Justia North Carolina Supreme Court Opinion Summaries
State v. Julius
The Supreme Court reversed the decision of the court of appeals affirming the trial court's denial of Defendant's motion to suppress and finding no error in her criminal trial, holding that the search for evidence in this case violated the Fourth Amendment and that remand was required.Defendant was convicted of trafficking in methamphetamine, possession with intent o manufacture, sell, or deliver methamphetamine, and possession of methamphetamine. The court of appeals affirmed. The Supreme Court reversed, holding (1) the search and subsequent seizure of contraband did not comport with the Fourth Amendment; and (2) remand was required for the trial court to determine if the evidence should be suppressed pursuant to the exclusionary rule. View "State v. Julius" on Justia Law
Town of Midland v. Harrell
The Supreme Court affirmed the judgment of the court of appeals affirming the trial court's entry of summary judgment in favor of the Town of Midland ordering Defendants to pay the Town a total of $97,400 in civil penalties but remanding the trial court's mandatory permanent injunction and abatement order and reversing the trial court's denial of Defendants' request for attorney's fees, holding that there was no error.In an earlier round of litigation, the court of appeals determined that Defendants were under a continuing responsibility to maintain the roads in a residential subdivision. The zoning administrator later sent Defendants a demand letter informing them that they owed civil penalties. When Defendants took no action, the Town filed suit, seeking a mandatory injunction and order of abatement requirement Defendants to repair the roads at issue. The trial court granted summary judgment for the Town. The court of appeals affirmed the civil penalties but reversed the permanent injunction and abatement order for failure to survive appellate scrutiny. The Supreme Court affirmed, holding (1) the Town had standing to bring this suit; and (2) the court of appeals correctly determined that it was bound by the prior decision of another panel holding Defendants responsible for the subdivision's roads. View "Town of Midland v. Harrell" on Justia Law
State v. Pickens
The Supreme Court affirmed the judgment of the trial court convicting Defendant, a former chorus teacher at a middle school, of first-degree rape and first-degree statutory sexual offense with a child, Ellen, a middle school student, holding that Defendant was not entitled to relief on his allegations of error.At issue on appeal, among other things, was whether evidence of Defendant's alleged rape of another student, Kathleen, was properly admitted during trial under N.C. R. Evid. 404(b). The Supreme Court reversed the decision of the court of appeals to vacate Defendant's sentence and otherwise affirmed, holding that the trial court (1) did not err in admitting Kathleen's Rule 404(b) testimony; and (2) did not improperly consider Defendant's choice not to plead guilty and exercise his right to a jury trial when it imposed Defendant's sentence or when it imposed consecutive sentences on Defendant. View "State v. Pickens" on Justia Law
Posted in:
Criminal Law
Sound Rivers, Inc. v. N.C. Dep’t of Environmental Quality
The Supreme Court affirmed the decision of the administrative law judge (ALJ) from the Office of Administrative Hearings affirming the decision of the North Carolina Department of Environmental Quality, Division of Water Resources (Division) to issue a National Pollutant Discharge Elimination System Permit to Martin Marietta Materials, Inc., holding that there was no error in the proceedings below.The permit at issue allowed Martin Marietta to discharge twelve million gallons of mining wastewater per day from Vanceboro Quarry into Blounts Creek tributaries. The ALJ affirmed the issuance of the permit. The superior court reversed, concluding that the Division failed to ensure "reasonable compliance with the biological integrity standard." The court of appeals reversed, concluding that the permit was properly and validly issued in accordance with the applicable regulations. The Supreme Court affirmed, holding that the ALJ properly made findings of fact and properly applied those facts to a correct interpretation of the regulatory plain language. View "Sound Rivers, Inc. v. N.C. Dep't of Environmental Quality" on Justia Law
State v. Abbitt
The Supreme Court affirmed a portion of the decision of the court of appeals upholding the trial court's ruling that Defendants' proffered evidence that speculatively imputed blame for the charged offenses to other potential suspects could not be presented to the jury, holding that there was no error.Defendants were charged with first-degree murder, attempted robbery with a dangerous weapon, and assault with a deadly weapon. At issue was the refusal of the trial court to allow Defendants to introduce evidence that Defendants asserted would show that two other individuals, not themselves, had committed the crimes. The court of appeals affirmed. The Supreme Court affirmed, holding (1) while the proffered evidence was relevant to the issues presented for the jury's resolution, the potential evidence for the jury's consideration was not admissible; and (2) the court of appeals correctly applied the pertinent legal principles in concluding that the exclusion of Defendants' proffered evidence did not constitute prejudicial or reversible error. View "State v. Abbitt" on Justia Law
Posted in:
Criminal Law
State v. McKoy
The Supreme Court affirmed the decision of the court of appeals upholding Defendant's voluntary manslaughter conviction after determining that if the trail court erred in refusing to admit certain cell phone evidence the error was not sufficiently prejudicial to warrant a new trial, holding that the trial court's decision did not constitute an abuse of discretion.On appeal, Defendant argued that the trial court committed reversible error by refusing to allow the jury to consider photographs and text messages found on the victim's cellular phone. The court of appeals affirmed, concluding that Defendant received a fair trial free of prejudicial error. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in admitting the evidence and that admitting the disputed evidence almost certainly would not have changed the outcome of Defendant's trial. View "State v. McKoy" on Justia Law
Posted in:
Criminal Law
Value Health Solutions, Inc. v. Pharmaceutical Research Associates, Inc.
