Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals upholding Defendant's voluntary manslaughter conviction after determining that if the trail court erred in refusing to admit certain cell phone evidence the error was not sufficiently prejudicial to warrant a new trial, holding that the trial court's decision did not constitute an abuse of discretion.On appeal, Defendant argued that the trial court committed reversible error by refusing to allow the jury to consider photographs and text messages found on the victim's cellular phone. The court of appeals affirmed, concluding that Defendant received a fair trial free of prejudicial error. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in admitting the evidence and that admitting the disputed evidence almost certainly would not have changed the outcome of Defendant's trial. View "State v. McKoy" on Justia Law

In this appeal from the orders and opinions entered in December 2019, February 2020, May 2020, and April 2021 by the superior court after the case was designated a mandatory complex business case, the Supreme Court affirmed in part and reversed in part, holding that remand was required as to some issues.Plaintiffs and Defendants entered into an asset purchase agreement under which three software applications for use in the clinical trial process would be sold to Defendants by Plaintiffs in exchange for stock and $2.5 million. After the deal soured Plaintiffs brought this lawsuit asserting claims for, among other things, breach of contract and negligent misrepresentation. The trial court granted Defendants' motions to dismiss as to some claims and then granted summary judgment for Defendants on all remaining claims. The Supreme Court affirmed the trial court as to all issues except for the order granting summary judgment on the issues of breach of portions of the asset purchase agreement, holding that further discovery was required. View "Value Health Solutions, Inc. v. Pharmaceutical Research Associates, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's second-degree murder conviction, holding that the evidence was sufficient to support a jury finding that Defendant was the aggressor when she shot and killed the victim, and therefore, the trial court did not err in giving an instruction on the aggressor doctrine.At issue was the proper application of North Carolina's castle doctrine statute. See N.C. Gen. Stat. 14-51.2(b). Defendant and the victim in this case had a tumultuous relationship, and on the day of the murder Defendant had warned the victim not to come to her residence. The victim came anyway and was shot and killed. Defendant was convicted of second-degree murder. The court of appeals remanded the case for a new trial, holding that the trial court improperly instructed the jury on the aggressor doctrine. The Supreme Court reversed, holding that the trial court properly instructed the jury that if it found that Defendant was the aggressor, the presumption in section 14-51.2 was no longer available for her. View "State v. Hicks" on Justia Law

The Supreme Court affirmed the jury verdict that Defendant was guilty of the first-degree murder of a young child as well as of first-degree kidnapping, sexual offense with a child and felony child abuse inflicting serious injury, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to disqualify the trial judge; (2) the trial court erroneously admitted at trial a full-body photograph of the victim during certain testimony, but the error was not prejudicial; (3) the trial court may have improperly allowed certain witnesses to testify about their emotional reactions to seeing the victim's injuries, but the evidence was not prejudicial; (4) the trial court erred in denying Defendant's second motion to suppress a statement he made to law enforcement officers at a hospital, but there was no prejudice; (5) there was no cumulative prejudice; (6) there was no error in the trial court's rulings related to Defendant's attempt to establish a prima facie case of racial or gender-based discrimination; (7) North Carolina's death sentence system is constitutional; and (8) Defendant received a fair trial and capital sentencing proceeding. View "State v. Richardson" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's conviction for possession of a firearm by a felon because the State failed to obtain a separate indictment for that offense under N.C. Gen. Stat. 14-415.1(c), holding that a violation of the mandatory separate indictment provision is not fatally defective.The State brought an indictment charging Defendant with possession of a firearm and two related offenses. The State did not obtain a separate indictment for Defendant's offense of possession of a firearm by a felon. The trial court convicted Defendant of possession of a firearm by a felon, possession of a firearm with an altered or removed seal number, and carrying a concealed weapon. The court of appeals reversed in part because the State failed to obtain a separate indictment for Defendant's conviction for possession of a firearm by a felon. The Supreme Court reversed, holding that the court of appeals erroneously applied its precedent in State v. Wilkins, 737 S.E.2d 791 (N.C. App. 2013), and that Wilkins is hereby specifically overruled. View "State v. Newborn" on Justia Law

