Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court modified and affirmed the decision of the court of appeals affirming Defendant's convictions, holding that Defendant preserved his challenges to the sufficiency of the evidence for appeal but that the State presented sufficient evidence to support the convictions.A jury found Defendant guilty of obtaining property worth less than $100,000 by false pretenses, accessing a government computer, altering court records, and unlicensed bail bonding. On appeal, Defendant argued that the State presented insufficient evidence that he aided and abetted another and that he obtained a thing of value. The court of appeals concluded that Defendant waived his challenge to the sufficiency of the State's evidence of aiding and abetting and that Defendant waived his right to appellate review to the sufficiency of the State's evidence that he obtained a thing of value. The Supreme Court affirmed as modified, holding (1) Defendant preserved each of his challenges to the sufficiency of the evidence; and (2) the State presented sufficient evidence that Defendant aided and abetted another and that he obtained a thing of value. View "State v. Golder" on Justia Law

The Supreme Court reversed the judgment of the court of appeals awarding Defendant a new trial after he was convicted of first-degree murder, holding that the trial court did not commit prejudicial error when it overruled Defendant's objections to the State's closing argument.A jury found Defendant guilty of first-degree murder by premeditation and deliberation and/or by lying in wait. On appeal, Defendant argued that the trial court abused its discretion when it failed to sustain his objections to comments made by the prosecutor during closing argument about race. The court of appeals agreed, holding that the trial court committed prejudicial error by overruling Defendant's objections to the prosecutor's comments and by failing to instruct the jury to disregard the comments or to declare a mistrial. The Supreme Court reversed, holding that, assuming without deciding that the prosecutor's comments were improper, Defendant was not prejudiced by the error. View "State v. Copley" on Justia Law

In this business case, the Supreme Court reversed the orders of the business court denying Plaintiffs' motion for default judgment based on its finding that Plaintiffs had failed to satisfy their burden of proving that the court possessed personal jurisdiction over Defendant, a nonresident company, holding that Defendant's contacts with North Carolina were sufficient to permit the exercise of personal jurisdiction over it in North Carolina state courts.In the complaint, Plaintiffs sought an injunction, in part, directing Defendant to turn over certain documents and information necessary for Plaintiffs to wind up the affairs of a limited-liability limited partnership. A default was entered against Defendant, but the business court denied Plaintiffs' motion for default judgment. The Supreme Court reversed, holding that Defendant had sufficient minimum contacts with this state such that a North Carolina court could constitutionally exercise personal jurisdiction over it. View "Beem USA Limited-Liability Limited Partnership v. Grax Consulting LLC" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions and rejecting Defendant's argument that the trial court erred in denying his motion to dismiss on jurisdictional grounds, holding that Defendant failed to demonstrate that he was an Indian for purposes of the federal Indian Major Crimes Act (IMCA) such that he was not subject to the jurisdiction of North Carolina's courts.Defendant was charged in Jackson County with first-degree murder, robbery with a dangerous weapon, and possession of a firearm by a felon. Defendant moved to dismiss the charges for lack of subject matter jurisdiction, arguing that he was an Indian, and therefore, he could only be tried in federal court pursuant to the IMCA. After a hearing, the trial court denied Defendant's motion to dismiss, determining that Defendant was not an Indian within the meaning of the IMCA. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to dismiss; and (2) the trial court did not err by denying Defendant's request for a special jury verdict. View "State v. Nobles" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that the trial court failed to satisfy the requirements of N.C. Gen. Stat. 15A-1242 before allowing Defendant to proceed pro se, holding that the court of appeals correctly concluded that Defendant did not forfeit his right to counsel and that the trial court was therefore required to ensure that his waiver of counsel was knowing, intelligent, and voluntary.Defendant was charged with offenses related to his failure to maintain a valid driver's license. Defendant was first tried in the district court, where he was convicted. Defendant appealed to the superior court, where he was tried without counsel and convicted by a jury. On appeal, a majority of the court of appeals determined that Defendant did not engage in such serious misconduct as to warrant forfeiture of the right to counsel. The Supreme Court affirmed, holding that Defendant was entitled to a new trial because the trial court violated his right to counsel under the federal and state Constitutions. View "State v. Simpkins" on Justia Law

