Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the court of appeals remanding this case to the trial court for findings of fact and conclusions of law on Defendant's motion to dismiss for failure to state a claim upon which relief could be granted, holding that the court of appeals erred.Plaintiffs brought this complaint against Bank alleging fraud and other related claims. The trial court granted Bank's motion to dismiss pursuant to N.C. R. Civ. P. 12(b)(6). The court of appeals reversed and remanded the case because the trial court did not make findings of fact and the court could not "conduct a meaningful review of the trial court's conclusions of law." The Supreme Court vacated the judgment, holding that the court of appeals erred by not conducting a de novo review of the sufficiency of the allegations in Plaintiffs' complaint. View "Taylor v. Bank of America, N.A." on Justia Law

The Supreme Court held that the Due Process Clause allows North Carolina courts to exercise personal jurisdiction over companies that received millions of dollars in assets by E.I. DuPont de Nemours and Company (Old DuPont) when the company, facing liability for releasing harmful chemicals into the North Carolina environment over a period of decades, underwent a significant corporate reorganization.North Carolina brought an action against Old DuPont and its corporate successors, asserting negligence, trespass, public nuisance, fraud, and fraudulent transfer related to Old DuPont's use of harmful chemicals at its Fayetteville Works plant and its subsequent reorganization to avoid liability. At issue was whether the Due Process Clause permits jurisdiction to be exercised over a corporate successor when the predecessor is subject to jurisdiction in the forum and state law subjects the successor to liability. The Supreme Court affirmed the business court's denial of Defendants' motion to dismiss, holding that personal jurisdiction could be established through the imputation analysis for all of the State's claims arising out of or related to Old DuPont's activities in North Carolina. View "State ex rel. Stein v. E.I. DuPont de Nemours & Co" on Justia Law

The Supreme Court reversed the order of the trial court granting Defendants' motion to dismiss this action brought against Troy University, an accredited, four-year state university with several campuses in Alabama and an office in Fayetteville, North Carolina, alleging various tort claims arising out of his employment and termination, holding that Troy University explicitly waived its sovereign immunity.Plaintiff brought this lawsuit against Troy University and two individual defendants asserting, among other things, claims for wrongful discharge from employment in violation of public policy and negligent retention or supervision of an employee. The trial court dismissed the complaint based on sovereign immunity, citing Franchise Tax Bd. of Cal. v. Hyatt, 139 S. Ct. 1485 (2019), which established that states are required to recognize sovereign immunity of other states as a matter of constitutional law. The Supreme Court reversed and remanded the case, holding (1) Troy University explicitly waived its sovereign immunity and consented to be sued in North Carolina; and (2) therefore, the doctrine of sovereign immunity did not bar Plaintiff's suit against Defendants. View "Farmer v. Troy 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 modified the decision of the court of appeal affirming the denial of Defendant's petition for a writ of certiorari to the extent that this Court affirms the outcome reached by the lower appellate court without prejudice to Defendant to pursue any other legal remedy that has not been determined by the Court's opinion, holding that the superior court properly acted within its discretion in denying Defendant's petition for a writ of certiorari.The court of appeals determined that only the superior court's order denying Defendant's certiorari petition, and not the order denying Defendant's motion to reinstate charges, was properly before the appellate court. The Supreme Court affirmed as modified, holding (1) a criminal defendant does not possess the right to compel the district attorney, who has the authority to place the defendant’s unresolved criminal charges in a dismissed-with-leave status, to reinstate the dismissed charges and to place the charges on a trial court’s criminal case calendar for resolution; and (2) a trial court lacks the authority to order that criminal charges that have been dismissed with leave by the district attorney be reinstated and placed on a trial court’s criminal case calendar against the will of the district attorney. View "State v. Diaz-Tomas" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals ruling that Defendant waived the right to appellate review of the trial court's denial of Defendant's request for a self-defense instruction, holding that Defendant properly preserved his challenge and that the trial court did not err by refusing to deliver the requested self-defense instruction.After the conclusion of the jury instruction conference and prior to the delivery of the trial court's instructions to the jury defense counsel requested that an instruction on self-defense to be given to the jurors. The trial court denied the request. The jury subsequently returned verdicts convicting Defendant of assault by strangulation and other offenses. Defendant appealed, challenging the trial court's rejection of his self-defense instruction. The court of appeals affirmed, holding that Defendant waived appellate review on the issue. The Supreme Court affirmed as modified, holding (1) Defendant's challenge to the trial court's refusal to issue a self-defense instruction was properly preserved for appellate review; and (2) the trial court did not err in declining to instruct the jury on self-defense. View "State v. Hooper" 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 affirmed the decision of the court of appeals determining that the trial court correctly denied Defendant's motion for a transcript of a prior trial and a motion to continue, holding that the trial court likely erred, but the error was harmless beyond a reasonable doubt.Defendant was charged with multiple driving offense arising from impaired driving. The first trial ended in a mistrial. Before the second trial, Defendant filed a motion for transcript seeking to obtain a transcript of the previous trial and a motion to continue. The trial court denied both motions, and a jury found Defendant guilty of all charges. The Supreme Court affirmed, holding that the trial court likely erred in failing to apply the two-party Britt test upon Defendant's requests for a transcript of the previous proceeding, but the error was harmless beyond a reasonable doubt. View "State v. Gaddis" 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