North Carolina Case Commentaries

Unforeseeable Chains of Events and Generalized Warnings Do Not Establish Proximate Cause: Long v. Fowler (N.C. 2025)

Date: Oct 22, 2025

Unforeseeable Chains of Events and Generalized Warnings Do Not Establish Proximate Cause: Long v. Fowler (N.C. 2025) Introduction In Long v. Fowler, the Supreme Court of North Carolina affirmed...

Mauck v. Cherry Oil Co.: Put/Call Shareholder Agreements Can Defeat Meiselman Dissolution Absent Pleaded “Reasonable Necessity” Under N.C.G.S. § 55-14-30(2)(ii)

Date: Oct 22, 2025

Mauck v. Cherry Oil Co.: Put/Call Shareholder Agreements Can Defeat Meiselman Dissolution Absent Pleaded “Reasonable Necessity” Under N.C.G.S. § 55-14-30(2)(ii) Introduction This North Carolina...

No Binding Agency Deference in North Carolina: Mitchell mandates de novo review of state administrative regulations

Date: Oct 22, 2025

No Binding Agency Deference in North Carolina: Mitchell v. UNC Board of Governors mandates de novo review of state administrative regulations Introduction In Mitchell v. University of North Carolina...

General Permit Conditions That Function as Regulations Are “Rules”: North Carolina Supreme Court Requires APA Rulemaking for Broad Animal‑Waste Permit Conditions

Date: Oct 22, 2025

General Permit Conditions That Function as Regulations Are “Rules”: The North Carolina Supreme Court Requires APA Rulemaking for Broad Animal‑Waste Permit Conditions Case: N.C. Dep't of Env't...

Reviewing the ALJ, Not the Agency, and Recognizing “But-For” Prejudice in Two‑Applicant CON Contests: The North Carolina Supreme Court’s Decision in Pinnacle Health Services v. NCDHHS

Date: Oct 22, 2025

Reviewing the ALJ, Not the Agency, and Recognizing “But-For” Prejudice in Two‑Applicant CON Contests Pinnacle Health Services of N.C., LLC v. N.C. Department of Health & Human Services (N.C. Oct. 17,...

State v. Chemuti: Superior-Court Petition Is the Exclusive Path to Obtain Law‑Enforcement Recordings Under N.C.G.S. § 132‑1.4A

Date: Oct 22, 2025

State v. Chemuti: Superior-Court Petition Is the Exclusive Path to Obtain Law‑Enforcement Recordings Under N.C.G.S. § 132‑1.4A Introduction In State v. Chemuti (Supreme Court of North Carolina, Oct....

State v. Lail (N.C. 2025): Misstating the Rule 403 Standard Constitutes Abuse of Discretion; Plain Error Review Does Not Reach Discretionary Evidentiary Rulings

Date: Oct 22, 2025

State v. Lail (N.C. 2025): Misstating the Rule 403 Standard Constitutes Abuse of Discretion; Plain Error Review Does Not Reach Discretionary Evidentiary Rulings Introduction In State v. Lail, the...

State v. Norman: Probable Cause for a Vehicle Search Warrant Can Rest on Distinctive Vehicle Identification and a Fictitious Plate—No Need to Resolve Knock-and-Talk Legality When Tainted Facts Are Excised

Date: Oct 22, 2025

State v. Norman: Probable Cause for a Vehicle Search Warrant Can Rest on Distinctive Vehicle Identification and a Fictitious Plate—No Need to Resolve Knock-and-Talk Legality When Tainted Facts Are...

Rogers Overrules Carter: North Carolina Adopts a State Constitutional Good-Faith Exception and Limits § 15A‑974’s Good-Faith to Statutory (Chapter 15A) Violations

Date: Oct 22, 2025

Rogers Overrules Carter: North Carolina Adopts a State Constitutional Good-Faith Exception and Limits § 15A‑974’s Good-Faith to Statutory (Chapter 15A) Violations Introduction In State v. Rogers, the...

Clarifying Batson Mootness in North Carolina: Step One Is Not Moot Absent a Step-Three Ruling

Date: Oct 22, 2025

Clarifying Batson Mootness in North Carolina: Step One Is Not Moot Absent a Step-Three Ruling Introduction In State v. Wilson, the Supreme Court of North Carolina addressed a recurring procedural...

