Justia North Carolina Supreme Court Opinion Summaries

In this case, the plaintiff, Frankie Delano Washington, was convicted of various serious felony offenses. During his trial, he asserted that his constitutional right to a speedy trial had been violated. His argument was initially rejected, but later won on appeal and his convictions were set aside. Subsequently, Washington and his son filed a suit against the State and various state and local officials, alleging that the State knowingly charged him for crimes he did not commit. Among the numerous claims brought forth, Washington argued for a common law claim against the State for damages caused by the deprivation of his state constitutional right to a speedy trial.However, the Supreme Court of North Carolina held that Washington had an adequate state law remedy and therefore, a separate Corum claim was not available. The court reasoned that the plaintiff had already received a meaningful remedy for the State's violation of his rights, as his criminal convictions had been permanently set aside. The court further clarified that an "adequate remedy" is one that meaningfully addresses the constitutional violation, even if the plaintiff might prefer a different form of relief. This decision upholds the foundational principle that a Corum claim is applicable when one's rights are violated, and the law offers either no remedy or a remedy that is meaningless. The court ultimately affirmed the decision of the Court of Appeals, which had upheld the trial court's entry of summary judgment. View "Washington v. Cline" on Justia Law

This case was brought before the Supreme Court of North Carolina to determine whether a person who files a motion to claim exempt property after a judgment is entered makes a general appearance in the action and thereby waives objections to the sufficiency of service of process and personal jurisdiction.The plaintiff, John Slattery, alleged that he was induced to invest $500,000 in a sham technology company, Appy City, by defendants Timothy Fields and Melissa Crete. Later, he named additional defendants, including Daisy Mae Barber, alleging they conspired to hide the invested funds by converting them into cryptocurrency. The Business Court entered default judgment against all defendants, including Barber, when they failed to respond to the complaint. Barber first appeared in the case when she filed a motion to claim exempt property. Later, she moved to set aside the entries of default and summary judgment, arguing the Business Court’s judgment was void for lack of personal jurisdiction as she had not been served with process nor appeared in the action before the entry of summary judgment.The Supreme Court of North Carolina held that when a defendant makes a general appearance in an action after the entry of a judgment, she waives any objections to the lack of personal jurisdiction or the sufficiency of service of process if she does not raise those objections at that time. Therefore, Barber, by filing a motion to claim exempt property, made a general appearance in the underlying action and did not raise her objections to personal jurisdiction or the sufficiency of service of process until over three months later. As a result, she waived these objections, and the Business Court’s judgment may be enforced. The decision of the Business Court was affirmed. View "Slattery v. Appy City, LLC" on Justia Law

The Supreme Court of North Carolina reversed a decision by the Court of Appeals regarding the interpretation of a clause in the Financial Responsibility Act (FRA) about underinsured motorist (UIM) coverage. The defendant, Mr. Hebert, was in a vehicle accident where multiple parties were injured, and he sought to claim UIM coverage under his policy and his parents' policy. The Court of Appeals had allowed him to "stack" or add together the UIM limits from both policies to qualify his vehicle as underinsured. However, the Supreme Court disagreed with this interpretation.The court held that the FRA's plain language only permits the claimant’s UIM coverages that pertain to the vehicle involved in the accident, not all UIM policies for which the UIM claimant is personally eligible. Therefore, the defendant could not stack his policy’s UIM limits with his parents’ policy’s UIM limits to qualify his vehicle as underinsured. The court concluded that the defendant's vehicle did not qualify as an underinsured highway vehicle under the FRA, and he could not activate his policy’s UIM coverage. Consequently, the Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for entry of judgment on the pleadings in favor of the plaintiff, North Carolina Farm Bureau Mutual Insurance Company. View "N.C. Farm Bureau Mut. Ins. Co. v. Hebert" on Justia Law

