Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court vacated the decision of the trial court to exercise personal jurisdiction over Defendant, Logan Wagner, in a proceeding initiated by Plaintiff, Marisa Mucha, who was seeking to obtain a domestic violence protection order, holding that Defendant did not have the requisite minimum contacts with North Carolina.The only contact Defendant had with North Carolina was more than two dozen phone calls he made to Plaintiff's cell phone on the day she moved to North Carolina. Plaintiff filed a pro se complaint and motion for a DVPO in District Court, Wake County. Defendant filed a motion to dismiss for lack of personal jurisdiction. The trial court denied the motion to dismiss and entered a DVPO. The Supreme Court dismissed the trial court's order, holding that the Due Process Clause forbade the trial court from exercising personal jurisdiction over him to enter a DVPO. View "Mucha v. Wagner" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court dismissing this complaint against Defendants in their individual capacities, holding that the complaint adequately stated claims for the tort relief sought by the Estate of Melvin Joseph Long.Long was working to reconnect a trailer-mounted chiller on the campus of North Carolina State University (NCSU) when a metal flange fatally hit him with great force. Long's Estate brought this action against NCSU employees who had worked on the chiller during the months before Long's accident. Defendants filed a motion to dismiss, which the trial court granted. The court of appeals reversed, holding (1) Defendants had been sued in their individual capacities and were therefore not entitled to the defense of sovereign immunity; and (2) the complaint adequately stated claims for negligence and gross negligence. View "Estate of Long v. Fowler" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order and declaratory judgment of the superior court in favor of Defendant in this personal injury action, holding that, under the circumstances, Defendant was not entitled to collect underinsured benefits.Defendant was a North Carolina resident who sought to collect underinsured motor vehicle coverage benefits from Plaintiff, her North Carolina insurer, after she was injured while traveling in Alabama in a car owned and operated by a Tennessee resident and insured by a Tennessee insurer. Plaintiff denied the claim and initiated a declaratory judgment action seeking a ruling establishing that the UIM coverage of its politics did not apply to Defendant's injuries. The trial court concluded that Defendant was not entitled to coverage under the UIM provision of her insurance contract. The court of appeals affirmed. The Supreme Court reversed, holding that because the amount of the stacked UIM coverage limits exceeded the sum of the applicable bodily injury coverage limits, the Tennessee driver's car was an "underinsured motor vehicle" as defined under North Carolina's Financial Responsibility Act for the purposes of giving effect to Defendant's contract with Plaintiff. View "N.C. Farm Bureau Mutual Insurance Co. v. Lunsford" on Justia Law

The Supreme Court vacated the portions of the motion for appropriate relief (MAR) court's order summarily dismissing Defendant's guilt-innocence phase ineffective assistance of counsel (IAC) claims, vacated the portion of the order summarily ruling that Defendant's claim alleging he was impermissibly shackled in view of the jury was procedurally barred, and otherwise affirmed, holding that the court erred in part.Defendant was convicted of first-degree murder and sentenced to death. Defendant later filed an MAR petition and then a supplemental motion for appropriate relief. The MAR court dismissed Defendant's claims. The Supreme Court vacated the MAR court's order in part and remanded the matter to the court, holding (1) Defendant was entitled to an evidentiary hearing on his guilt-innocence phase IAC claims; and (2) Defendant was entitled to an evidentiary hearing to obtain the facts necessary to determine whether Defendant's claim that he was impermissibly shackled was procedurally barred and, if not, whether it had merit. View "State v. Allen" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the trial court denying Defendant's motion to suppress evidence of a bag of narcotics seized from his vehicle during a traffic stop, holding that the trial court properly denied Defendant's motion to suppress.On appeal, Defendant argued that the law enforcement officers conducting a search for weapons on his person and in the areas of his vehicle under his immediate control did not possess the required reasonable suspension to initiate a warrantless search. The Supreme Court disagreed, holding (1) the law enforcement officer who conducted the traffic stop presented articulable facts at the suppression hearing giving rise to a reasonable suspicion that Defendant was armed and dangerous; and (2) the trial court did not err in denying Defendant's request to suppress the controlled substances that were discovered as a result of the search of the areas of Defendant's vehicle which were under his immediate control. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the order of the superior court court granting summary judgment in favor of Defendants and concluding that North Carolina Railroad Company was not an agency or subdivision of the North Carolina government for purposes of the Public Records Act (the Act), N.C. Gen. Stat. 132-1, holding that there was no error.Plaintiff Southern Environmental Law Center, acting in reliance upon the Act, submitted a request to the president of the Railroad seeking to inspect certain records. The Railroad declined to provide the requested records, asserting that it was not subject to the Act. Plaintiff then brought this action requesting that the court enter an order declaring that the Railroad was an agency of the state for purposes of the Act. The trial court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that the trial court did not err in granting summary judgment in favor of Defendants. View "Southern Environmental Law Center v. N.C. Railroad Co." on Justia Law

