Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the order of the trial court denying the motion for class certification brought by Plaintiffs, inmates in North Carolina Department of Public Safety (DPS) custody, seeking to represent certain individuals in DPS custody who are being or will be subjected to solitary confinement, holding that the trial court did not abuse its discretion.Plaintiffs filed a class action lawsuit seeking to certify a class of current and future inmates assigned to one of five restrictive housing classifications, alleging that the conditions of confinement constituted cruel or unusual punishment. The trial court denied Plaintiffs' motion for class certification, finding that a certifiable class did not exist. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in concluding that Plaintiffs failed to demonstrate a common predominating issue among the proposed class members. View "Dewalt v. Hooks" on Justia Law

The Supreme Court exercised is constitutional power to address constitutional violations through equitable remedies by affirming and reinstating the trial court's directive instructing certain State officials to transfer the funds necessary to comply with years two and three of the State's comprehensive remedial plan (CRP), holding that this Court has an obligation to safeguard the constitutional rights of North Carolina's schoolchildren.In November 2021, the trial court issued the order before the Supreme Court for review. In the order, the trial court declared that the State had failed to fulfill its constitutional obligations to provide school children, especially those at risk and socioeconomically disadvantaged, their constitutional right to a sound basic education. The trial court ordered the State to transfer the total amount of funds necessary to effectuate years two and three of the CRP. The State Controller sought an order preventing her from being required to comply with the trial court's order. The court of appeals issued a writ of prohibition restraining the trial court from proceeding in the matter. Thereafter, the trial court issued an order removing that transfer directive. The Supreme Court stayed the writ of prohibition and reinstated the trial court's November 2021 directive, holding that the judiciary must fulfill its obligation to protect the fundamental rights of the State's individuals. View "Hoke County Bd. of Education v. State" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals upholding the revocation of Defendant's probation, holding that Defendant's confrontation argument under N.C. Gen. Stat. 15A-1345(e) was not preserved.Defendant pleaded guilty to discharging a weapon into occupied property and possession of a firearm by a convicted felon. Later, Defendant's probation was revoked following a determination that he had committed new criminal offenses. On appeal, Defendant argued that the trial court violated his constitutional right to confront witnesses against him at the probation hearing. The court of appeals affirmed, holding that there was no Sixth Amendment violation in this case. The Supreme Court modified and affirmed the judgment below, holding (1) a defendant's arguments under N.C. Gen. Stat. 15A-1345(e) are preserved when a defendant lodges a proper objection or the trial court does not permit confrontation and fails to make a finding of good cause; and (2) the condition requiring a finding of good cause was not satisfied in this case. View "State v. Jones" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the order of the trial court denying Nation Ford Baptist Church Inc.'s (Church) motion to dismiss the underlying complaint with respect to Pastor Phillip R.J. Davis's claim for a declaratory judgment, holding that certain claims must be dismissed for lack of subject matter jurisdiction.Pastor Davis filed a complaint against the Church and Nation Ford's Board of Directors, arguing that the Board exceeded its authority under the Church's corporate bylaws when it purported to terminate him by vote of the Board because the governing bylaws allowed termination only by vote of the Church's congregation at a special general meeting. The trial court denied the Church's motion to dismiss, and the court of appeals affirmed. The Supreme Court reversed in part, holding (1) Pastor Davis's claim for a declaratory judgment regarding the various bylaws can proceed; and (2) First Amendment principles required the dismissal of Pastor Davis's other claims. View "Nation Ford Baptist Church, Inc. v. Davis" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals affirming an order of the superior court resentencing Defendant on his first-degree murder conviction to life with the possibility of parole after twenty-five years and running his first-degree kidnapping sentence consecutively with his murder sentence, holding that Defendant failed to show prejudice.Defendant filed a motion for appropriate relief seeking sentencing under Miller v. Alabama, 567 U.S. 460 (2012). The trial court allowed the motion and resentenced Defendant. On appeal, the court of appeals rejected Defendant's claim that he received ineffective assistance of counsel at sentencing. The Supreme Court affirmed as modified, holding (1) the reasoning below is rejected to the extent it incorrectly suggested that the resentencing court lacked authority to run Defendant's first-degree murder sentence concurrently with his robbery with a dangerous weapon sentences; and (2) the court of appeals correctly concluded that Defendant could not demonstrate prejudice. View "State v. Oglesby" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the trial court's denial of Defendant's motion to suppress, holding that the trial court's findings of fact were supported by competent evidence and that Defendant's search and seizure did not violate the Fourth Amendment of the United States Constitution.Following the trial court's denial of Defendant's motion to suppress Defendant pleaded guilty to various drug offenses. The court of appeals vacated the convictions, concluding that the trial court erred in denying Defendant's motion to suppress. The Supreme Court reversed, holding (1) competent evidence supported the trial court's findings of fact; (2) Defendant was lawfully detained pursuant to Michigan v. Summers, 452 U.S. 692 (1981) and State v. Williams, 490 S.E.2d 583 (N.C. 1997); and (3) the frisk of Defendant was reasonable under the totality of the circumstances. View "State v. Tripp" on Justia Law

