Justia North Carolina Supreme Court Opinion Summaries

After a second jury trial, Defendant was convicted of the first-degree murder of his wife, Michelle Young. The court of appeals vacated the conviction and ordered a new trial, concluding that the trial court had committed prejudicial error by admitting evidence concerning a complaint that had been filed and default judgments that had been entered in two actions - a wrongful death and declaratory judgment action that had been brought against Defendant by the executrix of Ms. Young’s estate and a complaint that had been filed in an action in which members of Ms. Young’s family sought to obtain custody of Emily, the daughter of Defendant and the victim, from Defendant. The Supreme Court reversed, holding that the court of appeals erred by awarding Defendant a new trial based upon the admission of the challenged evidence. Remanded for consideration of Defendant’s remaining challenges to the trial court’s judgment. View "State v. Young" on Justia Law

At issue in this case was whether an adult relative who supervises a child during a sleepover is a “caretaker” of that child under section 7B-101(3) of the Juvenile Code. R.R.N. was abused by Mr. B., a relative, when she spent the night at his house along with his wife and three children. The Wilson County Department of Social Services (DSS) filed a petition alleging that R.R.N. was an abused and neglected juvenile, stating that Mr. B. was R.R.N.’s “caretaker” when R.R.N. spent a single night at his house. Respondent, R.R.N.’s mother, filed a motion to dismiss the petition, arguing that the Juvenile Code did not apply because Mr. B. was not R.R.N.’s caretaker. The trial court disagreed and adjudicated R.R.N. to be an abused and neglected juvenile, thereby allowing the court to assume authority over R.R.N. and her family. The court of appeals reversed. The Supreme Court affirmed, holding that Mr. B. was not R.R.N.’s “caretaker,” as contemplated by section 7B-101(e), when he sexually abused her, and therefore, the trial court erred in adjudicating R.R.N. an abused and neglected juvenile. View "In re R.R.N." on Justia Law

After a jury trial, Defendant was convicted of robbery with a dangerous weapon, second-degree burglary, and first-degree murder under the felony murder rule. Defendant was sentenced to life imprisonment without parole. The Court of Appeals vacated the judgment and ordered that Defendant receive a new trial, holding that the trial court abused its discretion by excluding evidence of a threatening voice mail message left by one of Defendant’s sisters for a different sister and that the error was prejudicial. The Supreme Court reversed, holding that the trial court’s ruling that the probative value of the voice mail message was outweighed by other concerns under N.C. R. Evid. 403 was not “manifestly unsupported by reason.” View "State v. Triplett" on Justia Law

Aqua North Carolina (Aqua), a public utility providing water and utility service, requested authority from the North Carolina Utilities Commission to implement a rate adjustment mechanism of the type described in N.C. Gen. Stat. 62-133.12. After a hearing, the Commission approved Aqua’s request, finding that the request to implement a rate adjustment mechanism was in the public interest. The Attorney General appealed the Commission’s order. The Supreme Court affirmed, holding that the Commission provided sufficient findings, reasoning, and conclusions to support its finding that the mechanism is in the public interest and that the Commission’s determination is supported by substantial evidence in view of the record as a whole. View "State ex rel. Utils. Comm'n v. Cooper" on Justia Law

Plaintiffs, twenty-five taxpayers, filed a complaint challenging the Opportunity Scholarship Program, which allows a small number of students in lower-income families to receive scholarships from the State to attend private school. The trial court declared the Opportunity Scholarship Program legislation unconstitutional on its face and permanently enjoined further implementation and enforcement of the legislation, including the disbursement of public funds. The Supreme Court reversed the trial court’s order and final judgment and dissolved the injunction, holding that no prohibition in the Constitution or in precedent foreclosed the General Assembly’s enactment of the challenged legislation in this case. View "Hart v. State" on Justia Law