In a case before the Supreme Court of North Carolina, the plaintiff, David Beavers, brought civil claims for alienation of affection and criminal conversation against his ex-wife’s alleged lover, John McMican. The main issues revolved around the interpretation of N.C.G.S. § 52-13 which specifies that post-separation conduct cannot give rise to liability, and whether the trial court improperly granted summary judgment in favor of McMican.The court determined that the Rodriguez v. Lemus decision, regarding what evidence is relevant to prove pre-separation conduct, was consistent with the legislative intent of N.C.G.S. § 52-13. The court held that evidence of post-separation conduct may be used to corroborate pre-separation conduct, as long as the pre-separation conduct gives rise to more than mere conjecture.However, the court found that the evidence of pre-separation conduct in this specific case did not rise above mere conjecture regarding the identity of Mrs. Beavers’ paramour. Consequently, the court reversed the decision of the Court of Appeals and held that the trial court properly granted summary judgment in favor of Mr. McMican. No sufficient evidence was presented to support the essential elements of Beavers’s claims against McMican, namely the sexual intercourse element of the criminal conversation claim, or the malice prong of the alienation of affection claim. View "Beavers v. McMican" on Justia Law

In this case, the Supreme Court of North Carolina was asked to consider whether the Court of Appeals erred in reversing and remanding the trial court’s decision to grant summary judgment in favor of the defendant, a landlord, in a lawsuit brought by the plaintiff, a tenant. The plaintiff had suffered serious burns in an explosion caused by a gas leak in the rental property. He claimed that the landlord had been negligent, violated the Residential Rental Agreements Act (RRAA), and breached the implied warranty of habitability.The Supreme Court held that the Court of Appeals erred in reversing the trial court’s decision. The Court found that the plaintiff had failed to provide any evidence that he had notified the landlord of the issues with the flooring or the heating system, or that the landlord had any actual knowledge of these issues. Consequently, the landlord's duty under the RRAA had not yet arisen. Therefore, the landlord could not be held liable for negligence, violation of the RRAA, or breach of the implied warranty of habitability.The Court further clarified that the RRAA does not completely abrogate the common law principle of caveat emptor (let the buyer beware) in relation to repairs and dangerous conditions on leased residential premises. The RRAA only imposes a duty on the landlord to make repairs after receiving notice or acquiring actual knowledge of the need for them. Therefore, the Court reversed the decision of the Court of Appeals on all of the plaintiff's claims, reinstated the trial court's order granting summary judgment in favor of the defendant, and dismissed the matter. View "Terry v. Pub. Serv. Co. of N.C" on Justia Law

In this case, the Supreme Court of North Carolina was asked to determine whether defendant Cassie Herring, who was injured in a car accident, qualifies for benefits under the underinsured motorist (UIM) coverage of her mother and stepfather's automobile insurance policy. The policy defined an "insured" to include any "family member" who is a resident of the named insured’s household. The question was whether Herring was a "resident" of her mother's household.Herring was injured while riding in a car with her father, and the driver of the other car was insured. The other driver's insurance company tendered the limit of its policy to Herring. Herring then sought additional coverage under the UIM provision of her mother and stepfather's policy. The insurer, North Carolina Farm Bureau Mutual Insurance Company (Farm Bureau), filed a declaratory judgment action, claiming that Herring was not a resident of her mother’s household and thus did not qualify for the UIM benefits.The trial court granted summary judgment for Herring and her parents, and the Court of Appeals affirmed. Farm Bureau appealed to the Supreme Court of North Carolina, arguing that there were genuine issues of material fact about Herring’s residency.The Supreme Court of North Carolina agreed with Farm Bureau and reversed the decision of the Court of Appeals. The court held that the evidence, when viewed in the light most favorable to Farm Bureau, raised genuine issues of material fact as to whether Herring was a resident of her mother's household at the time of the accident. The court noted that there were discrepancies between Herring's testimony and the affidavits submitted by her and her parents, which created credibility issues that should be resolved by a jury. Therefore, the court concluded that summary judgment was not appropriate, and the case was remanded for further proceedings. View "N.C. Farm Bureau Mut. Ins. Co. v. Herring" on Justia Law

