Justia Constitutional Law Opinion Summaries

Articles Posted in North Carolina Supreme Court
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In this business case, the Supreme Court reversed the orders of the business court denying Plaintiffs' motion for default judgment based on its finding that Plaintiffs had failed to satisfy their burden of proving that the court possessed personal jurisdiction over Defendant, a nonresident company, holding that Defendant's contacts with North Carolina were sufficient to permit the exercise of personal jurisdiction over it in North Carolina state courts. In the complaint, Plaintiffs sought an injunction, in part, directing Defendant to turn over certain documents and information necessary for Plaintiffs to wind up the affairs of a limited-liability limited partnership. A default was entered against Defendant, but the business court denied Plaintiffs' motion for default judgment. The Supreme Court reversed, holding that Defendant had sufficient minimum contacts with this state such that a North Carolina court could constitutionally exercise personal jurisdiction over it. View "Beem USA Limited-Liability Limited Partnership v. Grax Consulting LLC" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals concluding that the trial court failed to satisfy the requirements of N.C. Gen. Stat. 15A-1242 before allowing Defendant to proceed pro se, holding that the court of appeals correctly concluded that Defendant did not forfeit his right to counsel and that the trial court was therefore required to ensure that his waiver of counsel was knowing, intelligent, and voluntary. Defendant was charged with offenses related to his failure to maintain a valid driver's license. Defendant was first tried in the district court, where he was convicted. Defendant appealed to the superior court, where he was tried without counsel and convicted by a jury. On appeal, a majority of the court of appeals determined that Defendant did not engage in such serious misconduct as to warrant forfeiture of the right to counsel. The Supreme Court affirmed, holding that Defendant was entitled to a new trial because the trial court violated his right to counsel under the federal and state Constitutions. View "State v. Simpkins" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the superior court's judgment following Defendant's plea of guilty to trafficking in cocaine, holding that the court of appeals correctly determined that the trial court erred in denying Defendant's motion to suppress evidence discovered pursuant to an unlawful traffic stop. In his appeal, Defendant argued that his initial investigatory detention was not properly tailored to address a speeding violation and contended that the officer seized him without consent or reasonable suspicion of criminal activity. Therefore, Defendant argued, the officer unlawfully seized items from the vehicle during the ensuing search of the car and that those objects were the fruit of the poisonous tree. The court of appeals reversed the denial of the motion to suppress, concluding that the officer lacked reasonable suspicion to search the vehicle after the traffic stop had been completed. The Supreme Court affirmed, holding that the evidence was obtained as a result of the officer's unlawful detainment of Defendant without reasonable suspicion of criminal activity after the lawful duration of the traffic stop had concluded. View "State v. Reed" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing Defendant's conviction of first-degree murder, holding that the court of appeals properly found that the identification procedures at issue in this case were impermissibly suggestive, but the identification procedures ultimately did not violate Defendant's statutory or due process rights. After a trial, Defendant was convicted of first-degree murder and assault with a deadly weapon with intent to kill inflicting serious injury. On appeal, Defendant argued that the trial court erred in denying his motions to suppress the testimony of two eyewitnesses, including their in-court identifications of Defendant as the perpetrator of the crimes. The court of appeals remanded the case for a new trial, concluding that the eyewitness testimony was the result of impermissibly suggestive identification procedures and that the testimony was prejudicial. The Supreme Court reversed in part, holding that the court of appeals properly found that the eyewitnesses were subjected to witness identification procedures that were impermissibly suggestive but erred in failing to rule that the identification was sufficiently of independent origin to negate a substantial likelihood of a misidentification. View "State v. Malone" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming in part and reversing in part the trial court's denial of Defendant's motion to suppress, holding that the omission of pertinent facts in an officer's search warrant application resulted in a lack of probable cause for the issuance of the search warrant for either Defendant's residence or vehicle. The officer in this case possessed information that would suffice to establish probable cause for the issuance of a search warrant but failed to include key portions of this information in his affidavit supporting the warrant. The trial court denied Defendant's motion to suppress, concluding that the affidavit sufficiently established probable cause to support the magistrate's issuance of a warrant authorizing a search of Defendant's residence and vehicle. The court of appeals reversed in part, holding that the affidavit was sufficient to establish probable cause to search the vehicle but was insufficient to establish probable cause to search the residence. The Supreme Court reversed in part, holding that the motion to suppress should have been allowed as to evidence seized from both Defendant's residence and vehicle. View "State v. Lewis" on Justia Law

