Justia Constitutional Law Opinion Summaries

Andre Lester was charged and convicted of multiple sex offenses with a minor. At trial, the State presented Verizon phone records to link Lester to the crimes. Exhibit #2 showed the time, date, and connecting number for every call made to or from the phone allegedly belonging to Lester. Exhibit #3 featured a subset of that data, showing communications between Lester’s phone and the victim’s phone. Lester argued that the admission of these exhibits violated the Confrontation Clause and hearsay rules because he could not cross-examine the source of the data.The Superior Court of Wake County admitted the exhibits under Rule 803(24), the catch-all hearsay exception, despite acknowledging that they did not meet the business records exception under Rule 803(6). The jury convicted Lester on all counts, and he appealed. The Court of Appeals reversed the convictions, holding that the admission of the exhibits violated the Confrontation Clause and hearsay rules, and ordered a new trial.The Supreme Court of North Carolina reviewed the case and found that the Court of Appeals misapplied the Confrontation Clause analysis. The Supreme Court held that machine-generated raw data, if truly machine-generated, are neither hearsay nor testimonial under the Confrontation Clause. The Court emphasized that the primary purpose test should focus on why the data were created, not why they were later retrieved. The Court concluded that if Verizon’s systems recorded the data as part of routine operations, the data were not created for use in a trial. The Supreme Court reversed the decision of the Court of Appeals and remanded the case for consideration of Lester’s remaining issues. View "State v. Lester" on Justia Law

In 2011, plaintiffs sued the Roman Catholic Diocese of Charlotte, alleging sexual abuse by priests in the 1970s and 1980s. The trial court granted summary judgment for the Diocese, finding the claims time-barred by the statute of limitations. One plaintiff appealed and lost, while the other did not appeal. Both judgments became final a decade ago.In 2019, the General Assembly passed the SAFE Child Act, which revived previously time-barred claims for child sexual abuse. In 2020, plaintiffs filed new lawsuits asserting the same claims dismissed in the earlier judgments, arguing that the SAFE Child Act allowed them to do so. The trial court dismissed these new lawsuits with prejudice, citing the res judicata effect of the earlier judgments. The Court of Appeals affirmed, holding that the new lawsuits were barred by res judicata because final judgments had already been entered on the same claims.The Supreme Court of North Carolina reviewed the case and affirmed the Court of Appeals' decisions. The court held that the General Assembly does not have the power to set aside a final judgment of the judicial branch. The court emphasized that under the North Carolina Constitution, the judicial power belongs exclusively to the judicial branch, and the legislature cannot annul a judgment or decree of a court. The court concluded that the SAFE Child Act, like any other legislative act, cannot overturn a final judgment entered by the judicial branch. View "Doe v. Roman Cath. Diocese" on Justia Law

In August 1998, a 17-year-old defendant, a member of the Crips gang, participated in the abduction, robbery, and murder of three women, resulting in the death of two and the attempted murder of the third. The defendant was arrested and indicted on multiple charges, including two counts of first-degree murder. In 2000, a jury found him guilty, and he was sentenced to death. The North Carolina Supreme Court vacated the death sentence due to a jury polling error and remanded for resentencing. Following the U.S. Supreme Court's ruling in Roper v. Simmons, which prohibited the death penalty for juveniles, the defendant was resentenced to life without parole.The trial court later resentenced the defendant under a new statutory scheme following the U.S. Supreme Court's decision in Miller v. Alabama, which prohibited mandatory life without parole for juveniles. The trial court considered mitigating factors and sentenced the defendant to two consecutive life without parole terms, finding him irreparably corrupt. The defendant appealed, arguing that his sentences violated the Eighth Amendment and the North Carolina Constitution.The North Carolina Court of Appeals affirmed the sentences, finding that the trial court properly considered all mitigating factors and that the sentences complied with both federal and state constitutional requirements. The court rejected the defendant's argument that his sentences were unconstitutional per se and found that the evidence supported the trial court's conclusion of irreparable corruption.The North Carolina Supreme Court reviewed the case and affirmed the Court of Appeals' decision. The court held that the state constitution's prohibition on cruel or unusual punishments does not provide broader protections than the Eighth Amendment. The court also found that the trial court's resentencing did not violate the principles established in State v. Kelliher. View "State v. Tirado" on Justia Law

