Justia Constitutional Law Opinion Summaries

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

The North Carolina Department of Revenue (Defendant) unconstitutionally taxed the income of The Kimberly Rice Kaestner 1992 Family Trust (Plaintiff) pursuant to N.C. Gen. Stat. 105-160.2 based solely on the North Carolina residence of the beneficiaries during certain tax years because Plaintiff did not have sufficient minimum contacts with the State of North Carolina to satisfy the due process requirements of the state and federal Constitutions.Plaintiff filed a complaint alleging that Defendant wrongfully denied Plaintiff’s request for a refund because the taxes collected pursuant to section 105-160.2 violate the due process clause. The North Carolina Business Court concluded that the provision of section 105-160.2 allowing taxation of a trust income “that is for the benefit of a resident of this State” violated both the Due Process Clause and N.C. Const. art. I, 19, as applied to Plaintiff. The court therefore granted Plaintiff’s motion for summary judgment. The court of appeals affirmed. The Supreme Court affirmed, holding (1) section 105-160.2 is unconstitutional as applied to collect income taxes from Plaintiff for the tax years at issue; and (2) therefore, summary judgment was properly granted for Plaintiff. View "Kaestner 1992 Family Trust v. North Carolina Department of Revenue" on Justia Law

A police officer’s decision to briefly detain Defendant for questioning was supported by a reasonable suspicion of criminal activity.Defendant was indicted for robbery with a dangerous weapon. Defendant moved to suppress evidence obtained as a result of his seizure by the police officer, asserting that he had been unlawfully detained, in violation of his constitutional rights. The trial court denied the motion to suppress, and Defendant was subsequently convicted of common law robbery. The court of appeals ordered a new trial, concluding that the trial court committed prejudicial error by denying Defendant’s suppression motion and that the police officer lacked reasonable suspicion to detain Defendant for questioning. The Supreme Court reversed, holding that the undisputed facts established reasonable suspicion necessary to justify Defendant’s seizure. View "State v. Nicholson" on Justia Law

The Supreme Court reversed the decision of the court of appeals in vacating the judgments entered by the trial court based upon Defendant’s convictions for first-degree murder and attempted first-degree murder on the grounds that certain evidence had been admitted in violation of the Confrontation Clause.The court of appeals concluded that the statements at issue were admitted in violation of Defendant’s constitutional right to confront the State’s witnesses against him. The Supreme Court reversed, holding that the trial court did not err by overruling Defendant’s confrontation-based objection and allowing the admission of the challenged evidence. View "State v. Miller" on Justia Law

Defendant’s Fourth Amendment claims were not reviewable on direct appeal, even for plain error, because Defendant completely waived them.A police officer found cocaine in Defendant’s coat pocket during a traffic stop. Defendant did not move in liming to suppress evidence of the cocaine, nor did Defendant object to the State’s use of the cocaine evidence at any point during his trial. On appeal, Defendant argued that the trial court plainly erred by admitting evidence of the cocaine and that the seizure of the cocaine violated his rights under the Fourth Amendment. The court of appeals ordered a new trial, concluding that the trial court committed plain error by admitting evidence of the cocaine. The Supreme Court reversed, holding that Defendant waived his Fourth Amendment claims by not moving to suppress evidence of the cocaine before or after trial. The Court remanded the case for consideration of Defendant’s ineffective assistance of counsel claim because the court of appeals did not reach this claim. View "State v. Miller" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree murder, sexual offense of a child by a adult offender, and other crimes and his sentence of death, holding that there was no error in Defendant’s trial or sentencing and that Defendant’s death sentence was not disproportionate to his crimes.Among other things, the Supreme Court held (1) Defendant failed to meet his burden under Strickland v. Washington, 466 U.S. 668 (1984), of establishing that he received ineffective assistance of counsel; (2) Defendant failed to identify any error in the trial court’s evidentiary rulings; (3) the trial judge did not abuse his discretion in denying Defendant’s motions for a mistrial based upon an improper remark by the prosecutor during closing arguments; (4) there was no error in the jury instructions; (5) Defendant received a capital sentencing proceeding free of prejudicial error; and (6) the death sentence was not excessive or disproportionate. View "State v. McNeill" on Justia Law