A minor, Freedom Morris, sought emergency treatment for appendicitis at Vidant Medical Center and was operated on by Dr. David Rodeberg. Despite complaining of severe pain after the surgery, Morris was discharged. He returned to the hospital a day later with a fever and sharp abdominal pain. A second surgery performed by a different doctor revealed that not all of the appendix had been removed during the first operation. This had caused a ruptured appendix and infection in Morris' body. Morris underwent a third surgery to drain a pelvic abscess.More than five years after the first surgery, Morris filed a lawsuit against Dr. Rodeberg and Vidant Medical Center alleging medical malpractice and medical negligence. The defendants responded with motions to dismiss the complaint, arguing that the lawsuit was filed outside the statute of limitations for medical malpractice claims of persons who are over ten years old but under eighteen years old when their claims accrue. The trial court denied the defendants' motions, but the Court of Appeals reversed the trial court's order.The Supreme Court of North Carolina held that the three-year statute of limitations barred Morris' medical malpractice claims. The Court reasoned that while the North Carolina General Assembly has recognized that individuals under certain disabilities, including being a minor, are unable to appreciate the nature of potential legal claims and take appropriate action, subsection 1-17(c) of the North Carolina General Statutes eliminates the tolling of the medical malpractice claims of minors, except in certain situations. None of those exceptions applied to Morris' case, so his claim was subject to the standard three-year statute of limitations and was therefore time-barred. The Court did not address Morris' argument that the application of the three-year statute of limitations violated his constitutional right to equal protection of the laws because it did not have jurisdiction to review that issue. View "Morris v. Rodeberg" on Justia Law

The Supreme Court of North Carolina was required to decide whether a trial court can refuse to hear oral testimony during a summary judgment hearing on the mistaken belief that the North Carolina Rules of Civil Procedure prohibit the receipt of such testimony. The plaintiff, a corporation, had sued the defendants for breach of a commercial lease, and the defendants counterclaimed for fraud. During the summary judgment hearing, the trial court declined a request by the defendants to introduce live testimony, asserting that it was not permitted during a summary judgment hearing. The defendants appealed, and the Court of Appeals vacated the trial court's summary judgment order and remanded the case, leading to this appeal.The Supreme Court of North Carolina held that a trial court errs if it fails to exercise its discretion under the misapprehension that it has no such discretion, referring to Rule 43(e) of the North Carolina Rules of Civil Procedure that allows for the introduction of live oral testimony during a summary judgment hearing at the discretion of the trial court. The court found that the trial court was mistaken in its belief that it could not allow oral testimony, and this error warranted vacatur and remand for reconsideration. The Supreme Court thereby modified and affirmed the decision of the Court of Appeals to vacate the trial court's summary judgment order and remand the case. View "D.V. Shah Corp. v. VroomBrands, LLC" on Justia Law

The Supreme Court dismissed for lack of personal jurisdiction a decision of the court of appeals affirming the order of the trial court dismissing Plaintiff's claims against Defendants for lack of personal jurisdiction, holding that this Court was unable to engage in meaningful appellate review of this discretionary decision.The trial court's dismissal order was entered without the court ruling on Plaintiff's motions to compel responses to discovery requests concerning Defendants' contacts with North Carolina. On appeal, the court of appeals concluded that further jurisdictional discovery was unwarranted. The Supreme Court reversed and remanded the case, holding that because the trial court failed to provide reasons for the implied denial of Plaintiff's requests for further jurisdictional discovery this Court could not ascertain whether the court applied an analysis consistent with Ford Motor Co. v. Mont. Eighth Judicial District Court, 141 S. Ct. 1017 (2021). View "Miller v. LG Chem, Ltd." on Justia Law

The Supreme Court affirmed in part and reversed in part an order of the court of appeals in this jurisdictional dispute, holding that the Corporate Defendants intentionally reached out to North Carolina to conduct business activities in the state, and the claims at issue in this case arose from or were related to those activities.After Plaintiff was officially terminated from his employment he brought an action against Individual and Corporate Defendants alleging, inter alia, fraud, misrepresentation, and breach of contract. Defendants moved to dismiss the action. The trial court denied the motions. The court of appeals reversed, holding that the Corporate Defendants' activities alone were not sufficient to establish specific jurisdiction and that Plaintiff's claims did not arise out of, or even relate to, the alleged contacts between Defendants and North Carolina. The Supreme Court reversed the court of appeals' decision as to Corporate Defendants, affirmed with respect to Individual Defendants, and remanded, holding that the trial court may exercise personal jurisdiction over Corporate Defendants pursuant to the Due Process Clause. View "Schaeffer v. SingleCare Holdings, LLC" on Justia Law