In this appeal from the orders and opinions entered in December 2019, February 2020, May 2020, and April 2021 by the superior court after the case was designated a mandatory complex business case, the Supreme Court affirmed in part and reversed in part, holding that remand was required as to some issues.Plaintiffs and Defendants entered into an asset purchase agreement under which three software applications for use in the clinical trial process would be sold to Defendants by Plaintiffs in exchange for stock and $2.5 million. After the deal soured Plaintiffs brought this lawsuit asserting claims for, among other things, breach of contract and negligent misrepresentation. The trial court granted Defendants' motions to dismiss as to some claims and then granted summary judgment for Defendants on all remaining claims. The Supreme Court affirmed the trial court as to all issues except for the order granting summary judgment on the issues of breach of portions of the asset purchase agreement, holding that further discovery was required. View "Value Health Solutions, Inc. v. Pharmaceutical Research Associates, Inc." on Justia Law
Posted in:
Business Law, Contracts
State v. Hicks
The Supreme Court reversed the decision of the court of appeals reversing Defendant's second-degree murder conviction, holding that the evidence was sufficient to support a jury finding that Defendant was the aggressor when she shot and killed the victim, and therefore, the trial court did not err in giving an instruction on the aggressor doctrine.At issue was the proper application of North Carolina's castle doctrine statute. See N.C. Gen. Stat. 14-51.2(b). Defendant and the victim in this case had a tumultuous relationship, and on the day of the murder Defendant had warned the victim not to come to her residence. The victim came anyway and was shot and killed. Defendant was convicted of second-degree murder. The court of appeals remanded the case for a new trial, holding that the trial court improperly instructed the jury on the aggressor doctrine. The Supreme Court reversed, holding that the trial court properly instructed the jury that if it found that Defendant was the aggressor, the presumption in section 14-51.2 was no longer available for her. View "State v. Hicks" on Justia Law
State v. Richardson
The Supreme Court affirmed the jury verdict that Defendant was guilty of the first-degree murder of a young child as well as of first-degree kidnapping, sexual offense with a child and felony child abuse inflicting serious injury, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to disqualify the trial judge; (2) the trial court erroneously admitted at trial a full-body photograph of the victim during certain testimony, but the error was not prejudicial; (3) the trial court may have improperly allowed certain witnesses to testify about their emotional reactions to seeing the victim's injuries, but the evidence was not prejudicial; (4) the trial court erred in denying Defendant's second motion to suppress a statement he made to law enforcement officers at a hospital, but there was no prejudice; (5) there was no cumulative prejudice; (6) there was no error in the trial court's rulings related to Defendant's attempt to establish a prima facie case of racial or gender-based discrimination; (7) North Carolina's death sentence system is constitutional; and (8) Defendant received a fair trial and capital sentencing proceeding. View "State v. Richardson" on Justia Law
State v. Newborn
The Supreme Court reversed the decision of the court of appeals vacating Defendant's conviction for possession of a firearm by a felon because the State failed to obtain a separate indictment for that offense under N.C. Gen. Stat. 14-415.1(c), holding that a violation of the mandatory separate indictment provision is not fatally defective.The State brought an indictment charging Defendant with possession of a firearm and two related offenses. The State did not obtain a separate indictment for Defendant's offense of possession of a firearm by a felon. The trial court convicted Defendant of possession of a firearm by a felon, possession of a firearm with an altered or removed seal number, and carrying a concealed weapon. The court of appeals reversed in part because the State failed to obtain a separate indictment for Defendant's conviction for possession of a firearm by a felon. The Supreme Court reversed, holding that the court of appeals erroneously applied its precedent in State v. Wilkins, 737 S.E.2d 791 (N.C. App. 2013), and that Wilkins is hereby specifically overruled. View "State v. Newborn" on Justia Law
Posted in:
Criminal Law