Patricia Burnette Chastain was appointed as the clerk of superior court in Franklin County in May 2013 and was subsequently elected to the position in November 2013 and reelected in 2017. In July 2020, an attorney named Jeffrey Thompson filed an affidavit requesting an inquiry into Ms. Chastain's conduct, alleging various instances of misconduct, including distributing gift certificates to jurors, allowing a judicial candidate to address a jury, and acting unprofessionally with correctional officers, among other allegations.Judge John M. Dunlow initially suspended Ms. Chastain and set a hearing date. However, due to a conflict of interest, Judge Dunlow and another judge were recused, and Judge Thomas H. Lock was appointed to preside over the removal inquiry. After an evidentiary hearing, Judge Lock issued an order in October 2020 permanently removing Ms. Chastain from her position based on findings of willful misconduct. Ms. Chastain appealed, and the Court of Appeals vacated the order, holding that Judge Lock lacked authority under Article IV of the North Carolina Constitution to remove her and remanded the case for reconsideration under Article VI.The Supreme Court of North Carolina reviewed the case and held that Judge Lock had the authority to preside over the removal proceeding as a replacement for the recused senior regular resident superior court judge. The court also held that procedural due process requires that removal be based only on conduct identified in the initiating affidavit. Furthermore, the court clarified that the standard for removal under Article IV is "misconduct," not "willful misconduct." The Supreme Court vacated the Court of Appeals' decision and remanded the case for reconsideration of removal under the proper standards. The court also noted that discretionary review was improvidently allowed regarding the procedure for disqualification under Article VI. View "In re Chastain" on Justia Law

The case involves the father of a four-year-old child, Katy, who was initially placed with him by the Durham County Department of Social Services (DSS) after her mother, who had custody, was found to have substance abuse issues. DSS later discovered the father had a significant criminal history and was arrested for assault. Consequently, DSS recommended placing Katy with her paternal aunt and uncle, which the trial court approved. The trial court also found that both parents acted inconsistently with their constitutional rights as parents, although neither parent raised a constitutional claim during the trial.The Court of Appeals reviewed the case and, in a divided opinion, reversed the trial court's decision. The majority held that the trial court lacked authority to place Katy with anyone other than her father, as there were no allegations or findings that he was unfit or had acted inconsistently with his constitutional rights. The majority also ruled that the constitutional issue was preserved for appellate review because the father opposed DSS's recommendation. The dissent argued that the trial court's findings on the constitutional standard were premature and unnecessary.The Supreme Court of North Carolina reviewed the case and focused on whether the constitutional issue was properly preserved for appellate review. The Court held that a parent must explicitly raise a constitutional claim in the trial court to preserve it for appeal. Since the father conceded he did not argue the issue as a constitutional violation in the trial court, the Supreme Court determined the issue was not preserved. Consequently, the Court reversed the decision of the Court of Appeals, emphasizing the need for parents to inform the trial court and opposing parties of any constitutional challenges to ensure proper evidence is presented. View "In re K.C." on Justia Law

Petitioner was sentenced to multiple consecutive terms of imprisonment in 2019 for obtaining property by false pretenses. In June 2020, he filed a petition for writ of habeas corpus, claiming his detention was unlawful due to the North Carolina Department of Public Safety's inability to protect him from COVID-19, which he argued violated the Eighth Amendment and the North Carolina Constitution. The trial court denied his petition.The Superior Court of Wake County summarily denied the petition, citing N.C.G.S. § 17-4(2), which mandates denial of habeas corpus applications when the petitioner is held under a valid final judgment by a competent court. The Court of Appeals affirmed the trial court's decision but held that N.C.G.S. § 17-33(2) provided an exception to the rule in § 17-4(2). Despite acknowledging the case was moot due to the petitioner's release, the Court of Appeals applied the public interest exception to the mootness doctrine and proceeded to the merits.The Supreme Court of North Carolina reviewed the case to determine if the Court of Appeals erred in its interpretation. The Supreme Court held that the plain language of N.C.G.S. § 17-4(2) requires summary denial of habeas corpus applications for those detained by a final judgment of a competent court. The Court found no conflict between §§ 17-4 and 17-33, as the latter applies only to those detained by civil process, not criminal judgments. The Supreme Court modified and affirmed the Court of Appeals' decision, emphasizing that habeas corpus relief is not available under the circumstances presented by the petitioner. View "State v. Daw" on Justia Law

In the early days of the COVID-19 pandemic, Governor Roy Cooper of North Carolina issued an executive order limiting attendance at outdoor venues to twenty-five people. Robert Turner, who operated Ace Speedway in Alamance County, publicly opposed these restrictions and kept the racetrack open. This led to a series of events where Governor Cooper allegedly pressured local officials to enforce the order against Ace Speedway, culminating in the North Carolina Department of Health and Human Services (DHHS) issuing an abatement order to shut down the racetrack as a health hazard.The Superior Court of Alamance County initially issued a preliminary injunction against Ace Speedway, prohibiting it from holding events until it complied with the abatement order. Ace Speedway and its operators counterclaimed, alleging constitutional violations, including the right to earn a living and selective enforcement. The trial court denied the State’s motion to dismiss these counterclaims, and the State appealed. The North Carolina Court of Appeals affirmed the trial court’s decision, allowing the case to proceed.The Supreme Court of North Carolina reviewed the case and affirmed the Court of Appeals' decision. The Court held that Ace Speedway sufficiently alleged colorable claims under the North Carolina Constitution. The allegations suggested that the State's actions were not for a proper governmental purpose but to retaliate against Turner for his public criticism, thus violating the right to earn a living. Additionally, the selective enforcement claim was deemed colorable because Ace Speedway alleged it was targeted while other similar venues were not, based on Turner’s exercise of his First Amendment rights. The Court concluded that these claims were sufficient to overcome the State’s sovereign immunity at this stage. View "Kinsley v. Ace Speedway Racing, Ltd" on Justia Law

