Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court held in this appeal regarding two cases that were consolidated before trial by one superior court judge and then tried by another superior court judge that (1) the first judge erred in consolidating the cases because he was not scheduled to preside over the consolidated trial, but (2) the judge who presided at trial effectively corrected the procedural error, which left no error for the appellate courts to address.The Court concluded that the first judge’s consolidation order had no binding effect on the second judge because the first judge was not scheduled to preside over the trial. By ultimately consolidating the cases, the presiding judge implicitly ratified the consolidation decision, leaving the trial and judgment untainted. Therefore, other the first judge’s order was procedurally in error, but the presiding judge’s implicit determination that the cases should be consolidated for trial replaced the first judge’s determination on consolidation and corrected the procedural error that the first judge had made. View "Boone Ford, Inc. v. IME Scheduler, Inc." on Justia Law

The Supreme Court held that the trial court correctly denied Defendant’s motion to dismiss as to the charge of keeping or maintaining a vehicle which is used for the keeping or selling of controlled substances, holding that it can be reasonably be inferred from the evidence that Defendant had kept the car that he was driving and that he was using that car to store crack cocaine when he was arrested.Defendant was pulled over by law enforcement officers during a drug investigation. The officers discovered two bags of crack cocaine hidden behind the gas-cap door of the car that Defendant was driving. Defendant was indicted for several offenses. The trial court granted Defendant’s motion to dismiss as to the possession-of-cocaine charge but denied the motion as to all other remaining charges. The jury found Defendant guilty of all of these charges. The court of appeals reversed Defendant’s conviction for keeping or maintaining a vehicle which is used for the keeping or selling of a controlled substance, concluding that there was insufficient evidence to support the charge. The Supreme Court disagreed, holding that viewing the evidence in the light most favorable to the State and drawing all reasonable inferences from that evidence, a reasonable jury could find that Defendant committed the crime at issue. View "State v. Rogers" on Justia Law

The Supreme Court held that the two-year statute of limitations in N.C. Gen. Stat. 15-1 did not bar the State from prosecuting Defendant for the misdemeanor offense of driving while impaired (DWI) when the State did not charge Defendant by indictment or presentment and did not commence prosecution with the two-year period because other valid criminal pleadings listed in N.C. Gen. Stat. 15A-921 tolled the section 51-1 statute of limitations.The district court granted Defendant’s motion to dismiss, determining that the statute of limitations in section 15-1 barred further prosecution of Defendant. The court of appeals affirmed, concluding that the State was barred from prosecuting this action due to expiration of the statute of limitations. The Supreme Court reversed, holding (1) any criminal pleading that establishes jurisdiction in the district court should toll the two-year statute of limitations in section 15-1; and (2) the citation issued to Defendant for DWI tolled the statute of limitations in this case. View "State v. Curtis" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that Rule 9(j) does not permit a plaintiff to amend a timely filed medical malpractice complaint to cure a defective Rule 9(j) certification after the statute of limitations has run when the expert review required by Rule 9(j) occurred before the filing of the original complaint, holding that the procedures Plaintiff followed in this case were consistent with the letter and spirit of the rule.Plaintiff filed this medical malpractice complaint, but Plaintiff’s Rule 9(j) certification inadvertently used the language of a prior version of Rule 9(j). Defendants then filed a motion to dismiss. In response, Plaintiff filed a motion for leave to file an amended complaint to cure her defective Rule 9(j) certification. The trial court denied Plaintiff’s motion and dismissed the complaint with prejudice. The court of appeals affirmed, holding that where Plaintiff did not file the complaint with the proper Rule 9(j) certification before the running of the statute of limitation, the complaint could not have been deemed to have commenced within the statute. The Supreme Court reversed, holding that Plaintiff should be permitted to amend her medical malpractice complaint to correct a purely technical pleading error under the circumstances of this case. View "Vaughan v. Mashburn" on Justia Law

