Justia North Carolina Supreme Court Opinion Summaries

In this class action, the Supreme Court recognized a narrow exception to the doctrine of mootness when a named plaintiff's individual claim becomes moot before the plaintiff has had a fair opportunity to pursue class certification and has otherwise acted without undue delay regarding class certification.The Moses H. Cone Memorial Hospital Operating Corporation sued Christopher Chambers and his wife seeking collection of $14,358 plus interest allegedly owed for emergency room services. At the same time, Chambers filed a class action complaint against Moses Cone seeking a declaratory judgment that the contract he signed as an uninsured patient needing emergency medical treatment entitled Moses Cone to recover no more than the reasonable value of the services it provided. Prior to certification of the class in Chambers's declaratory judgment action, Moses Cone dismissed its claims against Chambers and his wife and ceased all other attempts to collect the debt. At issue on appeal was whether the class action was moot. The Supreme Court held that, under these circumstances, the named plaintiff's claim relates back to the filing of the complaint for mootness purposes, and even though his individual claim may have been satisfied, the named plaintiff retains the legal capacity to pursue class certification and class-wide relief. View "Chambers v. Moses H. Cone Memorial Hospital" on Justia Law

In this child custody dispute between two biological parents the Supreme Court reversed the decision of the court of appeals to the extent that it vacated the trial court's order regarding custody, holding that a trial court may grant full custody to one parent and deny visitation to the other parent under certain circumstances.The trial court entered an amended permanent child custody order awarding sole physical custody of the parties' children to Father and denying visitation by Mother. The court of appeals vacated the order, concluding that the trial court erred in denying Mother's ability to have visitation with her children without a determination that she was unfit to have visitation with them. The Supreme Court reversed, holding that the trial court may deny visitation to a non-custodial parent, so long as the court has entered a written finding of fact that such a custody award is in the best interests of the children, without the need to have determined that the parent who has been denied visitation is deemed unfit to spend time with the children. View "Routten v. Routten" on Justia Law

The Supreme Court affirmed the order of the trial court terminating Father's parental rights to his minor child, holding that the trial court did not err in adjudicating neglect as a ground to terminate Father's parental rights to his minor child pursuant to N.C. Gen. Stat. 7B-1111(a)(1).After a hearing, the trial court entered an order concluding that grounds existed to terminate Father's parental rights based on neglect and abandonment. See N.C. Gen. Stat. 7B-1111(a)(1), (7). The trial court further concluded that termination of Father's parental rights was in the child's best interests. The Supreme Court affirmed, holding that the trial court's conclusion that a ground for termination existed pursuant to section 7B-1111(a)(1) was sufficient in and of itself to support the termination of Father's parental rights. View "In re J.M.J.-J" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals affirming the trial court's determination that Defendant failed to demonstrate a fair and just reason for the withdrawal of his guilty plea, holding that the trial court did not err in denying Defendant's motion to withdraw his guilty plea.Defendant pled guilty to second-degree murder, robbery with a dangerous weapon, and conspiracy to commit robbery. Defendant later filed a motion to withdraw his guilty plea. The trial court denied Defendant's motion. The court of appeals affirmed after considering and applying the factors identified by the Supreme Court in State v. Handy, 391 S.E.2d 159 (N.C. 1990). The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to withdraw his guilty plea based upon the trial court's ruling that Defendant failed to show any fair and just reason for the withdrawal of his guilty plea; and (2) this Court disavows the dicta contained in the court of appeals' decision regarding the subject of prejudice to the State after the court's stated conclusion that Defendant had not satisfied the Handy factors. View "State v. Taylor" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming superior court judgments denying Defendant's Batson motion, holding that Defendant presented a sufficient record to permit meaningful appellate review of Defendant's Batson challenge and that Defendant established the existence of a prima facie case of discrimination necessary to require the performance of a complete Batson analysis.The trial court allowed Defendant to make a Batson motion but subsequently denied the motion, finding that there was no prima facie showing justifying the Batson challenge. The court of appeals also rejected Defendant's Batson claim, stating that, "[a]ssuming, arguendo, that defendant's argument is properly before us, we find no error in the ruling of the trial court and affirm." The Supreme Court reversed and remanded the case for further proceedings in the superior court, holding (1) the record was sufficient to permit appellate review of the merits of Defendant's Batson claim; and (2) the trial court erred in failing to find the existence of a prima facie showing of racial discrimination. View "State v. Bennett" on Justia Law

