Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the Court of Appeals finding that the citation that charged the offense for which Defendant was convicted was legally sufficient to properly invoke the trial court’s subject-matter jurisdiction, holding that the trial court had subject-matter jurisdiction to enter judgment in this criminal proceeding.Defendant was convicted of operating a motor vehicle when having an open container of alcohol in the passenger compartment while alcohol remained in his system. On appeal, Defendant argued that the trial court lacked jurisdiction in this criminal matter because the citation purporting to charge him of the charged offense failed to allege all of its essential elements. The court of appeals affirmed. The Supreme Court affirmed, holding that the citation included sufficient criminal pleading contents in order to properly charge Defendant with the misdemeanor offense for which he was found guilty. View "State v. Jones" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals concluding that the trial court committed prejudicial error in three of its rulings during the trial proceedings and that Defendant was entitled to a new trial, holding that the court of appeals erred in finding error on two of the three issues but properly found prejudicial error on the first issue.A jury found Defendant guilty of assault with a deadly weapon inflicting serious injury. The court of appeals reversed, concluding that the trial court committed prejudicial error by (1) omitting the relevant stand-your-ground language from jury instructions on self-defense, (2) excluding evidence at trial of specific incidents of the victim’s violent past conduct, and (3) denying Defendant’s motion to continue. The Supreme Court reversed in part, holding (1) the Court of Appeals correctly found that Defendant was entitled to a new trial on the basis that the trial court committed reversible error in omitting the relevant stand-your-ground language from the jury instructions; but (2) the trial court did not err in excluding specific instances of the victim’s violent conduct or in denying Defendant’s motion to continue. View "State v. Bass" on Justia Law

The Supreme Court ordered that Respondent Ronald L. Chapman be suspended without compensation from office as a Judge of the General Court of Justice, District Court Division Twenty-Six, for thirty days for conduct violating Canons 1, 2A, 3A(5), and 3B(1) of the North Carolina Code of Judicial Conduct and for conduct prejudicial to the administration of justice that brings the judicial office into disrepute, in violation of N.C. Gen. Stat. 7A-376, holding that the Judicial Standards Commission’s recommended thirty-day suspension without compensation was appropriate.The Commission Counsel filed a statement of charges against Respondent, alleging that he had engaged in inappropriate conduct by failing to issue a ruling for more than five years on a motion for permanent child support. Based on its findings of fact and conclusions of law, the Commission recommended that the Supreme Court suspend Respondent without pay for a period of thirty days. The Supreme Court concluded that the recommended sanction was appropriate and ordered that Respondent be suspended without compensation for thirty days. View "In re J.C." on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that Defendant’s stipulation to a certain type of second-degree murder was an improper stipulation, holding that Defendant properly stipulated to the facts underlying his conviction and the conviction itself.As part of a plea agreement, Defendant stipulated to the sentencing worksheet showing his prior offenses, one of which was a second-degree murder conviction designated as a B1 offense. In so stipulating, Defendant acknowledged that the factual basis of his conviction involved general second-degree murder, a B1 classification, and did not implicate the exception for less culpable conduct involving an inherently dangerous act or omission or a drug overdose, a B2 classification. The court of appeals vacated the trial court’ judgment and set aside Defendant’s guilty plea, concluding that Defendant improperly stipulated to a matter of “pure legal interpretation.” The Supreme Court reversed, holding (1) Defendant’s stipulation was properly understood to be a stipulation to the facts of his prior offense, and those facts supported the offense’s B1 classification; and (2) the trial court properly accepted the stipulation. View "State v. Arrington" on Justia Law

The Supreme Court reversed the decision of the court of appeals awarding Defendant a new trial because of a plain error in a jury instruction on aiding and abetting, holding that the trial court erred in giving the aiding and abetting instruction but that the error did not amount to plain error.The jury convicted Defendant of several drug crimes. The Court of Appeals granted Defendant a new trial, holding that the trial court committed plain error in giving the aiding and abetting instruction. The Supreme Court reversed, holding (1) the Court of Appeals erred in reasoning that, absent the improper aiding and abetting instruction, the jury probably would have reached a different result and erred in applying the correct stander for plain error; and (2) given the evidence of Defendant’s guilt, the trial court’s error in giving the aiding and abetting instruction did not amount to plain error. View "State v. Maddux" on Justia Law