Cutter v. Vojnovic: Derivative Standing Denied for General Partners and Modern Clarification of Partnership Formation in North Carolina

Date: Aug 26, 2025

Cutter v. Vojnovic: Derivative Standing Denied for General Partners and Modern Clarification of Partnership Formation in North Carolina 1. Introduction In Cutter v. Vojnovic, the Supreme Court of...

“Present Candor over Past Reform” – Devalle v. N.C. Sheriffs’ Education & Training Standards Commission

Date: Aug 26, 2025

“Present Candor over Past Reform” The North Carolina Supreme Court Redefines the Temporal Focus of the “Good Moral Character” Inquiry for Justice-Officer Certification 1. Introduction In Devalle v....

Durbin v. Durbin: Escalating Parental Conflict as a “Substantial Change in Circumstances” Justifying Custody Modification

Date: Aug 26, 2025

Durbin v. Durbin: Escalating Parental Conflict as a “Substantial Change in Circumstances” Justifying Custody Modification 1. Introduction Durbin v. Durbin, decided by the Supreme Court of North...

Howell v. Cooper: The North Carolina Supreme Court Broadens Direct State-Constitutional Remedies for Economic Restrictions in Public Emergencies

Date: Aug 26, 2025

Howell v. Cooper: The North Carolina Supreme Court Broadens Direct State-Constitutional Remedies for Economic Restrictions in Public Emergencies Introduction In Howell v. Cooper (22 Aug 2025) the...

“Unexplained Severe Abuse = Predictive Neglect” & “No Sua Sponte Review”: The Twin Doctrines Reaffirmed in In re E.H. & R.H. (N.C. 2025)

Date: Aug 26, 2025

“Unexplained Severe Abuse = Predictive Neglect” & “No Sua Sponte Review”: A Comprehensive Commentary on In re E.H. & R.H., Supreme Court of North Carolina (2025) 1. Introduction The Supreme Court of...

No-Inducement Standard for North Carolina Referral-Sales Claims – A Commentary on Jackson v. Home Depot U.S.A., Inc.

Date: Aug 26, 2025

No-Inducement Standard for North Carolina Referral-Sales Claims Jackson v. Home Depot U.S.A., Inc. (N.C. 2025) I. Introduction Jackson v. Home Depot U.S.A., Inc. is the North Carolina Supreme Court’s...

“Situational-Awareness” and Contributory Negligence: The Precedential Reach of Moseley v. Hendricks (N.C. 2025)

Date: Aug 26, 2025

“Situational-Awareness” and Contributory Negligence: The Precedential Reach of Moseley v. Hendricks (Supreme Court of North Carolina, 2025) 1. Introduction Moseley v. Hendricks is a sharply divided...

From “Rational” to “Reasonable”: N.C. Bar & Tavern Ass’n v. Stein and the New Fruits-of-Labor Scrutiny in North Carolina

Date: Aug 26, 2025

From “Rational” to “Reasonable”: N.C. Bar & Tavern Association v. Stein (2025) and the Re-Tooling of Fruits-of-Labor Doctrine Introduction In N.C. Bar and Tavern Association v. Stein, the Supreme...

Administrative Agencies Barred from Deciding As-Applied Constitutional Tax Challenges – Commentary on N.C. Dep’t of Revenue v. Philip Morris USA, Inc. (N.C. 2025)

Date: Aug 26, 2025

Administrative Agencies Barred from Deciding As-Applied Constitutional Tax Challenges: A Full Commentary on N.C. Department of Revenue v. Philip Morris USA, Inc., Supreme Court of North Carolina...

“Good-Bye, Chevron: The Supreme Court of North Carolina Re-Establishes Pure De Novo Review in Savage v. N.C. Department of Transportation”

Date: Aug 26, 2025

“Good-Bye, Chevron: The Supreme Court of North Carolina Re-Establishes Pure De Novo Review in Savage v. N.C. Department of Transportation” 1. Introduction Savage v. N.C. Dep’t of Transportation, No....