Respondent voluntarily placed her newborn son with the Guilford County Department of Health and Human Services (DHHS) based upon her concerns about the safety of her home. DHHS later filed a petition seeking to have Respondent’s parental rights terminated. After a hearing, the trial court terminated Respondent’s parental rights in her son. The court of appeals reversed the trial court’s termination order, concluding that the trial court had abused its discretion by failing to conduct an inquiry into whether Respondent was entitled to the appointment of a parental guardian ad litem given that the information available to the trial court raised a substantial question concerning Respondent’s competence. The Supreme Court reversed, holding that the trial court did not abuse its discretion by failing to conduct an inquiry into Respondent’s competence before proceeding with the termination hearing. View "In re T.L.H." on Justia Law

Petitioners filed a request that the North Carolina Environmental Management Commission issue a declaratory ruling clarifying the application of the Commission’s groundwater protection rules to coal ash lagoons. After the Commission issued its declaratory ruling, Petitioners sought judicial review, claiming that the Commission had misconstrued the applicable regulations and erred in failing to construe the applicable regulations in the manner contended for by Petitioners in their original request for declaratory relief. The trial court determined that portions of the Commission’s decision were plainly erroneous and inconsistent with the regulations and reversed the Commission’s decision with respect to Petitioners’ second request for a declaratory ruling. The Supreme Court vacated the trial court’s order and remanded to the trial court with instructions to dismiss Petitioners’ appeal from the Commission’s declaratory ruling on mootness grounds, holding that the General Assembly’s enactment of Chapter 122 of the 2014 North Carolina Session Laws supersedes the rule at issue in this appeal with respect to coal ash lagoons located at facilities with active permits. Remanded. View "Cape Fear River Watch v. N.C. Envtl. Mgmt. Comm’n" on Justia Law

Defendant was indicted for felony breaking or entering a place of worship and felony larceny after breaking or entering. After a trial, the jury found Defendant guilty of felony larceny and felony breaking or entering a place of religious worship. The court of appeals vacated Defendant’s larceny conviction and reversed his conviction for breaking or entering, concluding (1) the larceny indictment was “fatally flawed” because it it did not specifically state that a church, the alleged co-owner of the stolen property, was a legal entity capable of owning property; and (2) there was insufficient evidence of Defendant’s intent to commit larceny. The Supreme Court reversed, holding (1) the indictment was sufficient on its face because the name of a church necessarily imports an entity capable of owning property; and (2) there was sufficient evidence of Defendant’s criminal intent to sustain a conviction for felony breaking or entering a place of religious worship. Remanded. View "State v. Campbell" on Justia Law

After a jury trial, Defendant was convicted of trafficking in cocaine by possession, trafficking in cocaine by transportation, and possession of cocaine with the intent to sell or deliver. Defendant appealed, arguing that the trial court committed plain error by failing to adequately instruct the jury that the State had to prove beyond a reasonable doubt that he knew that he had possessed and transported cocaine. The court of appeals reversed Defendant’s convictions and awarded him a new trial. The Supreme Court reversed, holding that the trial court did not err by failing to instruct the jury in accordance with footnote four to N.C.P.I. Crim. 260.17 and 260.30 because the trial court’s instructions here adequately addressed the issue that the jury had to decide to determine Defendant’s guilt or innocence. View "State v. Galaviz-Torres" on Justia Law

A police officer stopped and searched Defendant outside a shop known for drug activity. Defendant was subsequently indicted for possession of a firearm by a felon, possession of a firearm with an altered serial number, and conspiracy to posses with intent to sell or deliver marijuana. Defendant filed a motion to suppress the evidence obtained as a result of the initial stop, arguing that the officer lacked reasonable suspicion to conduct an investigatory stop. The trial court denied the motion. The court of appeals reversed, holding that the officer lacked reasonable suspicion to conduct an investigatory stop of Defendant. The Supreme Court reversed, holding that the unchallenged findings of fact made by the trial court sufficiently established that the officer possessed reasonable suspicion to conduct a brief investigatory stop of Defendant. View "State v. Jackson" on Justia Law