmed, holding that the trial court committed prejudicial error by declining Defendant's request to issue a pattern jury instruction on involuntary manslaughter. View "State v. Brichikov" on Justia Law

The Supreme Court reversed the decision of the business court concluding that the sales of printed materials produced by Petitioner, which was based in Wisconsin, out of state and shipped to its North Carolina customers and their designees lacked a sufficient nexus to North Carolina for the imposition of state sales tax, holding that the business court erred.At issue on appeal was whether the Supreme Court of the United States' decision in McLeod v. J.E. Dilworth Co., 322 U.S. 327 (1944), remained controlling precedent or if subsequent Supreme Court decisions provided an alternative method for determining the constitutionality of North Carolina's sales tax regime. The Supreme Court held (1) the formalism doctrine established in Dilworth did not survive the decisions of the United States Supreme Court in Complete Auto Transit Inc. v. Brady, 430 U.S. 274 (1977) and South Dakota v. Wayfair, Inc., 138 S. Ct. 2080 (2018) so as to render the sales tax regime of North Carolina in violation of the Commerce Clause and Due Process Clause; and (2) North Carolina's imposition of sales tax on the transactions at issue was constitutional under Complete Auto. View "Quad Graphics, Inc. v. N.C. Dep't of Revenue" on Justia Law

The Supreme Court affirmed the decision of the court of appeals finding no error in Defendant's sentences, holding that the trial court did not abuse its discretion in declining to reduce Defendant's sentence due to Defendant's rendition of substantial assistance.Defendant pleaded guilty to trafficking a controlled substance and possession of a firearm by a felon. At sentencing, the trial court declined Defendant's invitation to make a downward adjustment to his sentence in light of the assistance he provided to law enforcement officers in their criminal investigation. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in sentencing Defendant. View "State v. Robinson" on Justia Law

In this interlocutory appeal, the Supreme Court affirmed the order of the trial court compelling discovery pursuant to N.C. R. Civ. P. 37, holding that the trial court was not required to make findings of fact to support its ruling.Plaintiff brought an action for wrongful death against the defendants from which the decedent sought medical care. At issue was Plaintiff's motion to compel Defendants to comply with an existing discovery order. The trial court granted the motion but did not make specific findings of fact. The court of appeals remanded the case for the trial court to enter factual findings and conclusions of law. The Supreme Court reversed, holding (1) Defendants did not specifically request findings of fact regarding the statutory elements set forth in N.C. Gen. Stat. 90-21.22A; and (2) in the absence of such a request, the trial court was not required to make any findings of fact in resolving Plaintiff's motion to compel. View "Williams v. Allen" on Justia Law

The Supreme Court reversed portions of the court of appeals' opinion that found error in certain portions of the trial court's order eliminating reunification as a permanent plan and ceasing further review hearings in a neglect and dependency case concerning Mother's child, holding the trial court did not err.The trial court entered the order eliminating reunification as a permanent plan only after it found that an alternate permanent plan of custody with a court-approved caretaker had been achieved and after the court had received evidence showing that the court-approved caretakers understood the legal significance of the child's placement in their home. The court of appeals vacated the order and remanded the case. The Supreme Court reversed in part, holding that the court of appeals erred in determining that the trial court erred in ceasing reunification efforts and in failing to fulfill its statutory obligations concerning verification. View "In re K.P." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court determining that Defendant's behavior was sufficiently egregious to warrant the forfeiture of her right to counsel, holding that Defendant was entitled to a new trial.Defendant was charged with attempting to possess a firearm while subject to an ex parte Domestic Violence Protection Order prohibiting the same. After a trial, at which Defendant proceeded pro se, the jury found Defendant guilty. The court of appeals affirmed. Defendant appealed, arguing that the court of appeals erred in holding that Defendant waived her right to counsel or alternatively forfeited her right to counsel. The Supreme Court agreed and reversed, holding (1) the issue of waiver was inapposite because Defendant expressly requested the appointment of counsel; and (2) the trial court erred in its alternate determination that Defendant's behavior was sufficiently egregious to warrant the forfeiture of the right to counsel. View "State v. Atwell" on Justia Law