Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court held that partisan gerrymandering claims present a political question that is nonjusticiable under the North Carolina Constitution, thus overruling the Court's decision in Harper I and affirming the court of appeals' decision dismissing all of Plaintiffs' claims with prejudice.Plaintiffs brought an action alleging that legislative and congressional redistricting plans drawn by the General Assembly in 2021 and then on remand in 2022 are partisan gerrymanders in violation of specific provisions of the North Carolina Constitution. On rehearing, the Supreme Court held (1) this Court's previous holding in Harper v. Hall, 868 S.E.2d 499, 551 (N.C. 2022) that partisan gerrymandering presents a justiciable claim is overruled, and this Court's opinion in Harper v. Hall, 881 S.E.2d 156, 162 (N.C. 2022) is withdrawn and superseded by this opinion; and (2) the court of appeals correctly concluded that partisan gerrymandering claims present nonjusticiable, political questions and dismissed all of Plaintiffs' claims with prejudice. View "Harper v. Hall" on Justia Law

The Supreme Court reversed the decision of the court of appeals determining that provisions in the settlement agreement in this case were ambiguous, holding that the plain language of the settlement agreement was unambiguous.After Defendant and Melissa Galloway Snell executed a memorandum of mediated settlement agreement a judgment a divorce was granted to the parties. At issue was a life insurance policy on Melissa's life that listed the Melissa Galloway Snell Living Trust as the policy's beneficiary. The parties' four children were beneficiaries of the trust. When Defendant claimed that he was entitled to the proceeds from Melissa's policy the trust brought suit seeking a declaratory judgment. The trial court granted the trustee's motion for summary judgment. The court of appeals reversed, concluding that the relevant language of the settlement agreement was ambiguous. The Supreme Court reversed, holding that the court of appeals erred by concluding that the settlement agreement was ambiguous. View "Galloway v. Snell" on Justia Law

The Supreme Court modified the decision of the court of appeals affirming the denial of a petition to terminate Father's parental rights and clarified the correct standard of review at the adjudication and dispositional stage, holding that there were no grounds to terminate Father's parental rights pursuant to N.C. Gen. Stat. 7B-1111(a)(1), (4), or (7).Mother filed a petition to terminate Father's parental rights, alleging that grounds for termination existed under section 7B-1111(a0(1), (4), and (7). In denying the petition, the trial court found that Father made an effort to have a relationship with his child but was blocked from doing so, that the child was not neglected, and that Father had not willfully abandoned the child. The court of appeals affirmed. The Supreme Court affirmed as modified, holding (1) the trial court did not err in concluding that the grounds necessary to terminate Defendant's parental rights did not exist; and (2) the court of appeals' decision is modified to the extent it could be read to be applying an abuse of discretion, rather than a clear, cogent, and convincing evidence, standard of review at the adjudicatory stage of the proceeding. View "In re S.R." on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating the orders of the trial court dismissing Mother's terminating MOther's parental rights, holding that the trial court did not err.After a hearing, the trial court terminated Mother's parental rights. The court of appeals remanded the case for a new hearing, citing its concerns about the fundamental fairness offered to Mother before the trial court dismissed her provisional counsel. The Supreme Court reversed and remanded the case for further proceedings, holding (1) the trial court complied with the legislature's enactments concerning provisional counsel under N.C. Gen. Stat. 7B-1108.1(a)(1) and properly considered at the pretrial hearings the issues listed in N.C. Gen. Stat. 7B-1101.1(a)(1); and (2) therefore, the court of appeals erred by reversing the judgment of the trial court. View "In re R.A.F." on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals affirming the judgment of the trial court in this termination of parental rights case, holding that any error was harmless.The trial court in this case referenced a timeline introduced into evidence and expressly relied on that timeline, which the court found to be "credible and reliable," in determining that grounds existed to terminate Respondent's parental rights for willful failure to make reasonable progress under N.C. Gen. Stat. 7B-1111(a)(2). The Supreme Court affirmed as modified, holding (1) the trial court's findings of fact were proper because the trial court did not merely accept and rely upon the timeline but expressly evaluated whether the timeline was credible and reliable; (2) there was no error in the trial court's disposition order; and (3) if the trial court erred by permitting an amendment that added an additional ground for termination, the error was harmless. View "In re H.B." on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that S.B. 824 violates N.C. Const. art. I, 19 and permanently enjoining that law, holding that S.B. 824 does not violate the protections set forth in Article I, Section 19.Pursuant to S.B. 824, registered voters are required to present one of several acceptable forms of identification prior to casting a ballot and require the State to provide free voters identification cards to any registered voter. At issue was whether North Carolina's photo identification statute is constitutional. Plaintiffs moved for a preliminary injunction to enjoin implementation and enforcement of S.B. 824. The trial court denied the injunction. The court of appeals reversed, holding that S.B. 824 violates Article I, Section 19 because it was enacted with discriminatory intent. The Supreme Court reversed, holding that Plaintiffs failed to prove beyond a reasonable doubt that S.B. 824 was enacted with discriminatory intent or actually produces a "meaningful disparate impact along racial lines." View "Holmes v. Moore" on Justia Law