In 2017, the City of Greenville, North Carolina, installed traffic cameras at its most dangerous intersections as part of its Red Light Camera Enforcement Program (RLCEP). The program was funded through a cost-sharing agreement with the Pitt County Board of Education (Board), which received 100% of the collected red light penalties and then reimbursed the City for the actual costs of maintaining the program. In 2018, plaintiffs Eric Fearrington and Craig Malmrose received citations for red light violations captured by RLCEP cameras and challenged their citations in court, arguing that the RLCEP violated Article IX, Section 7 of North Carolina’s Constitution, which promises public schools the “clear proceeds” of all penalties, forfeitures, and fines.The trial court ruled in favor of the Board and City, but the Court of Appeals reversed the dismissal of plaintiffs’ claim and remanded for entry of summary judgment in their favor. The Board and City then petitioned the Supreme Court of North Carolina for discretionary review.The Supreme Court of North Carolina affirmed the Court of Appeals decision on plaintiffs’ taxpayer standing but limited the available remedies to injunctive and declaratory relief, not a “refund.” On plaintiffs’ constitutional challenge, however, the court reversed the Court of Appeals. The court held that the Interlocal Agreement and the Local Act authorizing it did not countermand the constitutional provision’s text or purpose. The court did not discern a “plain and clear” constitutional violation, and thus reversed the award of summary judgment to plaintiffs on their constitutional claim, and remanded the case to the Court of Appeals for further remand to the trial court for entry of summary judgment in favor of Greenville and the Board. View "Fearrington v. City of Greenville" on Justia Law

During an investigation of a stolen car, law enforcement officers followed a suspect into a nearby home where they discovered an illegal drug operation. One of the participants in the operation, the defendant, did not live at the residence and denied any ownership or control over the premises or the objects within, including a safe containing illegal items. The homeowner, who was also the defendant's uncle, consented to the search of the home. After the defendant was convicted of several drug-related offenses, he appealed, arguing that the evidence should have been suppressed because the police entered the home without a warrant.The Supreme Court of North Carolina was tasked with deciding if the defendant had standing to challenge the warrantless entry into the home, given that he had declared he did not live there. The Court of Appeals had previously reversed the trial court's denial of the motion to suppress, stating that the trial record did not support any finding that the defendant lacked a reasonable expectation of privacy in the home.The Supreme Court of North Carolina reversed the decision of the Court of Appeals, holding that the evidence presented at the suppression hearing could support findings that the defendant lacked standing to challenge the search. The court, however, noted that the trial court failed to make these findings despite the presence of materially conflicting evidence in the trial record. The case was remanded to the trial court for findings of fact based on the trial record. Depending on those findings, the trial court could again deny the motion to suppress, or it may grant the motion to suppress in whole or in part and order a new trial. View "State v. Jordan" on Justia Law

In this case, the plaintiff, Frankie Delano Washington, was convicted of various serious felony offenses. During his trial, he asserted that his constitutional right to a speedy trial had been violated. His argument was initially rejected, but later won on appeal and his convictions were set aside. Subsequently, Washington and his son filed a suit against the State and various state and local officials, alleging that the State knowingly charged him for crimes he did not commit. Among the numerous claims brought forth, Washington argued for a common law claim against the State for damages caused by the deprivation of his state constitutional right to a speedy trial.However, the Supreme Court of North Carolina held that Washington had an adequate state law remedy and therefore, a separate Corum claim was not available. The court reasoned that the plaintiff had already received a meaningful remedy for the State's violation of his rights, as his criminal convictions had been permanently set aside. The court further clarified that an "adequate remedy" is one that meaningfully addresses the constitutional violation, even if the plaintiff might prefer a different form of relief. This decision upholds the foundational principle that a Corum claim is applicable when one's rights are violated, and the law offers either no remedy or a remedy that is meaningless. The court ultimately affirmed the decision of the Court of Appeals, which had upheld the trial court's entry of summary judgment. View "Washington v. Cline" on Justia Law