The Supreme Court held that juvenile offenders who have received sentences of life imprisonment with the possibility for parole must have the opportunity to seek an early release afforded by the prospect of parole after serving no more than forty years' incarceration.Defendant was fifteen years old when he received sentences of 240 to 348 months' imprisonment for a rape conviction and life imprisonment with the possibility of parole for a murder conviction, ordered by the trial court to run consecutively. The Supreme Court held that, while juvenile offenders who have received sentences of life imprisonment with the possibility of parole are not guaranteed parole at any point during their terms of incarceration, to compel Defendant to serve a term of incarceration in excess of forty years upon the trial court's determination that Defendant was neither incorrigible nor irredeemable would constitutionally constitute a de facto life sentence. View "State v. Conner" on Justia Law

The Supreme Court vacated the decision of the court of appeals dismissing Defendant's appeal of his conviction for two counts of manufacturing methamphetamine, holding that the trial court erred in denying Defendant's motion to suppress.Defendant filed two motions to suppress evidence obtained during two searches of Defendants home in 2014 and 2015. Both motions were denied. Defendant appealed, but the court of appeals dismissed the appeal and denied his petition for a writ of certiorari. The Supreme Court remanded the case for reconsideration in light of State v. Ledbetter, 371 N.C. 192 (2018) and State v. Stubbs, 368 N.C. 40 (2015). On remand, the court of appeals again denied the petition, indicating that Defendant's failure to provide timely notice of his intent to appeal was fatal to his petition. The Supreme Court vacated the decision below, holding that the court of appeals had the jurisdiction and authority to issue the writ of certiorari. View "State v. Killette" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating the order of the trial court denying Defendant's motion to dismiss, holding that the trial court did not err.Defendant was charged with one count of driving while impaired and one count of reckless driving. Defendant filed a motion to suppress evidence obtained at a Harnett County checking station. The trial court denied the motion to dismiss, and Defendant later pleaded guilty to driving while impaired. The court of appeals vacated the trial court's order denying Defendant's motion to suppress, concluding that the trial court could not assess whether the public interest in the checking station outweighed its infringement on Defendant's Fourth Amendment privacy interests. The Supreme Court reversed, holding that the unchallenged findings of fact supported the trial court's conclusion that the public interest served by the checking station outweighed the intrusion on Defendant's liberty interests. View "State v. Cobb" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing the order of the trial court and vacating Defendant's convictions on the grounds that the delay in his case was unjustified and violated his Sixth Amendment right to a speedy trial, holding that remand was required.After a jury trial, Defendant was convicted of felony hit and run resulting in serious injury or death, two counts of second-degree murder, and attaining violent habitual felon status. The court of appeals reversed and vacated Defendant's convictions, holding that the trial court erred in denying Defendant's pretrial motion to dismiss based on speedy trial grounds. The Supreme Court reversed in part, holding (1) the trial court improperly admitted the testimony of Defendant's prior attorney where there was no waiver of the attorney-client privilege; and (2) the case is remanded for a rehearing on Defendant's speedy trial claim. View "State v. Farook" on Justia Law