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The Supreme Court modified and affirmed the opinion of the court of appeals reversing, but only as to Defendant individually, the superior court's determination that North Carolina's satellite-based monitoring (SBM) of sex offenders is constitutional, holding that the court of appeals erred by limiting its holding to the constitutionality of the SBM program as applied only to Defendant. Defendant was statutorily required to enroll in the SBM program and to wear an ankle monitor at all times for his lifetime based on his convictions for sex crimes. Defendant argued that the imposition of the monitoring violated his constitutional rights to be free from unreasonable search and seizure. The trial court found that the SBM program was not unconstitutional. The United States Supreme Court held that a State conducts a search when it attaches a device to a person's body, without consent, for the purpose of tracking that individual's movements. On remand, the superior court upheld the imposition of lifetime SBM on Defendant. The court of appeals reversed, concluding that lifetime SBM of Defendant was unreasonable. The Supreme Court modified and affirmed, holding that the program is unconstitutional as applied to all individuals who, like Defendant, are subject to mandatory lifetime SBM based solely on their status as a "recidivist." View "State v. Grady" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court convicting Defendant of first-degree murder and other offenses and sentencing him to life imprisonment without parole, holding that the trial court violated Defendant's Sixth Amendment right to confront witnesses against him by limiting Defendant's cross-examination of the State's principal witness, and the error was not harmless beyond a reasonable doubt. At Defendant's murder trial, Lakenda Malachi was the only witness to provide direct evidence of Defendant's presence at the scene. Defendant sought to impeach Malachi's testimony, but the trial court sustained objections to defense counsel's questions. After Defendant was convicted he appealed. The court of appeals concluded that the trial court committed constitutional error by restricting Defendant's cross-examination of Malachi and that the error was not harmless beyond a reasonable doubt. The Supreme Court affirmed, holding that the court of appeals correctly found that the trial court committed prejudicial error. View "State v. Bowman" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals concluding that a law enforcement officer's warrantless search of Defendant's USB drive was not permissible under the "private-search doctrine," holding that the State failed to carry its burden of presenting competent evidence establishing that the officer's warrantless search was permissible under the private-search doctrine. The officer conducted a warrantless search of Defendant's USB drive following a prior search of the USB drive by a private individual. The trial court denied Defendant's motion to suppress. The court of appeals reversed the trial court's denial of Defendant's motion to suppress, concluding that the warrantless search was not authorized under the private-search doctrine but that remand was appropriate to determine whether probable cause existed to issue the search warrant without the evidence obtained from the unlawful search. The Supreme Court affirmed, holding that the private-search doctrine cannot apply to a thumb drive because, even though some of the thumb drive has been previously opened, an officer cannot proceed with "virtual certainty" that nothing else of significance is in the device. View "State v. Terrell" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgments of the trial courts allowing Defendant's motion to suppress, holding that the trial courts' findings of fact failed to support their legal conclusion that the investigating officer lacked the probable cause needed to place Defendant under arrest for impaired driving. Defendant was charged with driving while subject to an impairing substance. In granting the motion to suppress, the trial courts concluded that the investigating officer lacked probable cause to place Defendant under arrest for driving while impaired. The court of appeals reversed, concluding that the facts supported a conclusion that the officer had probable cause to stop and cite Defendant for driving while impaired. The Supreme Court affirmed, holding that the undisputed facts supported the officer's decision to place Defendant under arrest for impaired driving. View "State v. Parisi" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals holding that Defendant's right to be free from double jeopardy was violated when the State voluntarily dismissed Defendant's charge after his first trial ended in a hung jury mistrial and when Defendant was retried six years later when new evidence emerged, holding that Defendant's second prosecution was barred by the Double Jeopardy Clause and that the trial court erred in denying Defendant's motion to dismiss his indictment on double jeopardy grounds. Specifically, the Court held (1) jeopardy attaches when the jury is empaneled and continues following a mistrial until a terminating event occurs; (2) when the State enters a voluntary dismissal after jeopardy has attached, jeopardy is terminated in the defendant's favor, and the State cannot retry the case without violating a defendant's right to be free from double jeopardy; and (3) because Defendant's jeopardy remained attached following the mistrial declaration in his first trial and was terminated when the State subsequently entered a dismissal of the charge under N.C. Gen. Stat. 15A-931, Defendant's second prosecution was barred by the Double Jeopardy Clause. View "State v. Courtney" on Justia Law