The Supreme Court affirmed the order of the trial court terminating Mother's parental rights to her five minor children, holding that the trial court's findings supported its conclusion that grounds existed to terminate Mother's parental rights to the children pursuant to N.C. Gen. Stat. 7B-1111(a)(3).The trial court concluded that grounds existed to terminate Mother's parental rights based on neglect, failure to make reasonable progress toward correcting the conditions that led to the children's removal from her care, failure to pay a reasonable portion of the cost of the children's care while they were in the custody of the Department of Social Services (DSS), and dependency. The court further concluded that terminating Mother's parental rights was in the best interests of the children. The Supreme Court affirmed, holding that the record supported the trial court's conclusion that grounds existed to terminate Mother's parental rights for failure to pay a reasonable portion of the cost of the children's care while they were in DSS custody. View "In re J.M." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the superior court's judgment following Defendant's plea of guilty to trafficking in cocaine, holding that the court of appeals correctly determined that the trial court erred in denying Defendant's motion to suppress evidence discovered pursuant to an unlawful traffic stop.In his appeal, Defendant argued that his initial investigatory detention was not properly tailored to address a speeding violation and contended that the officer seized him without consent or reasonable suspicion of criminal activity. Therefore, Defendant argued, the officer unlawfully seized items from the vehicle during the ensuing search of the car and that those objects were the fruit of the poisonous tree. The court of appeals reversed the denial of the motion to suppress, concluding that the officer lacked reasonable suspicion to search the vehicle after the traffic stop had been completed. The Supreme Court affirmed, holding that the evidence was obtained as a result of the officer's unlawful detainment of Defendant without reasonable suspicion of criminal activity after the lawful duration of the traffic stop had concluded. View "State v. Reed" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing in part the trial court's judgments and holding that the trial court had erred by denying Defendant's motion to dismiss the possession of a weapon of mass death and destruction charge for insufficiency of the evidence, holding that a "flash bang" grenade is a weapon of mass death and destruction as defined in N.C. Gen. Stat. 14-288.8(a).Defendant was convicted of, among other things, possession of a weapon of mass death and destruction, which stemmed from his possession of "flash bang" grenades. The court of appeals reversed in part, holding that the flash bang grenades found in Defendant's car were not devices or weapons or grenades capable of causing mass death and destruction when constructing section 14-288.8(c)(1). The Supreme Court reversed, holding that the State presented substantial evidence tending to show that Defendant possessed an "explosive or incendiary" grenade in violation of N.C. Gen. Stat. 14-288.8(a). View "State v. Carey" on Justia Law

The Supreme Court reversed the decision of the court of appeals invalidating a decision by an administrative law judge (ALJ) to award back pay and attorneys' fees to a local government employee protected under the North Carolina Human Resources Act who prevailed in a wrongful termination proceeding before the Office of Administrative Hearings, holding that N.C. Gen. Stat. 126-34.02 explicitly provides that an ALJ has the authority to award back pay and attorneys' fees to any protected state and local government employee.Petitioner was dismissed from her employment with Forsyth County Department of Social Services on the grounds of grossly inefficient job performance and unacceptable personal conduct. An ALJ reversed the Department's decision to terminate Petitioner's employment on the grounds that the Department had violated Petitioner's procedural rights and lacked just cause to dismiss Petitioner from its employment. The ALJ then ordered the Department to reinstate Petitioner to her former position, with all applicable back pay and benefits, and to pay Petitioners' attorneys' fees. The court of appeals vacated the ALJ's decision in part, concluding that the ALJ lacked the authority to award back pay and attorneys' fees. The Supreme Court reversed, holding that the ALJ had sufficient express statutory authority to award back pay and attorneys' fees to Petitioner. View "Rouse v. Forsyth County Department of Social Services" on Justia Law

The Supreme Court affirmed the order of the trial court granting summary judgment in favor of Osae and Scott Bader with respect to SciGrip's trade secrets claim, unfair and deceptive trade practices claim, and request for punitive damages and deciding the parties' motions with regard to SciGrip's breach of contract claims, holding that the trial court did not err.As to SciGrip's breach of contract claims, the trial court granted summary judgment in favor of SciGrip with respect to its breach of contract claim against Osae for violating a consent judgment while he was employed by Bader and refused to grant summary judgment in favor of SciGrip or Osae with respect to sciGrip's claim for breach of contract against Osae for violating the consent judgment during his period of employment with another entity. Further, the court denied Osae's motion to preclude the admission of certain expert testimony proffered by SciGrip on mootness grounds. The Supreme Court affirmed after careful consideration of the parties' challenges to the court's order in light of the evidence in the record, holding that the trial court did not err. View "SciGrip, Inc. v. Osae" on Justia Law