Justia Constitutional Law Opinion Summaries

Articles Posted in North Carolina Supreme Court

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The Supreme Court vacated the order of the trial court imposing lifetime satellite-based monitoring (SBM) upon Defendant without prejudice to the State's ability to file another application for SBM, holding that the trial court committed error relating to a substantial right. The trial court ordered him to enroll in SBM for life upon his release from prison. On appeal, Defendant argued that the trial court erred in imposing lifetime SBM because it failed to determine whether the monitoring effectuated a reasonable search under the Fourth Amendment. In response, the State asserted that Defendant waived the ability to challenge this constitutional issue on appeal by failing to preserve it below. The court of appeals concluded that Defendant had properly preserved the Fourth Amendment issue and, alternatively, that Appellate Rule 2 allowed it to review the issue. The Supreme Court reversed in part and affirmed in part, holding (1) Defendant waived his ability to raise the issue of the imposition of SBM on constitutional grounds; (2) the court of appeals properly invoked Rule 2 to review the unpreserved issue; and (3) where the State conceded that the trial court committed error relating to a substantial right, the court of appeals did not abuse its discretion by invoking Rule 2. View "State v. Bursell" on Justia Law

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The Supreme Court modified and affirmed the decision of the Court of Appeals concluding that Defendant’s inculpatory statements to law enforcement should have been suppressed but that the error was harmless, holding that the trial court correctly concluded that, under the totality of the circumstances, Defendant’s inculpatory statements were voluntary. On appeal, the Court of Appeals determined that Defendant’s inculpatory statements were involuntary and inadmissible because they were given under the influence of fear or hope caused by the interrogating officers’ statements and actions but that the admission of the statements was harmless beyond a reasonable doubt due to the overwhelming additional evidence of Defendant’s guilt. The Supreme Court modified and affirmed, holding (1) the trial court erred in merging the Miranda and voluntariness inquiries; (2) Defendant did not preserve his argument that officers employed the “question first, warn later” technique to obtain Defendant’s confession; and (3) the trial court correctly concluded that the Miranda requirements were met and that Defendant’s statements to the officers were voluntarily made. View "State v. Johnson" on Justia Law

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The Supreme Court reversed the decision of the Court of Appeals reversing and vacating Defendant’s conviction of being a felon in possession of a firearm and reversing the trial court’s denial of Defendant’s motion to suppress evidence of the firearm, holding that both the search and seizure of Defendant in this case were supported by individualized suspicion and thus did not violate the Fourth Amendment. On appeal, the Court of Appeals held that the search was invalid because it was not supported by reasonable suspicion. The Supreme Court reversed, holding (1) the rule announced in Michigan v. Summers, 452 U.S. 692 (1981), justified the seizure because Defendant posed a real threat to the safe and efficient completion of the search; and (2) the warrantless detention and search of Defendant did not violate the Fourth Amendment. View "State v. Wilson" on Justia Law

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The Supreme Court affirmed the decision of the Court of Appeals affirming the decision of the superior court determining that the appointments process in N.C. Gen. Stat. 143B-9(a) does not violate the Constitution, holding that senatorial confirmation of the members of the Governor of North Carolina’s Cabinet does not violate the separation of powers clause when, as in this case, the Governor retains the power to nominate the members, has strong supervisory authority over them, and has the power to removal them at will. Plaintiff, the Governor of North Carolina, brought this action challenging the appointments provision of subsection 143B-9(a), which grants the North Carolina Senate the power to confirm the people that he nominates to serve in his Cabinet. The Supreme Court held that subsection 143B-9(a)’s senatorial confirmation requirement does not violate the separation of powers clause because it leaves the Governor with enough control to take care that the laws be faithfully executed. View "Cooper v. Berger" on Justia Law

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The Supreme Court affirmed the decision of the Court of Appeals affirming the superior court’s order dismissing this complaint under N.C. R. Civ. P. 12(b)(6), holding that the State, and not a board of county commissioners, is solely responsible for preserving the right of every child in North Carolina to receive a sound basic education pursuant to the North Carolina Constitution. Plaintiffs alleged that Defendant’s continued support and maintenance of a tripartite school district system and its refusal to manage and distribute resources efficiently among the school districts resulted in Defendant’s failure to provide the students of Halifax County an opportunity to receive a sound basic education. The trial court dismissed the complaint for failure to state a claim, concluding that a board of county commissioners is absolved of any constitutional duty to provide its students the opportunity to receive a sound basic education. The Court of Appeals affirmed. The Supreme Court affirmed, holding that, along with the State, a board of county commissioners is not required to provide the opportunity for North Carolina children to receive a sound basic education. View "Silver v. Halifax County Board of Commissioners" on Justia Law

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The Supreme Court modified and affirmed the decision of the court of appeals finding no error in Defendant’s convictions and sentences. The Court of Appeals held that Defendant waived her sentencing arguments because Defendant failed to voice any objection to her sentence or the sentencing proceedings in the trial court. The Supreme Court affirmed as modified, holding (1) Defendant waived her Eighth Amendment arguments by failing to raise them before the sentencing court; (2) Defendant’s nonconstitutional sentencing issues were preserved for appellate review by statute despite her failure to lodge a contemporaneous objection but were nonetheless meritless; and (3) discretionary review was improvidently granted as to Defendant’s ineffective assistance claim. View "State v. Meadows" on Justia Law

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The Supreme Court held that the court of appeals erred in reversing the trial court’s denial of Defendant’s motion to suppress, holding that the suppression motion contained sufficient findings of fact to support the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights pursuant to N.C. Gen. Stat. 7B-2101 before making certain incriminating statements. The court of appeals determined that the totality of the circumstances set forth in the record did not fully support the trial court’s conclusion that Defendant knowingly, willingly, and understandingly waived his juvenile rights. The Supreme Court reversed, holding (1) the trial court’s findings of fact had adequate evidentiary support, and those findings supported the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights; and (2) in reaching a contrary conclusion, the court of appeals failed to focus upon the sufficiency of the evidence to support the trial court’s findings of fact and to give proper deference to those findings. View "State v. Saldierna" on Justia Law

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The Supreme Court held in this criminal case that while the claim asserted in Defendant’s motion for appropriate relief was not subject to the procedural bar established by N.C. Gen. Stat. 15A-1419(a)(3), the trial court did not err by denying Defendant’s motion for the reasons stated by the court of appeals. The jury returned a verdict convicting Defendant of first-degree murder, and the trial court sentenced Defendant to a term of life imprisonment without parole. Defendant later filed a motion for appropriate relief asserting, among other things, that his constitutional right to effective, conflict-free trial counsel had been violated. The trial court denied Defendant’s motion after conducting an evidentiary hearing. The Supreme Court concluded that Defendant’s ineffective assistance of counsel claim was not procedurally barred and overturned the trial court’s order denying Defendant’s motion for appropriate relief. The Supreme Court affirmed in part and reversed in part, holding (1) Defendant was not subject to the procedural bar created by N.C. Gen. Stat. 15A-1419(a)(3) with respect to his ineffective assistance of counsel claim; but (2) the trial court properly denied Defendant’s motion for appropriate relief. View "State v. Hyman" on Justia Law

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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

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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