The Supreme Court reversed the decision of the court of appeals determining that the trial court's findings of fact did not support its conclusion adjudicating Glenda a neglected juvenile, holding that the court of appeals erred by requiring findings of fact from the trial court to adjudicate a juvenile neglected that are not required by statute or Supreme Court precedent.After Glenda's sibling died, the Department of Social Services filed a petition alleging that Glenda was a neglected juvenile. After the trial court concluded as a matter of law that Glenda was a neglected juvenile within the meaning of N.C. Gen. Stat. 7B-101(15) Respondent appealed. The court of appeals vacated the adjudication and disposition order, concluding that the trial court's written findings of fact did not support its conclusion that Glenda was a neglected juvenile. The Supreme Court reversed, holding that the findings of fact supported the trial court's adjudication and conclusion of law that Glenda was a neglected juvenile. View "In re G.C." on Justia Law

The Supreme Court affirmed the judgment of the trial court granting Defendants' motion for an award of attorneys' fees as part of their costs under N.C. R. Civ. P. 41(d) pursuant to N.C. Gen. Stat. 6-21.5 and the trial court's subsequent order awarding $599,262 in attorneys' fees as costs, holding that the trial court did not abuse its discretion.Plaintiffs, limited partners of the Fayetteville Ambulatory Surgery Center Limited Partnership (FASC), asserted five claims against Cape Fear Valley Ambulatory Surgery Center, LLC and its owner, Cumberland County Hospital System, Inc. Plaintiffs later voluntarily dismissed the case without prejudice. Defendants subsequently brought a motion for fees. The trial court granted the motion for attorneys' fees as part of Defendants' costs under Rule 41(d) pursuant to N.C. Gen. Stat. 6-21.5. The Supreme Court affirmed, holding that the trial court did not abuse its discretion granting the motion for attorneys' fees. View "Woodcock v. Cumberland County System, Inc." 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

The Supreme Court reversed the decision of the court of appeals reversing the trial court's adjudications of nine-year-old Margaret as an abused and neglected juvenile and her two younger siblings as neglected juveniles, holding that the trial court's order contained sufficient findings, supported by clear cogent, and convincing evidence, supporting the court's adjudications of Margaret and her siblings.In reversing the trial court's adjudications, the court of appeals held that the trial court improperly admitted some hearsay evidence and that the trial court's reasoning was so "reliant and intertwined with" the hearsay evidence that the proper remedy was to vacate the trial court's order. The Supreme Court reversed after reaffirming the proper role of an appellate court in reviewing a trial court's adjudication and disposition in a juvenile proceeding, holding that the court of appeals erred by vacating or reversing the trial court's adjudications because the court properly adjudicated Margaret as an abused and neglected juvenile and properly adjudicated her siblings as neglected juveniles. View "In re A.J.L.H." on Justia Law