Justia Civil Rights Opinion Summaries

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

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