Justia Constitutional Law Opinion Summaries

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

In this case filed by Governor Roy A. Cooper III challenging the constitutionality of legislation creating a new Bipartisan State Board of Elections and Ethics Enforcement and appointing existing members of the State Ethics Commission to serve as the members of the Bipartisan State Board, the Supreme Court reversed a three-judge superior court panel’s ruling that the Governor’s claims constituted non-justiciable political questions and that the Governor lacked standing, as well as a supplemental order ruling that Session Law 2017-6 was not unconstitutional on its face. The Supreme Court held (1) the panel erred by dismissing the Governor’s complaint because the claims asserted did not raise a nonjusticiable political question, and the Governor had standing to assert the claims; and (2) the provisions of Session Law 2017-6 concerning the membership of and appointments to the Bipartisan State Board impermissibly interfere with the Governor’s ability to faithfully execute the laws in violation of N.C. Const. art. II, section 5(4). View "Cooper v. Berger" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing an order denying Defendant’s motion to suppress and vacating Defendant’s guilty plea.Defendant moved to suppress the evidence derived from a search of the car he was driving after he was pulled over for traffic violations, arguing that the search violated the Fourth Amendment. The trial court denied the motion to suppress. The court of appeals reversed, concluding that the traffic stop had been unlawfully prolonged under the standard that the United States Supreme Court set out in Rodriguez v. United States, 575 U.S. __ (2015). The Supreme Court reversed, holding that the stop was not unlawfully prolonged under the standard set forth in Rodriguez. View "State v. Bullock" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the Court of Appeals reversing the trial court’s order addressing the appropriate measure of damages in this condemnation action.The North Carolina Department of Transportation (DOT) condemned a leasehold interest held by Adams Outdoor Advertising of Charlotte Limited Partnership (Adams). Adams owned a billboard situated on the leasehold and rented out space on the billboard. At the time of the taking the billboard did not conform to city or state regulations, but Adams possessed permits that allowed for the billboard’s continued use. The Supreme Court held (1) the fair market value provision of N.C. Gen. Stat. Article 9 governed this condemnation proceeding; (2) the value added by the billboard, the evidence of rental income derived from leasing advertising space on the billboard, and the value added to the leasehold interest by the permits issued to Adams may be considered in determining the fair market value of the leasehold interest; (3) an automatic ten-year extension of a lease may be considered in determining the fair market value, but options to renew the lease may not be; and (4) bonus value method evidence offered by DOT may not be considered in determining the fair market value of the leasehold interest. View "Department of Transportation v. Adams Outdoor Advertising of Charlotte Limited Partnership" on Justia Law

Defendant was subjected to a custodial interrogation as defined in Miranda v. Arizona, 384 U.S. 436 (1966), when police questioned him while he was confined under a civil commitment order, and therefore, the failure of police to advise him of his Miranda rights rendered inadmissible the incriminating statements he made during the interrogation. The trial court concluded otherwise and denied Defendant’s motion to suppress. Defendant was subsequently convicted of robbery with a dangerous weapon. The Supreme Court reversed the trial court’s denial of Defendant’s motion to suppress and vacated his conviction, holding that the trial court’s order denying Defendant’s motion to suppress was an erroneous application of the law and that the error was prejudicial. View "State v. Hammonds" on Justia Law

In this criminal case, the prosecutor’s comments in his closing argument were improper but did not amount to prejudicial error in light of the evidence against Defendant, and therefore, the trial judge did not err by failing to intervene ex mero motu in the prosecutor’s closing arguments.The court of appeals vacated Defendant’s conviction and ordered a new trial, concluding that the prosecutor’s statements had the cumulative effect of resulting in unfair prejudice to Defendant, and therefore, the trial court erred by failing to intervene ex mero motu. The Supreme Court disagreed, holding (1) the prosecutor’s statements were improper; but (2) the statements were not so grossly improper as to prejudice Defendant’s due process rights. View "State v. Huey" on Justia Law

The record should be further developed in this case before a reviewing court can adequately address Defendant's ineffective assistance of counsel claim.Defendant was convicted of robbery with a dangerous weapon. The court of appeals affirmed. Defendant later filed a motion for appropriate relief (MAR) arguing that the evidence was insufficient to support his conviction and that his appellate counsel was ineffective for failing to raise this claim on appeal. Without conducting an evidentiary hearing, the trial court denied Defendant’s MAR. The court of appeals reversed, concluding that Defendant received ineffective assistance of appellate counsel in his first appeal and that Defendant’s conviction would have been reversed had his counsel raised the sufficiency of the evidence issue in his first appeal. The Supreme Court reversed, holding that the record before the court was insufficient to determine whether Defendant received ineffective assistance of counsel. View "State v. Todd" on Justia Law