Justia North Carolina Supreme Court Opinion Summaries

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 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

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals dismissing the complaint in this case involving the removal of a Confederate monument with prejudice, holding that dismissal should have been without prejudice.After the City of Winston Salem decided to remove a Confederate monument from the grounds of the former Forsyth County Courthouse Plaintiff, the United Daughters of the Confederacy, North Carolina Division, Inc., filed a complaint against the City and County seeking the issuance of a temporary restraining order and preliminary injunction enjoining Defendants from taking affirmative action to remove or relocate the monument prior to full adjudication of the respective rights of the parties. The trial court dismissed the case with prejudice, concluding that Plaintiff failed establish standing and failed to state a claim upon which relief could be granted. The court of appeals affirmed. The Supreme Court reversed in part, holding that the trial court (1) did not err by dismissing the amended complaint for lack of standing; but (2) erred by dismissing the complaint with, rather than without, prejudice. View "United Daughters of the Confederacy, N.C. Division v. City of Winston-Salem" on Justia Law

The Supreme Court held that the trial court did not violate Defendant's due process rights by proceeding with Defendant's involuntary commitment hearing when Defendant was not represented by counsel and that the trial court's factual findings were sufficient to support its conclusion that Defendant was dangerous to herself.Specifically, the Supreme Court held (1) the trial court did not violate Defendant's due process rights; (2) Defendant preserved her right to challenge the trial court's incorporation of a non-testifying physician's exam report into its findings of fact, and the trial court committed harmless error by incorporating the report into its findings of fact; and (3) the court of appeals correctly held that the trial court made sufficient findings of fact based on the evidence presented by the testifying witness to support its involuntary commitment decision. View "In re R.S.H." on Justia Law

The Supreme Court held that a deceased employee's prior timely filing of a workers' compensation claim for an injury was sufficient to establish the Industrial Commission's jurisdiction over a dependent's subsequent claim for death benefits allegedly resulting from that injury, thus reversing the court of appeals' ruling below.The Commission in this case denied Plaintiff's claim for death benefits and dismissed the claim with prejudice on the grounds that Plaintiff's untimely filing could not grant the Commission jurisdiction over the claim. The court of appeals affirmed. The Supreme Court reversed, holding that the decedent's timely claim established the Commission's jurisdiction over this matter. View "McAuley v. N.C. A&T State University" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating the judgments entered upon Defendant's convictions for multiple serious felonies, including first-degree murder, holding that the record did not support the trial court's determination that Defendant's actions were sufficiently obstructive to constitute a forfeiture of his right to counsel.Defendant was indicted on charges of first-degree murder, attempted first-degree murder, and other crimes. The trial court decided before trial that Defendant's actions forfeited his opportunity to have assigned counsel, and Defendant proceeded pro se. The jury returned guilty verdicts on all offenses, and Defendant was sentenced to life imprisonment for the murder conviction. The court of appeals awarded Defendant a new trial, determining that the trial court deprived Defendant of his constitutional right to counsel by concluding that he had forfeited that right. The Supreme Court affirmed, holding that Defendant was entitled to a new trial because he did not engage in the type of egregious misconduct that would permit the trial court to deprive him of his constitutional right to counsel. View "State v. Harvin" on Justia Law

The Supreme Court affirmed the order of the trial court denying the motion for class certification brought by Plaintiffs, inmates in North Carolina Department of Public Safety (DPS) custody, seeking to represent certain individuals in DPS custody who are being or will be subjected to solitary confinement, holding that the trial court did not abuse its discretion.Plaintiffs filed a class action lawsuit seeking to certify a class of current and future inmates assigned to one of five restrictive housing classifications, alleging that the conditions of confinement constituted cruel or unusual punishment. The trial court denied Plaintiffs' motion for class certification, finding that a certifiable class did not exist. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in concluding that Plaintiffs failed to demonstrate a common predominating issue among the proposed class members. View "Dewalt v. Hooks" on Justia Law

The Supreme Court exercised is constitutional power to address constitutional violations through equitable remedies by affirming and reinstating the trial court's directive instructing certain State officials to transfer the funds necessary to comply with years two and three of the State's comprehensive remedial plan (CRP), holding that this Court has an obligation to safeguard the constitutional rights of North Carolina's schoolchildren.In November 2021, the trial court issued the order before the Supreme Court for review. In the order, the trial court declared that the State had failed to fulfill its constitutional obligations to provide school children, especially those at risk and socioeconomically disadvantaged, their constitutional right to a sound basic education. The trial court ordered the State to transfer the total amount of funds necessary to effectuate years two and three of the CRP. The State Controller sought an order preventing her from being required to comply with the trial court's order. The court of appeals issued a writ of prohibition restraining the trial court from proceeding in the matter. Thereafter, the trial court issued an order removing that transfer directive. The Supreme Court stayed the writ of prohibition and reinstated the trial court's November 2021 directive, holding that the judiciary must fulfill its obligation to protect the fundamental rights of the State's individuals. View "Hoke County Bd. of Education v. State" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals upholding the revocation of Defendant's probation, holding that Defendant's confrontation argument under N.C. Gen. Stat. 15A-1345(e) was not preserved.Defendant pleaded guilty to discharging a weapon into occupied property and possession of a firearm by a convicted felon. Later, Defendant's probation was revoked following a determination that he had committed new criminal offenses. On appeal, Defendant argued that the trial court violated his constitutional right to confront witnesses against him at the probation hearing. The court of appeals affirmed, holding that there was no Sixth Amendment violation in this case. The Supreme Court modified and affirmed the judgment below, holding (1) a defendant's arguments under N.C. Gen. Stat. 15A-1345(e) are preserved when a defendant lodges a proper objection or the trial court does not permit confrontation and fails to make a finding of good cause; and (2) the condition requiring a finding of good cause was not satisfied in this case. View "State v. Jones" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the order of the trial court denying Nation Ford Baptist Church Inc.'s (Church) motion to dismiss the underlying complaint with respect to Pastor Phillip R.J. Davis's claim for a declaratory judgment, holding that certain claims must be dismissed for lack of subject matter jurisdiction.Pastor Davis filed a complaint against the Church and Nation Ford's Board of Directors, arguing that the Board exceeded its authority under the Church's corporate bylaws when it purported to terminate him by vote of the Board because the governing bylaws allowed termination only by vote of the Church's congregation at a special general meeting. The trial court denied the Church's motion to dismiss, and the court of appeals affirmed. The Supreme Court reversed in part, holding (1) Pastor Davis's claim for a declaratory judgment regarding the various bylaws can proceed; and (2) First Amendment principles required the dismissal of Pastor Davis's other claims. View "Nation Ford Baptist Church, Inc. v. Davis" on Justia Law