Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the Industrial Commission denying the Department's motion to dismiss Plaintiffs' claims arising from certain regulatory actions taken by the North Carolina Department of Health and Human Services in response to deficiencies that Department employees had identified during inspections of Plaintiffs' facility, holding that the Commission erred in failing to dismiss Plaintiffs' claims.Plaintiffs, an adult care home and its owner, contested the Department's regulatory actions by initiating a contested case before the Office of Administrative Hearings. The parties settled. Thereafter, Plaintiffs filed a claim with the Commission pursuant to the North Carolina State Tort Claims Act, alleging negligence. The Department filed a motion to dismiss on the grounds that Plaintiffs' claims were barred by the doctrine of sovereign immunity. The Commission denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Plaintiffs' claims were barred by sovereign immunity; and (2) Plaintiffs failed to assert a viable negligence claim against the Department. View "Cedarbrook Residential Center, Inc. v. N.C. Dep't of Health & Human Services" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals ruling that the trial court did not commit plain error by allowing the admission of testimony describing certain information provided by the State's principal witness as "rock solid", holding that the admission of the challenged portion of the testimony did not constitute plain error.After a jury trial, Defendant was convicted of first-degree murder, attempted first-degree murder, and first-degree burglary. The court sentenced Defendant to life imprisonment without parole. The Supreme Court modified and affirmed the decision of the court of appeals upholding the convictions, holding that the challenged portion of the testimony was inadmissible, but it was not reasonably probable that Defendant would have been acquitted had the challenged portion of the testimony not been admitted. View "State v. Caballero" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that the proceedings below did not result in a due process violation but reversed the court of appeals' decision to affirm the order of the trial court to have Respondent involuntarily committed, holding that the record evidence and the trial court's findings did not support that determination.The State filed a petition to have Respondent involuntarily committed for additional inpatient treatment pursuant to N.C. Gen. Stat. 122C-261 et seq. The court of appeals affirmed. The Supreme Court reversed in part, holding (1) the court of appeals properly found that there was no due process violation in the proceedings below; but (2) the trial court's findings could not be deemed sufficient to support a determination that Respondent posed a danger to himself given its failure to find a reasonable probability of Respondent suffering serious physical debilitation within the near future without immediate, involuntary commitment. View "In re C.G." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing one of Defendant's convictions for first-degree kidnapping for lack of sufficient evidence, holding that the trial court erred by denying Defendant's motion to dismiss the second first-degree kidnapping charge.On appeal, Defendant argued that the trial court erred in denying his motion to dismiss the second of two first-degree kidnapping charges for the purpose of facilitating the commission of a first-degree rape because the evidence showed that one of the alleged kidnappings had occurred after the commission of the rape had concluded. The court of appeals agreed and reversed the second of Defendant's first-degree kidnapping convictions. The Supreme Court affirmed, holding that the evidence did not support a finding that Defendant had committed the second first-degree kidnapping charge. View "State v. Elder" 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 affirmed the judgment of the Industrial Commission dismissing Shannon Stocks's claim for death benefits, holding that Stocks - the decedent's alleged, cohabitating fiancee - lacked a legally-recognized relationship and thus could not file a claim for death benefits.The decedent in this case died from injuries sustained in an industrial accident at Defendant. Plaintiffs - the decedent's daughter, son, estranged wife, and Stocks - all filed claims for death benefits under the North Carolina Workers' Compensation Act. The Commission dismissed Stocks's claim for benefits, and a consent order was entered dividing the decedent's death benefits equally among the remaining plaintiffs. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff could not file a claim for death benefits because she lacked a legal relationship with the decedent sufficient to qualify as a dependent under N.C. Gen. Stat. 97-39. View "West v. Hoyle's Tire & Axle, LLC" on Justia Law

The Supreme Court reversed the decision of the court of appeals upholding Defendant's conviction for violating N.C. Gen. Stat. 14-208.11(a)(4) and remanded the case to the court of appeals for further remand to vacate Defendant's conviction for failure to comply with the sex offender registry, holding that the evidence was insufficient to support an inference that Defendant willfully provided information under false pretenses.Defendant was charged with submitting incorrect address information to the sheriff "willfully" and "under false pretenses." Defendant filed a motion to dismiss the charges on grounds that the State's evidence was insufficient to show that he had the requisite intent to deceive. The trial court denied the motion to dismiss and convicted Defendant of violating The Supreme Court reversed, holding that the evidence was insufficient to support an inference that Defendant willfully provided information under false pretenses. View "State v. Lamp" 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 vacated the decision of the court of appeals affirming the order of the trial court summarily denying the City of Greensboro's request that the trial court modify restrictions it imposed upon the possible use and discussion of certain police video records by the Greensboro City Council, holding that the trial court abused its discretion.The order at issue was entered pursuant to N.C. Gen. Stat. 132-1.4A(g) to release recordings of an incident that occurred in Greensboro on September 10, 2016. The City of Greensboro interpreted the conditions in the order as a "gag order" and requested that the trial court modify the restrictions. The trial court summarily denied the request, and the court of appeals affirmed. The Supreme Court vacated the court of appeals and remanded the case for a new hearing, holding that the trial court abused its discretion by denying, without explanation, the City's motion to modify the restrictions. View "In re Custodial Law Enforcement Recording" on Justia Law