Legislative Limitations on Reopening Final Judgments: Separation of Powers under North Carolina Law

Introduction

Doe v. Roman Catholic Diocese of Charlotte (No. 167PA22 & No. 168PA22) is a landmark decision of the Supreme Court of North Carolina filed on January 31, 2025. The plaintiffs, John Doe 1K and John Doe, alleged decades‐old child sexual abuse by clergy of the Roman Catholic Diocese of Charlotte. Their original claims, filed in 2011 and dismissed as time-barred, became final over a decade ago. In 2019, the North Carolina General Assembly enacted the SAFE Child Act, reviving certain time-barred claims for child sexual abuse. The plaintiffs then attempted to bring new suits under the revived statutes, contending that the Act effectively set aside their prior final judgments. The key issue: Can the legislature, by enacting a revival statute, override final judicial judgments previously entered on the merits?

Summary of the Judgment

The Supreme Court affirmed the Court of Appeals’ rulings dismissing the plaintiffs’ new actions on res judicata grounds. Invoking Article IV, Section 1 and Article I, Section 6 of the North Carolina Constitution—the separation of powers clauses—the Court held that only the judiciary may set aside its own final judgments. Although the SAFE Child Act validly revives time-barred claims in principle, it cannot nullify pre-existing, final judgments. The legislative branch lacks authority to annul or reopen judgments rendered by the judicial branch.

Analysis

Precedents Cited

Hogan v. Cone Mills Corp. (315 N.C. 127): Established that relief from final judgments is an integral part of judicial power, and the legislature cannot encroach upon that.
Piedmont Mem’l Hosp., Inc. v. Guilford County (221 N.C. 308): Held unconstitutional any legislative attempt to annul or modify a court’s final decree.
Gardner v. Gardner (300 N.C. 715): Applied separation-of-powers principles to procedural judgments (e.g., venue dismissals) that the legislature attempted to override.
Poindexter v. First Nat. Bank of Winston-Salem (247 N.C. 606): Defined res judicata and underscored the importance of finality in litigation.
Thomas M. McInnis & Assocs., Inc. v. Hall (318 N.C. 421): Clarified that a final judgment on the merits bars subsequent suits on the same cause of action.
McKinney v. Goins (109PA22-2): In a companion case, held that a revival statute is not facially unconstitutional—but did not involve pre-existing final judgments.
Plaut v. Spendthrift Farm, Inc. (514 U.S. 211): The U.S. Supreme Court struck down a federal statute requiring the reopening of final judgments, reinforcing separation of powers at the federal level.

Legal Reasoning

1. Article IV, § 1: “The judicial power of the State shall be vested in a Supreme Court... The General Assembly shall have no power to deprive the judicial department of any power or jurisdiction that rightfully pertains to it.”
2. Article I, § 6: “The legislative, executive, and supreme judicial powers of the State government shall be forever separate and distinct from each other.”
3. Res Judicata: A doctrine rooted in finality—once a court of competent jurisdiction resolves a cause of action on the merits and the judgment becomes final, the parties cannot relitigate the same claim.
4. Judicial Power to Vacate Judgments: Only a court may set aside or modify its own judgments, whether under Rule 60(b) or other procedural mechanisms. The legislature cannot perform that function by statute.

Impact

• Separation of Powers Reinforced: This decision cements that revival statutes cannot circumvent prior final judgments.
• SAFE Child Act Applications: Victims whose claims were dismissed as time-barred may benefit from revival only if no final judgment on the merits has been entered against them.
• Judicial vs. Legislative Authority: Future enactments must respect boundaries: statutory reforms cannot retroactively erase final judicial decisions.
• Rule 60(b) Motions: Plaintiffs may still seek relief from their final judgments in the trial court under established procedural rules, subject to timeliness and merit.

Complex Concepts Simplified

Res Judicata: Latin for “a matter judged.” Once a court issues a final decision on the merits, that ruling is binding and bars new lawsuits on the same dispute.
Final Judgment: A decision by a court from which no appeal is taken or appeal rights are exhausted, rendering the decision conclusive.
Separation of Powers: A constitutional principle dividing government authority among legislative, executive, and judicial branches, each with exclusive powers.
Rule 60(b): A procedural mechanism allowing courts to relieve a party from a final judgment under specific circumstances (e.g., mistake, newly discovered evidence).

Conclusion

Doe v. Roman Catholic Diocese reaffirms a core tenet of North Carolina constitutional law: the legislature cannot, by statute, nullify or reopen final judgments entered by the courts. While the SAFE Child Act validly revives certain time-barred child sexual abuse claims, it cannot override the res judicata effect of judgments that became final before its enactment. Only the judicial branch, through mechanisms such as Rule 60(b), may grant relief from its own final orders. This decision thus preserves the integrity and finality of the judicial process and delineates clear boundaries between legislative reforms and judicial authority.