Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court modified the decision of the court of appeals, which held that the trial court lacked a sufficient factual basis to accept Defendant's guilty plea, holding that the trial court lacked a sufficient factual basis to accept Defendant's guilty plea but that the guilty plea must be accepted or rejected as a whole, not in part.The trial court sentenced Defendant to separate and consecutive sentences based on several assault charges arising from one assaultive episode. The court of appeals reversed, concluding that the State did not provide a sufficient factual basis for the trial court to enter judgments on multiple assault charges. The court then remanded the case with instructions to arrest two lesser judgments and to repentance Defendant on the remaining charges. The Supreme Court affirmed as modified, holding (1) the facts presented at the plea hearing did not establish that a distinct interruption occurred between assaults, and therefore, the court of appeals properly found that the trial court lacked a sufficient factual basis to accept Defendant's guilty plea; and (2) there was no basis for rejecting Defendant's guilty plea in part. View "State v. Robinson" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's conviction for driving while impaired, holding that even if the admission of certain testimony was erroneous under N.C. R. Evid. 701, Defendant failed to meet his burden of showing that such assumed error was prejudicial.At issue was the testimony of Officer Henry Carssow, who responded at the scene of a moped accident in which Defendant was involved. Officer Carssow applied for a search warrant to obtain a sample of Defendant's blood to check his blood alcohol concentration. A magistrate executed and signed the application. After Defendant's blood was drawn he was charged and ultimately convicted of unlawfully and willfully operating a motor vehicle while subject to an impairing substance. The court of appeals vacated Defendant's conviction, ruling that the trial court committed prejudicial error by admitting Officer Carssow's lay witness opinion that Defendant was driving the moped at the time of the accident. The Supreme Court reversed, holding (1) Officer Carssow's testimony was properly preserved for appeal; and (2) even if the admission of the testimony was erroneous, Defendant failed to show that such assumed error was prejudicial. View "State v. Delau" on Justia Law

The Supreme Court affirmed the orders of the trial court terminating Mother's parental rights to her daughter, holding that there was no error. After a termination hearing, the trial court determined that grounds existed to terminate Mother's parental rights under N.C. Gen. Stat. 7B-1111(a)(1) and (2) and that it was in the child's best interests to terminate Mother's parental rights. On appeal, Mother argued that the trial court erred by concluding that terminating her parental rights was in the child's best interests. The Supreme Court affirmed, holding that the court did not abuse its discretion by determining that termination of Mother's parental rights was in the child's best interests. View "In re H.R.S." on Justia Law

The Supreme Court held that the court of appeals erred in concluding that more than 220,000 former State employees (the Retirees) possessed no vested rights within the meaning of the Contracts Clause to the benefit of lifetime enrollment in any particular premium-free health insurance plan, holding that the trial court correctly concluded that the Retirees had obtained a vested right protected under the Contracts Clause.After the General Assembly enacted a statute eliminating Retirees' option to remain enrolled in the plan of their choice, the Retirees argued that the State had undertaken a contractual obligation to provide them with the option to remain enrolled in the premium-free preferred provider organization health insurance plan that allocated eighty percent of the costs of health care services to the insurer and twenty percent to the insured for life. The trial court entered partial summary judgment for Retirees. The court of appeals reversed and remanded for summary judgment in favor of the State. The Supreme Court reversed, holding that the trial court correctly determined there were no genuine issues of material fact relating to whether Retirees possessed a vested right protected under the Contracts Clause. View "Lake v. State Health Plan for Teachers & State Employees" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the order of the superior court (MAR court) granting Defendant's motion for appropriate relief (MAR) and awarding him a new trial, holding that the MAR court neither abused its discretion nor committed legal error in granting Defendant a new trial.Defendant was fourteen years old when he was indicted for and assaulting a cab driver who later died. Based largely on the basis of a confession Defendant made while being interrogated by a police detective outside the presence of a parent or guardian Defendant was convicted of first-degree murder. Years later, Defendant filed a MAR alleging that he was entitled to relief based on the newly discovered evidence of the testimony of a man who claimed that, on the night of the crime, another person confessed to him to assaulting the cab driver. The MAR court allowed the MAR and vacated Defendant's conviction. The court of appeals reversed. The Supreme Court reversed and remanded the case for a new trial, holding that the MAR court did not abuse its discretion in concluding that Defendant proved by a preponderance of the evidence all elements necessary to demonstrate his entitlement to a new trial on the basis of newly discovered evidence. View "State v. Reid" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the order of the trial court denying Defendant's motion for appropriate relief (MAR) and supplemental motion for appropriate relief (supplemental MAR) asserting that the indictment charging him with the offense of attempted robbery with a dangerous a dangerous weapon was fatally flawed, holding that the indictment was sufficient.Defendant pleaded guilty to second-degree murder and two robbery charges. The trial court denied both Defendant's MAR and supplemental MAR. The court of appeals reversed, concluding that the indictment's description of the victims of Defendant's attempted robbery was insufficient because it did not name the person against whom the offense was directed with certitude. The Supreme Court reversed, holding (1) the indictment comported with the requirements of N.C. Gen. Stat. 15A-924(a)(5) and the current status of the law; and (2) therefore, the trial court had the necessary jurisdiction to enter judgment against Defendant pursuant to his guilty plea. View "State v. Oldroyd" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that Defendant had failed to make the showing of materiality necessary to support an award of postconviction DNA testing, holding that there was no error.Defendant pleaded guilty to second-degree murder. After a sentencing hearing, Defendant was sentenced to a term of life imprisonment. The trial court denied Defendant's later request for postconviction DNA testing on the grounds that Defendant had failed to show that the requested testing would be material to his defense. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) Defendant's guilty plea did not preclude him from seeking postconviction DNA testing under N.C. Gen. Stat. 15A-269; and (2) the lower courts correctly concluded that Defendant failed to make the necessary showing of materiality. View "State v. Alexander" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree murder and possession of a firearm by a felon and his sentence of life imprisonment without parole, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not err or deprive Defendant of the right to a "complete self-defense instruction" by failing to instruct the jury using the exact language in which N.C.P.I. – Crim. 308.10 is couched; and (2) the court of appeals correctly held that Defendant failed properly to preserve his challenge to the trial court's second alleged instructional error for purposes of appellate review. View "State v. Benner" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing in part and vacating in part Defendant's convictions for insufficient evidence, holding that the court of appeals erred.After a jury trial, Defendant was found guilty of violating a civil domestic violence protective order while in possession of a deadly weapon, felonious breaking or entering, assault with a deadly weapon, and assault on a female. The court of appeals reversed Defendant's convictions for violation of a protective order and felonious breaking or entering for insufficient evidence. The Supreme Court reversed, holding that the court of appeals erred. View "State v. Tucker" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals affirming Defendant's convictions for first-degree murder, felonious speeding to elude arrest, and robbery with a dangerous weapon, holding that Defendant was disqualified from claiming the justification of self-defense.At issue on appeal was whether the trial court erred in instructing the jury that Defendant could not claim self-defense to justify his use of deadly force because he was also convicted of being a felon in possession of a firearm. The Supreme Court held (1) N.C. Gen. Stat. 14-51.4, the stand your ground law, requires the State to prove an immediate causal nexus between a defendant's attempt to commit, commission of, or escape after the commission of the felony and the circumstances giving rise to the defendant's perceived need to use force; (2) because the trial court failed to instruct the jury on this causal nexus requirement, the jury instructions were erroneous, but the error was not prejudicial; and (3) under section 14-51.4(1), Defendant was disqualified from claiming the justification of self-defense. View "State v. McLymore" on Justia Law