At issue was whether legislation amending portions of certain provisions of the North Carolina General Statutes, including Chapter 115C, violates N.C. Const. art. IX, 5.In 2016, the General Assembly enacted House Bill 17, which amended numerous provisions of Chapter 115C, eliminated certain aspects of the North Carolina State Board of Education’s (Board) oversight of a number of the powers and duties of the Superintendent of Public Instruction (Superintendent), and assigned several powers and duties that had formerly belonged to the Board to the Superintendent. The Governor subsequently signed into law House Bill 17, which became Session Law 2016-126. The Board filed a complaint seeking a declaratory judgment that certain provisions of Session Law 2016-126 are unconstitutional. A three-judge panel of the superior court concluded that statutory changes worked by Session Law 2016-126 did not contravene the relevant provisions of the North Carolina Constitution. The Supreme Court affirmed, holding the the enactment of Session Law 2016-126 does not, on its face, contravene N.C. Const. art. IX, 5. View "North Carolina State Board of Education v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree murder but vacated his sentence of death and remanded the case to the superior court for a new capital sentencing hearing.The Court held (1) there was no error in the trial court proceedings, including jury selection or the guilt phase, that led to Defendant’s conviction; (2) the evidence was sufficient to support the conviction; (3) the trial court did not err by denying Defendant’s motion to set aside the jury’s verdict in favor of the State with respect to the issue of Defendant’s alleged intellectual disability; (4) the trial court erred by failing to submit the statutory mitigating circumstance enumerated in N.C. Gen. Stat. 15A-2000(f)(6), which addresses the extent to which Defendant’s capacity to appreciate the criminality of his conduct or to conform his conduct to the law was impaired, to the jury at Defendant’s capital hearing. View "State v. Rodriguez" on Justia Law

The General Assembly lawfully delegated authority to the Rules Review Commission (Commission) to review and approve rules adopted by the State Board of Education (Board).The Board sought a declaratory ruling that the laws requiring the Board to submit its proposed rules and regulations to the statutorily created committee for review were unconstitutional. The trial court allowed summary judgment for the Board. The court of appeals reversed. The Supreme Court affirmed, holding that N.C. Const. art. IX, 5 authorizes the General Assembly to statutorily delegate authority to the Commission to review and approve administrative rules that are proposed by the Board for codification. View "North Carolina State Board of Education v. State" on Justia Law

The North Carolina Department of Revenue (Defendant) unconstitutionally taxed the income of The Kimberly Rice Kaestner 1992 Family Trust (Plaintiff) pursuant to N.C. Gen. Stat. 105-160.2 based solely on the North Carolina residence of the beneficiaries during certain tax years because Plaintiff did not have sufficient minimum contacts with the State of North Carolina to satisfy the due process requirements of the state and federal Constitutions.Plaintiff filed a complaint alleging that Defendant wrongfully denied Plaintiff’s request for a refund because the taxes collected pursuant to section 105-160.2 violate the due process clause. The North Carolina Business Court concluded that the provision of section 105-160.2 allowing taxation of a trust income “that is for the benefit of a resident of this State” violated both the Due Process Clause and N.C. Const. art. I, 19, as applied to Plaintiff. The court therefore granted Plaintiff’s motion for summary judgment. The court of appeals affirmed. The Supreme Court affirmed, holding (1) section 105-160.2 is unconstitutional as applied to collect income taxes from Plaintiff for the tax years at issue; and (2) therefore, summary judgment was properly granted for Plaintiff. View "Kaestner 1992 Family Trust v. North Carolina Department of Revenue" on Justia Law

A police officer’s decision to briefly detain Defendant for questioning was supported by a reasonable suspicion of criminal activity.Defendant was indicted for robbery with a dangerous weapon. Defendant moved to suppress evidence obtained as a result of his seizure by the police officer, asserting that he had been unlawfully detained, in violation of his constitutional rights. The trial court denied the motion to suppress, and Defendant was subsequently convicted of common law robbery. The court of appeals ordered a new trial, concluding that the trial court committed prejudicial error by denying Defendant’s suppression motion and that the police officer lacked reasonable suspicion to detain Defendant for questioning. The Supreme Court reversed, holding that the undisputed facts established reasonable suspicion necessary to justify Defendant’s seizure. View "State v. Nicholson" on Justia Law

The Supreme Court reversed the decision of the court of appeals in vacating the judgments entered by the trial court based upon Defendant’s convictions for first-degree murder and attempted first-degree murder on the grounds that certain evidence had been admitted in violation of the Confrontation Clause.The court of appeals concluded that the statements at issue were admitted in violation of Defendant’s constitutional right to confront the State’s witnesses against him. The Supreme Court reversed, holding that the trial court did not err by overruling Defendant’s confrontation-based objection and allowing the admission of the challenged evidence. View "State v. Miller" on Justia Law