Justia Constitutional Law Opinion Summaries

The Supreme Court reversed the judgment of the trial court allowing certain districting maps to stand, holding that the enacted maps violated several rights guaranteed to the people by the North Carolina Constitution.The General Assembly enacted districting maps for the United States Congress, the North Carolina House of Representatives, and the North Carolina Senate that "subordinated traditional neutral redistricting criteria in favor of significant partisan advantage by diluting the power of certain people's votes." The trial court denied Plaintiffs' claims, concluding as a matter of law that claims of extreme partisan gerrymandering present purely political questions that are nonjusticiable. The Supreme Court reversed, holding (1) Plaintiffs' partisan gerrymandering claims were justiciable under the North Carolina Constitution; and (2) the maps failed strict scrutiny and must be rejected. View "Harper v. Hall" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals upholding Defendant's conviction for taking indecent liberties with a child, holding that the case must be remanded for a new trial.On appeal, Defendant argued that the trial court erred in allowing the State's expert to testify that the minor child in this case was sexually abused in the absence of physical evidence confirming her opinion, that the State's expert identifying Defendant as the perpetrator of the charged offense constituted plain error, and that he received ineffective assistance of counsel (IAC). The court of appeals affirmed. The Supreme Court remanded the case for a new trial, holding (1) permitting testimony that the minor child was sexually assaulted in the absence of definitive physical evidence constituted plain error; (2) the trial court committed plain error in permitting testimony as to the medical recommendations identifying Defendant as the perpetrator; and (3) the court of appeals did not err in dismissing Defendant's IAC claim without prejudice. View "State v. Clark" on Justia Law

The Supreme Court vacated Defendant's conviction for robbery with a dangerous weapon, holding that the prosecutor's exclusion of an African-American potential juror constituted a substantive violation of Defendant's constitutional right to equal protection under Batson v. Kentucky, 476 U.S. 79 (1986).After the court of appeals affirmed Defendant's conviction, Defendant filed a notice of appeal with the Supreme Court, asserting that the case presented a substantial constitutional question under the Equal Protection Clause of the United States Constitution and N.C. Const. art. I, 19. The Supreme Court remanded the case to the trial court for reconsideration of Defendant's Batson challenge in light of the United States Supreme Court decision in Foster v. Chatman, 578 U.S. 488 (2016). On remand, the Supreme Court again ordered that Defendant's Batson objections be overruled. The Supreme Court reversed, holding that the State committed a substantive violation of Defendant's constitutional right to equal protection under the Fourteenth Amendment of the United States Constitution. View "State v. Clegg" on Justia Law

The Supreme Court modified and affirmed the ruling of the court of appeals finding no prejudicial error in the criminal proceedings resulting in Defendant's conviction for second-degree forcible rape and first-degree kidnapping, holding that there was no prejudicial error in the proceedings below. On appeal, Defendant alleged several trial court errors, including the two errors at issue on appeal. The court of appeals affirmed, thus rejecting each of Defendant's arguments. The Supreme Court modified and affirmed the court of appeals, holding that, assuming without deciding that the trial court's admission of certain testimony violated Defendant's rights under the Confrontation Clause and that other testimony violated N.C. R. Evid. 404(b), the assumed errors were not prejudicial. View "State v. Pabon" on Justia Law

The Supreme Court reversed the opinion of the court of appeals that vacated Defendant's conviction and remanded the case to the trial court for entry of a judgment of acquittal, holding that remand was required for a new trial.Defendant was convicted of "knowingly and willfully" threatening to kill a court officer. The court of appeals reversed, concluding that Defendant's conviction violated the Free Speech Clause of the First Amendment. At issue on appeal was whether the First Amendment protected Defendant from being convicted for publishing messages contained in his Facebook posts. The Supreme Court held that Defendant's messages were shielded by the First Amendment and that, because there remained questions for a properly instructed jury, the matter must be remanded for a new trial. View "State v. Taylor" on Justia Law

