Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court reversed the trial court's denial of Defendant's motion for appropriately relief filed after he was convicted of two counts of first-degree murder, holding that certain undisclosed evidence was material and that it was reasonably probable that, had it been disclosed to Defendant prior to trial, the outcome would have been different.Defendant was convicted of first-degree burglary, first-degree rape, robbery with a dangerous weapon, and two counts of first-degree murder and sentenced to death. The convictions were affirmed on direct appeal. In postconviction proceedings, it became clear that the State failed to produce certain pieces of evidence to Defendant prior to his trial. Later that year, postconviction counsel uncovered additional evidence. Defendant then filed a motion for appropriate relief, arguing that the State failed to disclose exculpatory evidence in violation of his due process right pursuant to Brady v. Maryland, 373 U.S. 83 (1963). The trial court denied the motion. The Supreme Court reversed and remanded this case with instruction to grant the motion and order a new trial, holding that the failure to disclose the exculpatory evidence prejudiced Defendant's ability to present a defense. View "State v. Best" on Justia Law

The Supreme Court reversed the order of the district court terminating Mother's parental rights to her minor daughter, holding that Petitioners did not prove by clear, cogent, and convincing evidence that grounds existed to terminate Mother's parental rights and that the requirements of N.C. Gen. Stat. 7B-1111(a)(6) and (7) were not met in this case.The trial court ultimately appointed Petitioners as the child's legal permanent guardians pursuant to N.C. Gen. Stat. 7B-600. Petitioners filed a petition seeking to terminate Mother's parental rights in order to adopt the child. The district court terminated Mother's parental rights pursuant to N.C. Gen. Stat. 7B-1111(a)(6) and (7). The Supreme Court reversed, holding that the requirements of section 7B-1111(a)(6) were not met because the child resided with legal permanent guardians and that the record lacked any evidence supporting a conclusion that Mother acted willfully within the meaning of section 7B-1111(a)(7). View "In re A.L.L." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's convictions, holding that the trial court abused its discretion when it "flatly prohibited questioning as to issues of race and implicit bias during voir dire" and that the trial court's improper restrictions on Defendant's questioning during voir dire prejudiced Defendant.Defendant was convicted of several crimes, including robbery with a dangerous weapon and second-degree kidnapping. On appeal, Defendant challenged the trial court's refusal to allow him to pursue during voir dire certain lines of inquiry relating to racial bias and police-officer shootings of black civilians. The court of appeals rejected Defendant's claims and found no error in the trial court's judgment. The Supreme Court reversed, holding that the trial court abused its discretion and prejudiced Defendant by restricting all inquiry into prospective jurors' racial biases and opinions regarding police officer shootings of black men. View "State v. Crump" on Justia Law

The Supreme Court affirmed the orders of the trial court terminating Father's parental rights to his two biological children, holding that the trial court did not abuse its discretion in finding the existence of the ground for termination of neglect.On appeal, Defendant argued that his guardian ad litem, appointed pursuant to N.C. R. Civ. P. 17 and N.C. Gen. Stat. 7B-1101.1, did not participate sufficiently to satisfy the statutory requirements, and therefore, the trial court erred in advancing the adjudication and disposition proceedings. The Supreme Court affirmed, holding (1) Father did not identify any actions his guardian ad litem could have taken that would have improved Father's chances to obtain a decision in his favor and did not show that the guardian ad litem did not otherwise adequately assist him in executing his legal rights; and (2) the ground of neglect supported the termination of Father's parental rights. View "In re W.K." on Justia Law

The Supreme Court affirmed the trial court's order regarding class certification in this case and dismissed Defendants' interlocutory appeal regarding portions of the trial court's order that pertained to discovery matters, holding that the superior court did not abuse its discretion in certifying two classes of plaintiffs.Plaintiffs commenced a putative class action by asserting claims against Defendants, Orange County and the Town of Chapel Hill, seeking to recover impact fees assessed under a now-repealed statute that had been enacted to allow certain counties and municipalities to defray the costs for constructing, among other public services, public schools. The trial court certified two classes of plaintiffs. Defendants appealed, challenging the class certification and a discovery order concerning Plaintiffs' motion to compel discovery responses. The Supreme Court affirmed in part and dismissed in part, holding (1) the trial court did not err in certifying the classes; and (2) Defendants' effort to appeal the contested discovery ruling was premature and hence must be dismissed for lack of appellate jurisdiction. View "Zander v. Orange County" on Justia Law

