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 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

The Supreme Court affirmed the opinion of the court of appeals affirming the trial court's entry of summary judgment in favor of Plaintiffs and holding that eight of nine restrictive covenants governing Plaintiffs' lots within the parties' residential subdivision were extinguished by operation of North Carolina's Real Property Marketable Title Act, N.C. Gen. Stat. 47B-1 to 47B-9, holding that the eight covenants were extinguished by operation of law.At issue on appeal was whether the court of appeals correctly determined that the Act's thirteenth enumerated exception did not apply to save all of the nine restrictive covenants in question. The Supreme Court affirmed, holding (1) the court of appeals correctly held that all but one of the restrictive covenants, as applied to Plaintiffs' property, were to be extinguished under the Act; and (2) a plain reading of section 47B-3(13) exempts from extinguishment only those covenants that actually require that a property be used residentially within the confines of a general or uniform scheme of development. View "C Investments 2, LLC v. Auger" on Justia Law

The Supreme Court reversed the order of the trial court permitting Father's court-appointed counsel to withdraw from representing Father in the case proceedings and the trial court's order ceasing efforts to reunify Father with his son (Child), holding that remand was required for additional proceedings.The Chowan County Department of Social Services (DSS) petitioned to terminate Father's parental rights to Child on multiple grounds. Father was granted the same attorney for the termination of parental rights matter as had been allowed to withdraw at an earlier hearing. Thereafter, trial court terminated Father's parental rights, concluding that all four of the alleged grounds of the termination existed. The Supreme Court reversed, holding that the trial court erred in allowing Father's counsel to withdraw from representation without proper notice evidence in the record of the attorney's intent to withdraw and without making further inquiry into the circumstances regarding the motion. View "In re L.Z.S." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the trial court's judgments revoking Defendant's probation entered more than one year after Defendant's term of probation had expired, holding that the trial court did not abuse its discretion.The trial court concluded that good cause existed to revoke Defendant's probation despite the expiration of his probationary period. Defendant appealed, arguing that the "good cause" found by the trial court failed as a matter of law to satisfy N.C. Gen. Stat. 15A-1344(f)(3). The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court (1) possessed the jurisdiction to revoke Defendant's probation after his term of probation had expired; and (2) did not abuse its discretion in determining that good cause existed for the revocation of Defendant's probation after his term of probation had expired. View "State v. Geter" on Justia Law