Paul Martin Newby

This case originated in 1994 when students, parents, and school boards from specific low-wealth and urban districts in North Carolina sued the State and State Board of Education, alleging that the allocation of education funds violated students' rights under the state constitution to a sound basic education. Over time, the litigation expanded from claims focused on named districts to a statewide challenge involving a comprehensive remedial plan for public education funding and resources. The North Carolina Supreme Court addressed whether the trial court had subject matter jurisdiction to issue its April 2023 order after the claims had transformed substantially without following procedures to invoke jurisdiction over the new issues. The Court held that the trial court lacked jurisdiction because litigants must properly invoke jurisdiction for the specific claims presented, and a complete change in subject matter without such invocation prevents adjudication. The decision emphasizes that jurisdiction is not automatically extended when the scope of a case shifts dramatically from its original pleadings.

civil rightsprocedure

In this case, defendant Quantez Lashay Thomas was convicted after a second trial of multiple theft-related offenses following a successful appeal that ordered a new trial due to an invalid waiver of counsel. After the first trial, the trial court had consolidated the convictions and imposed sentences that undercalculated the minimum term required by North Carolina's Structured Sentencing Act for the most serious offense in each judgment. On remand, the court corrected the error in the second judgment by imposing a longer sentence consistent with the statutory framework, resulting in an overall increase. The Supreme Court of North Carolina affirmed, holding that trial courts must impose lawful sentences under the mandatory sentencing statutes and that the statutory bar on increased sentences after a successful appeal does not prevent correction of an illegal original sentence. The core reasoning is that courts cannot perpetuate errors that produce sentences below the legislature's prescribed range.

criminal lawprocedure

The case involved a challenge to the denial of a motion to suppress evidence obtained under a search warrant in a criminal prosecution for breaking and entering and related thefts. Officers investigating stolen lottery tickets located a vehicle matching the description from security footage and conducted a knock-and-talk at the residence, during which they observed additional stolen items in the vehicle before obtaining the warrant. The North Carolina Supreme Court modified and affirmed the Court of Appeals decision upholding the trial court's ruling. The court held that the warrant was supported by probable cause from independent facts, such as the vehicle's description, fictitious plates, and connection to the crime, without needing to resolve whether the officers' actions at the vehicle during the knock-and-talk violated the Fourth Amendment.

criminal lawprocedure

This case involved whether cell-site location information (CSLI) obtained by police via a court order under 18 U.S.C. § 2703(d) should be suppressed in a drug trafficking prosecution because the order lacked probable cause under the U.S. and North Carolina Constitutions. The Supreme Court of North Carolina held that the statutory good faith exception in N.C.G.S. § 15A-974 applies only to substantial violations of Chapter 15A and not to constitutional violations, but that the federal and state constitutions themselves permit admission of the evidence under a good faith exception to the exclusionary rule. The Court therefore concluded that the trial court properly denied the defendant's motion to suppress, reversed the Court of Appeals' decision ordering a new trial, and remanded for further proceedings. The ruling turns on the distinction between statutory and constitutional remedies for improper acquisition of digital location records.

criminal lawprocedure

This case concerned whether the North Carolina Sheriffs’ Education and Training Standards Commission properly denied Maurice Devalle's application for justice officer certification on grounds that he lacked the good moral character required for deputy sheriffs. The Supreme Court of North Carolina held that the Commission did not act arbitrarily or capriciously, reversing the Court of Appeals' decision. The court applied the whole record test and found that Devalle's own sworn testimony provided substantial evidence of his lack of candor and truthfulness, stemming from incidents where he falsified time records and residency information while employed with the Highway Patrol. The decision emphasized that this evidence supported the Commission's conclusion without needing further investigation by the Commission itself.

labor & employmentcriminal law

In State v. Wright, police officers stopped defendant Eric Wayne Wright based on a tip about an illegal firearm, conducted a pat-down with his permission, and repeatedly requested consent to search his backpack, which contained a stolen handgun. The trial court denied Wright's motion to suppress the evidence, finding that he had voluntarily consented to the search under the totality of the circumstances, including that officers had returned his identification and maintained a calm demeanor without brandishing weapons. The Court of Appeals reversed and vacated the order, but the North Carolina Supreme Court reversed that decision, holding that the consent was voluntary and the search therefore permissible under the Fourth Amendment. The court reinstated the trial court's denial of the suppression motion.

criminal lawcivil rights