The Supreme Court affirmed the order of the Business Court granting summary judgment in favor of Defendants, holding that the Business Court properly determined that North Carolina's economic loss rule requires negligence claims to be based upon the violation of an extra-contractual duty imposed by operation of law.At issue was whether a commercial property owner who contracts for the construction of a building may seek to recover in tort for its economic loss from a subcontracted manufacturer of building materials with whom the property owner does not have contractual privity. Applying the economic loss rule irrespective of the existence or lack of a contractual relationship between the property owner and the subcontracted manufacturer, the court dismissed Plaintiff's negligence claim with prejudice. The Supreme Court affirmed, holding that purely economic losses are not recoverable under tort law, particularly in the context of commercial transactions. View "Crescent University City Venture, LLC v. Trussway Manufacturing, Inc." on Justia Law

The Supreme Court vacated Defendant's convictions and the resulting judgments against him, holding that the trial court committed prejudicial error in its jury instruction on the theory of acting in concert as a basis upon which to find Defendant guilty.After a jury trial, Defendant was convicted of simple possession of methamphetamine, heroin, and cocaine. During trial, the trial court gave instructions to the jury on both constructive possession and acting in concert as legal theories underlying the drug possession charges. The court of appeals affirmed. The Supreme Court reversed the decision of the court of appeals and vacated Defendant's convictions, holding that the trial court erred in instructing the jury on Defendant's criminal culpability on the theory of acting in concert, and the error was not harmless. View "State v. Glover" on Justia Law

The Supreme Court affirmed the decision of the trial court reversing the trial court's order granting judgment on the pleadings regarding Plaintiffs' claim for negligent infliction of emotional distress, holding that the court of appeals did not err.Plaintiffs filed a complaint including claims for negligent infliction of emotional distress, intentional infliction of emotional distress, and wrongful death after their two-year-old child was accidentally killed by a shotgun at Defendants' home. The trial court granted Defendants' motion for judgment on the pleadings, dismissing all of Plaintiffs' claims. The court of appeals reversed in part, holding that Plaintiffs' allegations regarding foreseeability were sufficient to support a claim for negligent infliction of emotional distress. The Supreme Court affirmed, holding that Plaintiffs' allegations were sufficient to support their claim for negligent infliction of emotional distress against Defendants. View "Newman v. Stepp" on Justia Law

The Supreme Court affirmed the decision of the court of appeals holding that substantial evidence existed to create a bona fide doubt as to Defendant's competency and that, therefore, the trial court's failure to make an inquiry into Defendant's competency at trial violated his due process rights, holding that the trial court committed prejudicial error by failing to conduct a competency hearing for Defendant.After a jury trial, Defendant was convicted of three counts each of second-degree sexual offense and taking indecent liberties with a child. On appeal, Defendant argued that events that occurred during trial combined with his lengthy history of mental illness, which included periods of incompetence to stand trial, created a duty upon the trial court sua sponte to inquire into his competency to stand trial. The court of appeals remanded the case to the trial court for a termination of whether a meaningful retrospective hearing could be conducted on the issue of Defendant's competency at the time of his trial. The Supreme Court affirmed, holding that, in light of substantial evidence that was sufficient to raise a bona fide doubt regarding Defendant's competency to stand trial, the trial court committed prejudicial error by failing to conduct a competency hearing for Defendant. View "State v. Hollars" on Justia Law

The Supreme Court held that the scheduling and procedural circumstances existent in this case did not constitute an infringement upon Defendant's constitutional right to a speedy trial.After a jury trial, Defendant was convicted of first-degree sex offense with a child and indecent liberties with a child. On appeal, Defendant argued that the trial court erred by denying his motion to dismiss the charges against him because the State violated his constitutional right to a speedy trial by failing to calendar his trial date for approximately five years following the issuance of the indictments against him. The court of appeals affirmed, holding that here was no speedy trial violation. The Supreme Court affirmed after weighing the factors set forth in Barker v. Wingo, 407 U.S. 514 (1972), as they applied to the circumstances of this case, holding that Defendant's constitutional right to a speedy trial was not violated. View "State v. Farmer" on Justia Law