The Supreme Court held that the trial court erred by failing to summarily deny the applications for the issuance of a writ of habeas corpus submitted by Petitioners, Carlos Chavez and Luis Lopez, for its consideration in this case.A sheriff entered into an agreement with the United States Immigration and Customs Enforcement pursuant to section 287(g) of the Immigration and Nationality Act, 8 U.S.C. 1357, that certified deputies to perform specific immigration enforcement functions, including the detention of undocumented aliens. Petitioners, who were being held in pretrial detention pursuant to immigration-related arrest warrants and detainers, filed petitions seeking the issuance of a writ of habeas corpus. The trial court issued writs of habeas corpus. The court of appeals vacated the trial court orders, concluding that the trial court lacks jurisdiction to issue writs of habeas corpus for alien petitions not in state custody and held under federal authority. The Supreme Court reversed in part, holding that state judicial officials acting in counties in which the sheriff has entered into a 287(g) agreement with the federal government do not have the authority to grant applications for the issuance of writs of habeas corpus for and to order the release of individuals held pursuant to immigration-related arrest warrants and detainers. View "Chavez v. McFadden" on Justia Law

The Supreme Court affirmed the order of the trial court terminating Parents' parental rights to their two minor children, holding that the trial court did not abuse its discretion by determining that termination of Parents' parental rights would be in the children's best interests.After a hearing, the trial court entered an order terminating Parents' parental rights on the grounds of neglect and failure to make reasonable progress. Further, the trial court concluded that termination of Parents' parental rights would be in the children's best interests. The Supreme Court affirmed, holding that the trial court considered all of the relevant statutory criteria set out in N.C. Gen. Stat. 7B-1110(a) and made a reasoned determination that termination of Parents' parental rights in the children would be in the children's best interests. View "In re I.N.C." on Justia Law

The Supreme Court affirmed the order of the trial court terminating Father's parental rights, holding that the status exception to the requirement that a nonresident parent have minimum contacts with North Carolina in order to establish personal jurisdiction over him for purposes of termination of parental rights proceedings applies to termination of parental rights proceedings.After the children in this case were adjudicated as neglected the trial court acknowledged that Father was a resident of South Carolina. The trial court later terminated Father's parental rights. Father appealed, arguing that the trial court lacked personal jurisdiction to terminate his parental rights because he lacked minimum contacts with the State of North Carolina. The Supreme Court affirmed, holding that due process does not require a nonresident parent to have minimum contacts with the State to establish personal jurisdiction for purposes of termination of parental rights proceedings. View "In re F.S.T.Y." on Justia Law

The Supreme Court modified and affirmed the judgment of the court of appeals reversing the trial court's award of attorney fees to Defendant, holding that N.C. Gen. Stat. 6-19.1 does not preclude a trial court from awarding attorney's fees in disciplinary actions by a licensing board, but when there is substantial justification for the agency's claims, the award of attorney's fees is unjust.The North Carolina State Board of Plumbing, Heater, & Fire Sprinkler Contractors disciplined Dale Winkler for working on a pool heater without proper licensure. The trial court affirmed. The court of appeals concluded that the Board lacked jurisdiction to discipline Winkler for conducting the pool heater inspection and vacated the portion of the Board's order relating to Winkler's inspection of the pool heater. Winkler then filed a motion for attorney's fees and costs. The trial court awarded Winkler attorney's fees and costs. The court of appeals held that the trial court erred in awarding attorney's fees because section 6-19.1 excludes cases arising out of the defense of a disciplinary action by a licensing board. The Supreme Court affirmed on different grounds, holding that the trial court erred in awarding Winkler attorney's fees because there was substantial justification for the Board's claims. View "Winkler v. N.C. State Board of Plumbing, Heating & Fire Sprinkler Contractors" on Justia Law

The Supreme Court affirmed the orders of the trial court on adjudication and disposition that terminated Mother's parental rights to her child, holding that the trial court did not err or abuse its discretion.Specifically, the Supreme Court held that the trial court (1) did not abuse its discretion in denying Mother's second motion to continue the termination hearing in order to obtain her son's testimony; and (2) did not err in adjudicating grounds for the termination of Mother's parental rights because the evidence and the court's findings of fact supported its conclusion that Mother willfully abandoned her child for purposes of N.C. Gen. Stat. 7B-1111(a)(7). View "In re A.L.S." on Justia Law