Justia Constitutional Law Opinion Summaries

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

The Supreme Court affirmed the orders of the trial court terminating Mother's parental rights to her daughter, holding that there was no error. After a termination hearing, the trial court determined that grounds existed to terminate Mother's parental rights under N.C. Gen. Stat. 7B-1111(a)(1) and (2) and that it was in the child's best interests to terminate Mother's parental rights. On appeal, Mother argued that the trial court erred by concluding that terminating her parental rights was in the child's best interests. The Supreme Court affirmed, holding that the court did not abuse its discretion by determining that termination of Mother's parental rights was in the child's best interests. View "In re H.R.S." on Justia Law

The Supreme Court held that the court of appeals erred in concluding that more than 220,000 former State employees (the Retirees) possessed no vested rights within the meaning of the Contracts Clause to the benefit of lifetime enrollment in any particular premium-free health insurance plan, holding that the trial court correctly concluded that the Retirees had obtained a vested right protected under the Contracts Clause.After the General Assembly enacted a statute eliminating Retirees' option to remain enrolled in the plan of their choice, the Retirees argued that the State had undertaken a contractual obligation to provide them with the option to remain enrolled in the premium-free preferred provider organization health insurance plan that allocated eighty percent of the costs of health care services to the insurer and twenty percent to the insured for life. The trial court entered partial summary judgment for Retirees. The court of appeals reversed and remanded for summary judgment in favor of the State. The Supreme Court reversed, holding that the trial court correctly determined there were no genuine issues of material fact relating to whether Retirees possessed a vested right protected under the Contracts Clause. View "Lake v. State Health Plan for Teachers & State Employees" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the order of the superior court (MAR court) granting Defendant's motion for appropriate relief (MAR) and awarding him a new trial, holding that the MAR court neither abused its discretion nor committed legal error in granting Defendant a new trial.Defendant was fourteen years old when he was indicted for and assaulting a cab driver who later died. Based largely on the basis of a confession Defendant made while being interrogated by a police detective outside the presence of a parent or guardian Defendant was convicted of first-degree murder. Years later, Defendant filed a MAR alleging that he was entitled to relief based on the newly discovered evidence of the testimony of a man who claimed that, on the night of the crime, another person confessed to him to assaulting the cab driver. The MAR court allowed the MAR and vacated Defendant's conviction. The court of appeals reversed. The Supreme Court reversed and remanded the case for a new trial, holding that the MAR court did not abuse its discretion in concluding that Defendant proved by a preponderance of the evidence all elements necessary to demonstrate his entitlement to a new trial on the basis of newly discovered evidence. View "State v. Reid" on Justia Law