The Supreme Court affirmed the order of the district court terminating Mother's parental rights, holding that Mother could not prevail on her ineffective assistance of counsel claim.After a hearing, the trial court concluded that grounds existed to terminate Mother's parental rights under N.C. Gen. Stat. 7B-1111(a)(1) and (6). The trial court then concluded that it would be in the child's best interest for Mother's parental rights to be terminated. On appeal, Mother argued that the trial court failed to ensure that she received ineffective assistance of counsel. The Supreme Court affirmed, holding that Mother failed to demonstrate that, but for the alleged deficiency by counsel, there was a reasonable probability of a different result. View "In re Z.M.T." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the trial court's order in this case, which imposed continuous GPS tracking using a small, unobtrusive ankle monitor on Defendant for life, constitutionally permissible under the Fourth Amendment as a reasonable, continuing, warrantless search.Defendant pleaded guilty to first-degree kidnapping, robbery with a dangerous weapon, and first-degree forcible rape. Upon Defendant's release from his active sentence the State filed a petition to impose lifetime satellite-based monitoring (SBM) on Defendant. After a hearing, the trial court filed a form order imposing lifetime SBM upon Defendant. The court of appeals reversed, and the State appealed. On appeal, Defendant argued that the imposition of lifetime SBM under the General Assembly's enacted statutory scheme governing the program was unconstitutional. The Supreme Court reversed, holding that the implementation of lifetime satellite-based monitoring was constitutionally permissible and applicable to Defendant under the Fourth Amendment under the specific facts of Defendant's case. View "State v. Strudwick" on Justia Law

The Supreme Court reinstated the order of the trial court imposing lifetime satellite-based monitoring (SBM) based upon Defendant's status as an aggravated offender, holding that the order complied with the Fourth Amendment of the United States Constitution and N.C. Const. art. I, 20.Defendant pleaded guilty to first-degree statutory rape and first-degree statutory sexual offense. While Defendant was on probation, he sexually assaulted his minor niece. The trial court ordered Defendant to enroll in lifetime SBM and that, under the totality of the circumstances, the SBM program was constitutionally reasonable as applied to Defendant. The Supreme Court affirmed, holding (1) a search effected by the imposition of lifetime SBM upon a defendant due to his status as an aggravated offender is reasonable under the Fourth Amendment; and (2) the SBM program does not violate Article I, Section 20 because SMB orders do not constitute general warrants. View "State v. Hilton" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the trial court denying Defendant's motion to suppress evidence of a bag of narcotics seized from his vehicle during a traffic stop, holding that the trial court properly denied Defendant's motion to suppress.On appeal, Defendant argued that the law enforcement officers conducting a search for weapons on his person and in the areas of his vehicle under his immediate control did not possess the required reasonable suspension to initiate a warrantless search. The Supreme Court disagreed, holding (1) the law enforcement officer who conducted the traffic stop presented articulable facts at the suppression hearing giving rise to a reasonable suspicion that Defendant was armed and dangerous; and (2) the trial court did not err in denying Defendant's request to suppress the controlled substances that were discovered as a result of the search of the areas of Defendant's vehicle which were under his immediate control. View "State v. Johnson" on Justia Law

The Supreme Court affirmed Defendant's conviction of speeding ninety-four miles per hour in a sixty-five mile-per-hour zone, holding that Defendant knowingly and voluntarily waived his constitutional right to a jury trial.In affirming Defendant's conviction, a divided panel of the Court of Appeals concluded that, even though the trial court failed to follow the statutory procedure for waiver of Defendant's right to a jury trial, Defendant was not prejudiced. The Supreme Court affirmed, holding (1) although the trial court's colloquy was untimely, the facts demonstrated that Defendant understood he was waiving his right to a trial by jury and the consequences of that decision; and (2) Defendant did not meet his burden of demonstrating that there was no reasonable possibility that had the error not been committed a different result would have been reached in a bench trial or a jury trial. View "State v. Hamer" on Justia Law