Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction, holding that the trial court clearly erred in ruling that Defendant failed to prove purposeful discrimination with respect to the State's use of peremptory challenges to strike three jurors without considering all of the evidence presented by Defendant.Defendant was found guilty of one count of first-degree murder and other crimes. On appeal, Defendant argued that the trial court erred by failing to grant three objections that he made under Batson v. Kentucky, 476 U.S. 79 (1986). The court of appeals affirmed Defendant's convictions. The Supreme Court reversed, holding (1) the court of appeals erred in its analysis of Defendant's Batson claims with respect to the three jurors; and (2) as to all three jurors, remand was required for reconsideration of whether Defendant proved purposeful discrimination in each case. View "State v. Hobbs" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's judgment convicting Defendant for conspiracy to commit harassment of a juror, holding that the trial court erred in denying Defendant's motion to dismiss the conspiracy charge for insufficient evidence.Defendant was convicted of conspiracy to commit harassment of a juror because of his actions at a courthouse following his twin brother's conviction for assault on a government official. On appeal, the court of appeals concluded that the trial court did not err in denying Defendant's motion to dismiss the conspiracy charge for insufficient evidence. The Supreme Court reversed, holding that the evidence in Defendant's trial was insufficient to raise anything more than mere conjecture that he had made an agreement with another person to threaten or intimidate a juror. View "State v. Mylett" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that officials of The University of North Carolina at Chapel Hill (University) are required to release, as public records, disciplinary records of its students who have been found to have violated the University's sexual assault policy, holding that the University did not have discretion to withhold the information sought.Plaintiffs, news organizations, brought this action for alleged violations of the North Carolina Public Records Act. Defendants argued that they were prohibited from complying with the Public Records Act in light of applicable provisions of the federal Family Educational Rights and Privacy Act (FERPA). The trial court determined that Defendants were not required to produce the student records requested by Plaintiffs, concluding that the doctrines of field preemption and conflict preemption operated to implicitly preempt, by force of federal law, any required disclosure by the Public Records Act of the requested records. The court of appeals reversed. The Supreme Court affirmed, holding (1) the information sought in this case was authorized by and specified in the FERPA as subject to release; and (2) therefore, as an agency of the state, the University must comply with the Public Records Act and allow Plaintiff access to the information. View "DTH Media Corp. v. Folt" on Justia Law

The Supreme Court reversed the decision of the Court of Appeals affirming the trial court's denial of Defendant's motion to suppress evidence, holding that there was no reasonable suspicion to justify the law enforcement officer's stop when Defendant signaled with his middle finger from the passenger side window of a moving vehicle.While assisting a stranded motorist, the officer turned his attention to another car traveling on the roadway, a white SUV. Defendant had his arm outside the passenger window and gestured with his middle finger, making an up-and-down motion. Believing that Defendant was committing the crime of disorderly conduct, the officer pursued and then stopped the SUV. At trial, Defendant moved to suppress the officer's testimony, arguing that there was no reasonable suspicion to justify the stop. The trial court denied the motion. Defendant pleaded guilty to resisting, delaying, or obstructing a public officer. The court of appeals affirmed the trial court's denial of Defendant's motion to suppress. The Supreme Court reversed, holding that the specific, articulable facts did not establish reasonable suspicion of the crime of disorderly conduct. View "State v. Ellis" on Justia Law

The Supreme Court affirmed the orders of the trial court terminating Father's parental rights in his two minor children in grounds of willful abandonment, holding that there was no error in the termination orders.In its termination orders, the trial court concluded that Father's actions and inactions manifested a "willful determination to forego all parental duties and relinquish all parental claims" regarding the children and that this was done with "purpose and deliberation." The custody and visitation order that was presented at Mother's request precluded Father from having direct contact with the children. On appeal, Father argued that this prohibition stood as an absolute barrier to his ability to show love, affection, and parental concern for the children and that this fact should preclude a finding of abandonment. The Supreme Court affirmed, holding that the trial court's termination orders should be affirmed. View "In re A.G.D." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing judgments entered by the superior court convicting and sentencing Defendant on five separate counts for violation of N.C. Gen. Stat. 14-269.2(b) based on an incident in which he was discovered on the grounds of a school in possession of five guns, holding that, under the rule of lenity, Defendant could only lawfully be convicted on one firearm count.Defendant's convictions arose from an incident in which he was discovered on the grounds of a school in possession of five guns. At issue was whether section 14-259.2(b) was ambiguous as to whether multiple convictions are permitted for the simultaneous possession of more than one firearm on a single occasion. The Supreme Court invoked the rule of lenity and held that Defendant could be convicted of only a single violation of the statute. View "State v. Conley" on Justia Law

In this medical malpractice action, the Supreme Court reversed the decision of the court of appeals affirming the trial court's order granting Defendant's motion to dismiss on the basis that Plaintiff's complaint failed to comply with N.C. R. Civ. P. 9(j), holding that the court of appeals erred in concluding that Plaintiff's expert witness was unwilling to testify that Defendant did not comply with the applicable standard of care.Specifically, the Supreme Court held (1) both the trial court and the court of appeals erred in failing to view the evidence regarding the expert witness's willingness to testify under Rule 9(j) in the light most favorable to Plaintiff; (2) in its de novo review, the court of appeals erred by deferring entirely to the findings of the trial court; and (3) the complaint should not be dismissed on Rule 9(j) grounds because the factual record demonstrated that the expert witness was willing to testify at the time of the filing of the complaint that Defendant breached the standard of care. View "Preston v. Movahed" on Justia Law

The Supreme Court affirmed the order of the trial court terminating Father's parental rights to his child, holding that the trial court did not err in its determination.Mother filed a petition to terminate Father's parental rights on the grounds that the child was born out of wedlock, Father failed to provide substantial financial support or consistent care with respect to Mother and the child, and that Father had willfully abandoned the child. The trial court concluded that grounds existed to terminate Father's parental rights based on willful abandonment and that termination of Father's parental rights was in the child's best interests. The Supreme Court affirmed, holding (1) the trial court properly appointed a guardian ad litem for the child; and (2) the trial court did not abuse its discretion by concluding that it would be in the child's best interests to terminate Father's parental rights. View "In re C.J.C." on Justia Law

The Supreme Court affirmed the order of the district court terminating Father's parental rights to his child, holding that the district court did not err in concluding that grounds existed to terminate Father's parental rights.The Pitt County Department of Social Services filed a petition to terminate the parental rights of Father, alleging four grounds to terminate his parental rights. The district court entered an order concluding that grounds existed to terminate Father's parental rights based on all of the grounds alleged in the petition. The district court further concluded that termination of Father's parental rights was in the child's best interests. The Supreme Court affirmed, holding that the district court did not err by concluding that grounds existed to terminate Father's parental rights. View "In re N.P." on Justia Law

The Supreme Court affirmed the decisions of the court of appeals and the trial court holding that the City of Asheville improperly denied an application for the issuance of a conditional use permit submitted by PHG Asheville, LLC seeking authorization to construct a hotel in downtown Asheville, holding that the City lacked the authority to deny the requested conditional use permit.The trial court determined that PHG was entitled to the issuance of the requested conditional use permit because the City had improperly concluded that PHG failed to present competent, material, and substantial evidence tending to show that the proposed hotel satisfied the standards of a conditional use permit set out in the City's unified development ordinance. The court of appeals affirmed. The Supreme Court affirmed, holding that PHG presented competent, material, and substantial evidence that the proposed hotel satisfied the relevant conditional use permit standards set out in the City's unified development ordinance. View "PHG Asheville, LLC v. City of Asheville" on Justia Law