At issue was the validity of the procedures prescribed in N.C. Gen. Stat. 15A-1340.19A - 15A-1340.19(D) (the Act) for the sentencing of juveniles convicted of first-degree murder in light of Miller v. Alabama, 467 U.S. 460 (2012) and its progeny.Defendant was convicted of first-degree murder and other crimes he committed when he was sixteen years old. Defendant was sentenced to life imprisonment without the possibility of parole for the murder conviction, a sentence that was then mandatory. After Miller was decided, the trial court resentenced Defendant to life imprisonment without parole. On appeal, Defendant challenged the constitutionality of the Act. The Court of Appeals upheld the constitutionality of the Act but reversed the resentencing judgment, concluding that the trial court failed to make adequate findings of fact to support its decision to impose the sentence. The Supreme Court modified and affirmed, holding (1) the Act does not incorporate a presumption in favor of a sentence of life without parole upon juveniles convicted of first-degree murder on the basis of a theory other than the felony murder rule; (2) the Act is not impermissibly vague, conducive to the imposition of arbitrary punishments, or an unconstitutional ex post facto law; and (3) further sentencing proceedings are required in this case. View "State v. James" on Justia Law

At issue was when the claims that Plaintiffs asserted against Defendant, the Town of Carthage, accrued and whether Plaintiffs’ claims were barred by a one-year, two-year, three-year, or ten-year statute of limitations and the doctrine of estoppel by the acceptance of benefits. The Supreme Court held (1) Plaintiffs’ cause of action accrued upon the Town’s exaction of the unlawful impact fees against Plaintiffs; (2) Plaintiffs’ claims against the Town arose from a liability created by statute that was subject to the three-year statute of limitations set out in N.C. Gen. Stat. 1-52(2); and (3) Plaintiffs’ claims against the Town were not barred by the doctrine of estoppel by the acceptance of benefits. View "Quality Built Homes Inc. v. Town of Carthage" on Justia Law

In this case seeking just compensation for the taking of property in Greensboro, the trial court erred in excluding testimony from a licensed real estate broker as an expert witness who would testify about the fair market value of the property before and after the taking.After a trial, the jury returned a verdict setting just compensation for the taking by the North Carolina Department of Transportation (DOT) of 2.193 acres of land in Greensboro at $350,000. Defendants appealed, arguing that their proposed expert’s report and his testimony on fair market value should have been admitted as evidence. The court of appeals affirmed. The Supreme Court reversed, holding that a new trial was warranted because N.C. Gen. Stat. 93A-83(f) did not prohibit the proposed expert from preparing his expert report on fair market value, and the trial court’s erroneous exclusion of the testimony about fair market value on that basis prejudiced Defendants. View "North Carolina Department of Transportation v. Mission Battleground Park, DST" on Justia Law

Plaintiff, a police officer, adequately stated a claim that his rights under Article I, Section 1 of the North Carolina Constitution were violated when his employer, the City of Wilmington, refused to consider Plaintiff’s appeal regarding the validity of an examination required for a promotion.Upon seeking promotion, Plaintiff took a written examination, a required step in the promotional process, but did not receive a passing score. Plaintiff filed a grievance regarding the test answers, but the City Manager informed him that the test answers were not a grievance item. Plaintiff filed a complaint, arguing that the City arbitrarily and irrationally deprived him of enjoyment of the fruits of his own labor, in violation of the Constitution. The trial court granted the City’s motion for judgment on the pleadings, in which the City argued that Plaintiff did not have a property interest that could support his claims. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court erred in dismissing Plaintiff’s claim arising under Article I, Section 1 of the North Carolina Constitution; but (2) Plaintiff did not state a valid claim under Article I, Section 19. View "Tully v. City of Wilmington" on Justia Law