The Supreme Court reversed the decision of the court of appeals and reinstated the opinion and award filed by the North Carolina Industrial Commission in favor of Plaintiff following a tractor-trailer accident in which Plaintiff, an employee a trucking company, sustained injury, holding that the agency's decision should not have been disturbed by the lower appellate court.After the accident, Plaintiff provided notice to her employer and its insurance carrier of the accident and of the injury her husband received in the accident but did not report injury to herself. The Commission concluded that Plaintiff's injury was causally related to the accident, that Plaintiff had a reasonable excuse for not providing notice of her injury until two years later, that Defendants were not prejudiced, and that Plaintiff was totally disabled as a result of her injury. The court of appeals reversed. The Supreme Court reversed, holding that there was no error in either the Commission's findings of fact or in its conclusions of law. View "Sprouse v. Turner Trucking Co." on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating an adjudication of J.U. for simple assault and battery, holding that the juvenile petition supported each element of misdemeanor sexual battery.The State filed a juvenile petition alleging that J.U. committed simple assault and battery. The district court adjudicated J.U. delinquent for simple assault and battery and entered a Level II disposition order. The court of appeals vacated the lower court's adjudication order in part and the disposition order in its entirety, concluding that the juvenile petition was "fatally defective" and failed to invoke the trial court's jurisdiction over the petition. The Supreme Court reversed, holding that the petition complied with statutory pleading standards and that no other jurisdictional defect existed. View "In re J.U." on Justia Law

In this appeal from the business court judgment denying Defendant's motion for a protective order the Supreme Court affirmed, holding that the trial court did not abuse its discretion.Defendants - a corporate entity and the individual corporate members of that entity - were jointly represented by the same law firm. During a joint conference call with counsel, defendant Nicholas Hurysh secretly recorded the conversation. Hurysh later sought to waive the attorney-client privilege and disclose the contents of the conference call. The corporate entity moved for a protective order. The trial court denied the protective order, concluding that Hurysh held the attorney-client privilege individually and was permitted to waive it. The Supreme Court affirmed, holding (1) there existed a factual dispute concerning the scope of counsel's representation on the conference call, and the trial court correctly resolved the dispute in favor of Hurysh; and (2) the trial court's findings were supported by substantial evidence, and the trial court's ultimate determination was not an abuse of discretion. View "Howard v. IOMAXIS, LLC" on Justia Law

The Supreme Court vacated the opinion of the court of appeals reversing Defendant's conviction of drug-related charges arising out of an incident that occurred when law enforcement officers observed Defendant moving in between buildings of a housing community and eventually found a white, powdery substance in his backpack, holding that remand was required.The court of appeals reversed Defendant's conviction for trafficking by possession of an opiate on the grounds that the trial court erroneously ruled that the State's expert was qualified to testify that fentanyl is an opiate. At issue was the impact of State v. Garrett, 2021-NCCOA-214, on this case. The Supreme Court vacated the court of appeals, holding that the trial court erred in concluding that whether fentanyl is an opiate is a question of fact, requiring remand. View "State v. Gibbs" on Justia Law

The Supreme Court dismissed for lack of personal jurisdiction a decision of the court of appeals affirming the order of the trial court dismissing Plaintiff's claims against Defendants for lack of personal jurisdiction, holding that this Court was unable to engage in meaningful appellate review of this discretionary decision.The trial court's dismissal order was entered without the court ruling on Plaintiff's motions to compel responses to discovery requests concerning Defendants' contacts with North Carolina. On appeal, the court of appeals concluded that further jurisdictional discovery was unwarranted. The Supreme Court reversed and remanded the case, holding that because the trial court failed to provide reasons for the implied denial of Plaintiff's requests for further jurisdictional discovery this Court could not ascertain whether the court applied an analysis consistent with Ford Motor Co. v. Mont. Eighth Judicial District Court, 141 S. Ct. 1017 (2021). View "Miller v. LG Chem, Ltd." on Justia Law