The Supreme Court affirmed the decision of the court of appeals ruling that an assessment that Mecklenburg County made of the business personal property owned by Harris Teeter, LLC at six grocery stores reflected the "true value" of that property, as required by N.C. Gen. Stat. 105-283, holding that none of Harris Teeter's challenges to the order of the North Carolina Property Tax Commission had merit.In rejecting Harris Teeter's challenge to the Commission's order, the court of appeals held that the Commission's findings had sufficient evidentiary support and that those findings had satisfied the County's obligation to prove that the methods it used in valuing Harris Teeter's property produced the true value of that property. The Supreme Court affirmed, holding that the manner in which the Commission resolved the issues in this case had ample record support. View "In re Harris Teeter, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's convictions of felony trafficking in methamphetamine and misdemeanor simple possession of marijuana, holding that a defendant does not forfeit her Fifth Amendment right to silence if she complies with N.C. Gen. Stat. 15A-905(c)(1) and gives notice of intent to offer an affirmative defense.Prior to trial, Defendant filed a notice of her intent to rely upon the affirmative defense of duress pursuant to section 15A-905(c)(1). The jury found Defendant guilty after a trial. The court of appeals affirmed, concluding that because Defendant gave notice of her intent to assert the affirmative defense of duress before she testified, the trial court did not err in admitting, during the State's case-in-chief, a detective's testimony of Defendant's silence at the scene. The Supreme Court reversed, holding (1) a defendant does not forfeit her Fifth Amendment right to silence if she gives pretrial notice of her intent to offer the affirmative defense of duress under section 15A-905(c)(1); and (2) the State may not preemptively impeach a defendant during its case-in-chief. View "State v. Shuler" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the order of the trial court granting summary judgment in favor of Plaintiff reforming a deed of trust and allowing foreclosure, holding that Plaintiff was entitled to summary judgment on its claims for reformation and judicial foreclosure.At issue in this case was when a cause of action accrues for reformation of a deed of trust based on mutual mistake. The Supreme Court held (1) a party discovers a mistake for purposes of N.C. Gen. Stat. 1-52(9), which provides a three-year statute of limitations for relief based on a mistake, when that party knows of the mistake or should have known in the exercise of due diligence; (2) Plaintiff's action was timely filed; and (3) there was no genuine issue of material fact as to whether the parties intended the deed of trust to secure the defaulted promissory note. View "Wells Fargo Bank, N.A. v. Stocks" on Justia Law

The Supreme Court affirmed the orders of the trial court terminating Mother's parental rights to her three children and terminating the children's two fathers' parental rights to the children, holding that there was no error in the proceedings below.On appeal, Mother's counsel identified three issues that could arguably support an appeal but stated why she believed each of those issues lacked merit. The Supreme Court affirmed as to Mother and both fathers, holding (1) the trial court's orders as to Mother were supported by competent evidence and based on proper legal grounds; and (2) the trial court did not err by concluding that grounds existed to terminate the fathers' parental rights in their respective children. View "In re M.S." on Justia Law