In this personal injury case involving a building that a city owned but leased to a nonprofit arts group, the Supreme Court reversed the decision of the court of appeals reversing the trial court’s order granting summary judgment in favor of Defendant, the City of Gastonia, based upon the doctrine of governmental immunity, holding that Defendant was entitled to governmental immunity under the circumstances of this case.Plaintiff filed this complaint alleging that Defendant was negligent in failing to maintain its building’s exit in a reasonably safe condition and failing to warn of the dangerous and hazardous condition of the exit. The trial court granted summary judgment for Plaintiff, concluding that Defendant was entitled to governmental immunity. The court of appeals reversed, concluding that governmental immunity did not apply. The Supreme court reversed, holding that the trial court correctly determined that Defendant’s activity in leasing the property to the arts group was a governmental function, and therefore, Defendant was entitled to governmental immunity. The court remanded this case to address the issue of whether Defendant waived governmental immunity by purchasing liability insurance. View "Meinck v. City of Gastonia" on Justia Law

The North Carolina Supreme Court held that the State failed to carry its burden of presenting sufficient evidence to support the trial court's decision to revoke defendant's probation based upon a finding that defendant willfully absconded probation. Therefore, the court affirmed the decision of the court of appeals. However, the court disavowed the portion of the opinion analyzing the pertinence of the fact that defendant's probationary term expired prior to the date of the probation violation hearing and holding "that the trial court lacked jurisdiction to revoke defendant’s probation after his case expired." View "State v. Krider" on Justia Law

The Supreme Court held that the court of appeals erred in reversing the trial court’s denial of Defendant’s motion to suppress, holding that the suppression motion contained sufficient findings of fact to support the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights pursuant to N.C. Gen. Stat. 7B-2101 before making certain incriminating statements.The court of appeals determined that the totality of the circumstances set forth in the record did not fully support the trial court’s conclusion that Defendant knowingly, willingly, and understandingly waived his juvenile rights. The Supreme Court reversed, holding (1) the trial court’s findings of fact had adequate evidentiary support, and those findings supported the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights; and (2) in reaching a contrary conclusion, the court of appeals failed to focus upon the sufficiency of the evidence to support the trial court’s findings of fact and to give proper deference to those findings. View "State v. Saldierna" on Justia Law

The Supreme Court held in this criminal case that while the claim asserted in Defendant’s motion for appropriate relief was not subject to the procedural bar established by N.C. Gen. Stat. 15A-1419(a)(3), the trial court did not err by denying Defendant’s motion for the reasons stated by the court of appeals.The jury returned a verdict convicting Defendant of first-degree murder, and the trial court sentenced Defendant to a term of life imprisonment without parole. Defendant later filed a motion for appropriate relief asserting, among other things, that his constitutional right to effective, conflict-free trial counsel had been violated. The trial court denied Defendant’s motion after conducting an evidentiary hearing. The Supreme Court concluded that Defendant’s ineffective assistance of counsel claim was not procedurally barred and overturned the trial court’s order denying Defendant’s motion for appropriate relief. The Supreme Court affirmed in part and reversed in part, holding (1) Defendant was not subject to the procedural bar created by N.C. Gen. Stat. 15A-1419(a)(3) with respect to his ineffective assistance of counsel claim; but (2) the trial court properly denied Defendant’s motion for appropriate relief. View "State v. Hyman" on Justia Law

The Supreme Court held that the habitual felon indictment returned against Defendant was not fatally defective, and therefore, the court of appeals erred in ordering that the judgment regarding the habitual conviction be vacated.Defendant was charged with assault with a deadly weapon with the intent to kill, attempted first-degree murder, having attained habitual felon status, and other charges. The jury found Defendant guilty as charged. On appeal, Defendant argued that the habitual felon indictment that had been returned against him was facially defective. The court of appeals agreed and ordered that the case be remanded for resentencing on the underlying felonies without the habitual felon enhancement. The Supreme Court reversed, holding that the habitual felon indictment returned against defendant was not fatally defective. View "State v. Langley" on Justia Law