Justia North Carolina Supreme Court Opinion Summaries

Plaintiff, a resident of Georgia, entered into an employment contract with Employer. Plaintiff was in South Carolina when he signed the offer letter. Plaintiff later transferred to Employer's Charlotte, North Carolina division, but Plaintiff never had a route that involved any deliveries in North Carolina during his employment with Employer. After Plaintiff received a work-related injury, Plaintiff began receiving disability and medical compensation according to Georgia law. Plaintiff later filed a claim for benefits with the North Carolina Industrial Commission. The Commission concluded that it did not have subject matter jurisdiction over Plaintiff’s claim. The Court of Appeals reversed, concluding that Plaintiff’s transfer to Employer’s Charlotte division involved a modification of Plaintiff’s employment contract, and that the modification was a proper basis to find the contract was “made” within North Carolina for purposes of establishing the Commission’s jurisdiction. The Supreme Court reversed, holding that N.C. Gen. Stat. 97-36, which authorizes compensation pursuant to North Carolina law if an individual’s employment contract was “made” in North Carolina, does not apply to a contract initially made in another state and subsequently modified in North Carolina. View "Burley v. U.S. Foods, Inc." on Justia Law

After a jury trial, Defendant was convicted of felonious larceny, misdemeanor injury to personal property, first degree trespass, and misdemeanor possession of stolen property. The convictions stemmed from an incident in which police officers stopped Defendant’s vehicle while he was driving on the campus of the North Carolina State University (NCSU) and discovered copper wire taken from an electrical substation on campus. Defendant appealed, arguing that the trial court lacked subject matter jurisdiction over the injury to personal property charge because the information filed failed to allege that NCSU and “NCSU High Voltage Distribution” were legal entities capable of owning property. The Court of Appeals vacated Defendant’s conviction for the injury to personal property charge, concluding that the trial court lacked jurisdiction over the charge because the information failed to allege that NCSU High Voltage Distribution was capable of owning property. The Supreme Court reversed, holding that where a criminal pleading alleges that injury to personal property was committed against multiple entities, at least one of which is capable of owning property, that pleading is not facially invalid. View "State v. Ellis" on Justia Law

An investigation that began with an anonymous complaint to police led to a search of Defendant’s home. The police applied for and received a warrant to search the apartment. When the warrant was executed, the officers discovered controlled substances, drug paraphernalia, and a firearm and ammunition. Defendant was arrested and indicted for drug trafficking, drug possession, and firearm charges. Defendant moved to suppress the evidence seized from his residence, arguing that the warrant was not supported by probable cause. The trial court denied the motion, and Defendant later pleaded guilty to several charges. The court of appeals reversed, holding that the search warrant was unsupported by probable cause. The Supreme Court reversed, holding that, under the the totality of circumstances, the evidence described in the affidavit was sufficient to support the magistrate’s finding of probable cause to search Defendant’s apartment. View "State v. McKinney" on Justia Law

Plaintiffs, two private corporations, sought a copy of the Automated Criminal/Infraction System database via the state’s Public Records Act (Act). The North Carolina Administrative Office of the Courts (AOC) declined to produce an index of the ACIS database and declined to provide a copy of the ACIS. Plaintiffs filed suit seeking an order requiring production of the requested materials and seeking a declaration that the ACIS database is a public document or public information as defined in the Act. The trial court granted judgment for Defendants on their responsive pleadings and dismissed the case. The court of appeals reversed as to the AOC, concluding that ACIS is a public record subject to disclosure under the Act and that the AOC was the custodian of the ACIS. The Supreme Court reversed, holding (1) N.C. Gen. Stat. 7A-109(d), addressing “remote electronic access” to court records, is a more specific statute that overrides applicability of the Act in this case; and (2) the legislature intended that remote electronic access to the ACIS be available solely through nonexclusive contracts, as provided in section 7A-109(d). Remanded. View "LexisNexis Risk Data Mgmt., Inc. v. N.C. Admin. Office of Courts" on Justia Law

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