Justia North Carolina Supreme Court Opinion Summaries

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

The Supreme Court reversed the decision of the court of appeals determining that the trial court committed prejudicial error in denying Defendant's request for a jury instruction on justification as a defense to the charge of possession of a firearm by a felon, holding that the trial court did not err.After a jury trial, Defendant was convicted of second-degree murder and possession of a firearm by a felon. The court of appeals reversed the conviction and remanded for a new trial, holding that the trial court committed prejudicial error by denying Defendant's requested instruction on justification. The Supreme Court reversed, holding (1) this case did not support all four elements of the justification defense as required by State v. Mercer, 838 S.E.2d 359 (N.C. 2020); and (2) therefore, the court of appeals erred in reversing Defendant's conviction and remanding for a new trial. View "State v. Swindell" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating the trial court's order authorizing sale and remanded the case, holding that the condominium association Executive Office Park of Durham Association, Inc. (Executive Office) had the power of sale for foreclosure pursuant N.C. Gen. Stat. 47C-3-116 for nonpayment of an assessment that occurred after October 1, 1986.The condominium in this case was formed prior to the enactment of the North Carolina Condominium Act in 1985. In 2018, Executive Office filed a claim of lien against three units owned by Martin Rock, alleging that assessments and other charges from 2018 had remained unpaid for more than thirty days. Thereafter, the substitute trustee sainitiated a power of sale foreclosure. The superior court entered an order authorizing sale. The court of appeals reversed, concluding that Executive Office lacked the power of sale for foreclosure. The Supreme Court reversed, holding (1) the court of appeals erred by failing to apply N.C. Gen. Stat. 47C-1-102(a) when addressing Rock's argument that Executive Office lacked the power of sale for foreclosure; and (2) because the condominium was created in North Carolina before October 1, 1986 and the assessments and non-payment occurred after that date, Executive Office possessed the power of sale permitted by section 47C-3-116(f). View "In re Foreclosure of a Lien by Executive Office Park of Durham Ass'n against Rock" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing in part and vacating in part the trial court's adjudication of abuse, neglect, and dependency and eliminating reunification efforts with Mother.The trial court adjudicated the child an abused, neglected, and dependent juvenile and, finding that reunification with Mother would be unsuccessful, ordered that reunification efforts with Mother cease. Mother's visitation rights with the child were terminated. The court of appeals vacated the disposition and permanency planning order, holding that the trial court denied Mother a fair hearing and erred in adjudicating the child an abused, neglected, and dependent juvenile. The Supreme Court reversed, holding (1) the trial court did not err in adjudicating the child abused, neglected, and dependent; (2) the trial court did not err in eliminating reunification efforts with Mother; and (3) Mother's counsel provided effective assistance. View "In re L.N.H." on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's conviction of felony obstructing of justice, holding that there was sufficient evidence to support the jury's verdict finding Defendant guilty of felony obstruction of justice.After a nearly three-week-long jury trial, Defendant was convicted of, among other offenses, obtaining property by false pretenses and felony obstruction of justice. The court of appeals reversed in part, concluding that the State did provide substantial evidence of obstruction to support the felony obstruction of justice conviction. The Supreme Court reversed and reinstated the felony obstruction of justice conviction, holding that there was sufficient evidence to convict Defendant of felony obstruction of justice. View "State v. Bradsher" on Justia Law

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