Criminal defendant—police body camera footage—statutory procedure for compelling release—no violation of right to present complete defense—In a criminal case arising from defendant's arrest for resisting a public officer, where defendant served a subpoena on the police department seeking body camera footage of her encounter with law enforcement, the statutorily-required procedure set forth in N.C.G.S. § 132-1.4A, which supplanted the use of a subpoena and provided the exclusive means for criminal defendants to seek disclosure of certain law enforcement agency recordings, did not violate defendant's constitutional rights to obtain evidence necessary to present a complete defense. Although the superior court–from which section 132-1.4A required defendant to seek an order releasing the footage–would have discretion under the statute in selecting which portions (if any) of the footage would be released, binding constitutional precedent would still require the court to exercise that discretion in a manner consistent with defendant's constitutional rights irrespective of the statute's criteria. State v. Chemuti , No. 282PA24 (N.C. Oct. 17, 2025) (Author: Justice Richard Dietz)

Complex business case—claims brought by minority shareholders—appellate review—deference to Business Court's analysis—In a complex business case, where the Supreme Court modified and affirmed the Business Court's dismissal of a judicial dissolution claim brought by plaintiffs (minority shareholders in a family-run corporation), the Court also affirmed the Business Court's grant of summary judgment to defendant majority shareholders on plaintiffs' remaining claims–including individual claims for constructive fraud and a constructive trust, as well as myriad derivative claims–on the ground that the Business Court's rulings on these issues were highly fact-bound and applied settled law to the evidence presented in the case, and therefore rehashing the Business Court's analysis would not meaningfully add to the Court's jurisprudence. Mauck v. Cherry Oil Co. , No. 318A24 (N.C. Oct. 17, 2025) (Author: Justice Anita Earls)

Judicial dissolution—minority shareholders—standing to sue—failure to state a claim—In a complex business case, where plaintiff minority shareholders in a family-run corporation alleged that their rights, including their reasonable expectation of continued involvement in managing the business, were thwarted when defendant majority shareholders fired them, removed them from the board of directors, and attempted to force a buyout of their shares, the Business Court erred in concluding that plaintiffs lacked standing to sue for judicial dissolution of the corporation under N.C.G.S. § 55-14-30(2)(ii), since plaintiffs' complaint sufficiently alleged a legal injury and because plaintiffs fell within the class of people the statute authorized to sue. Nevertheless, the complaint warranted dismissal under Civil Procedure Rule 12(b)(6) for failure to state a judicial dissolution claim. Specifically, the complaint alleged the existence of a buyback provision in the parties' shareholder agreement granting plaintiffs the right to sell their shares back to the corporation at fair market value–essentially the same relief they would receive through judicial dissolution, but without the collateral fallout resulting from dissolution of a company–without alleging additional facts showing that judicial dissolution was "reasonably necessary" to vindicate plaintiffs' rights or that plaintiffs were entitled to dissolution as equitable relief. Mauck v. Cherry Oil Co. , No. 318A24 (N.C. Oct. 17, 2025) (Author: Justice Anita Earls)

Police body camera footage—statute—superior court order—exclusive procedure for access—In a criminal case arising from defendant's arrest for resisting a public officer, where defendant served a subpoena on the police department seeking body camera footage of her encounter with law enforcement, which the Town of Mooresville claimed was protected from release under N.C.G.S. § 132-1.4A (laying out special procedures for protecting the confidentiality of certain law enforcement agency recordings), the district court's order compelling the Town to comply with the subpoena was vacated because the procedure set forth in section 132-1.4A–requiring defendant to petition the superior court in the county where the body camera footage was made for an order permitting release of the footage–supplanted the use of a subpoena and provided the exclusive means for criminal defendants to seek disclosure of recordings protected under the statute for use in criminal cases. The matter was remanded to afford defendant the opportunity to petition the superior court pursuant to the statute. State v. Chemuti , No. 282PA24 (N.C. Oct. 17, 2025) (Author: Justice Richard Dietz)

Exclusion of written statement—misapprehension of Rule 403 standard—abuse of discretion—In a prosecution for multiple sexual offenses, in which the trial court excluded a written statement by the victim, which could have been used to impeach her credibility, the trial court operated under a misapprehension of the law when it stated as the basis for the exclusion (under Evidence Rule 403) that the evidence was more prejudicial than probative, rather than the correct standard of evaluating whether the probative value of the evidence was substantially outweighed by the danger of unfair prejudice. Therefore, the Court of Appeals correctly determined that the trial court's error amounted to an abuse of discretion that caused prejudice to defendant and that, as a result, defendant was entitled to a new trial. State v. Lail , No. 166A24 (N.C. Oct. 17, 2025) (Author: Justice Per Curiam)

Certificate of need—contested case—final decisions subject to review—deference to factual determination—In a contested case proceeding initiated by petitioners–a pair of medical services entities that jointly filed an application for a certificate of need (CON) for a single additional fixed magnetic resonance imaging (MRI) scanner to be placed in Wake County–after respondent–the North Carolina Department of Health and Human Services, Health Care Planning and Certificate of Need Section–denied petitioners' application and awarded the CON to another applicant (respondent-intervenor), the Supreme Court emphasized that, under 2011 amendments to the Administrative Procedure Act, the final decision of the administrative law judge (ALJ), rather than the final agency decision by respondent, was subject to judicial review. Further, in reaching a final decision, the ALJ was not required to give deference to certain of respondent's factual determinations resulting from its comparative analysis of the competing applications, because respondent had committed multiple reversible errors (including mathematical mistakes and departures from respondent's own practices and procedures) and, thus, those determinations were not based upon respondent's specialized knowledge or expertise. Pinnacle Health Servs. of N.C. LLC v. N.C. Dep't of Health & Hum. Servs. , No. 285A23 (N.C. Oct. 17, 2025) (Author: Justice Phil Berger, Jr.)

Certificate of need—contested case—whole record review—substantial prejudice—In a contested case proceeding initiated by petitioners–a pair of medical services entities who had jointly filed an application for a certificate of need (CON) for a single additional fixed magnetic resonance imaging (MRI) scanner to be placed in Wake County–after respondent–the North Carolina Department of Health and Human Services, Health Care Planning and Certificate of Need Section–denied petitioners' application and awarded the CON to another applicant (respondent-intervenor), the decision of the administrative law judge (ALJ) to award the CON to petitioners was affirmed. The ALJ's reversal of respondent's comparative analysis was upheld where, as appellants, respondent and respondent-intervenor failed to meet their burden under the whole record test by showing that the ALJ's decision was not supported by substantial record evidence because they did not challenge any specific findings of fact. The ALJ's determination that petitioners suffered substantial prejudice was upheld because, where two eligible applicants compete for a single CON, the denied applicant (here, petitioners) is inherently prejudiced since, but for the denial, the denied applicant would have received the CON. Pinnacle Health Servs. of N.C. LLC v. N.C. Dep't of Health & Hum. Servs. , No. 285A23 (N.C. Oct. 17, 2025) (Author: Justice Phil Berger, Jr.)

Batson inquiry—first step not mooted—remanded for appellate review of the trial court's prima facie determination—During jury selection in a prosecution on charges including two counts of first-degree murder, where defendant raised a Batson objection–asserting that the State had used peremptory challenges based on the race of prospective jurors, thus triggering a potentially three-step process in which the trial court first determines whether defendant has made a prima facie case, and, if so, then permits the State to offer race-neutral explanations for challenges, after which the court would determine whether defendant has shown purposeful discrimination by the State–the first step, in which the trial court held that defendant had failed to establish a prima facie case, was not mooted by the State's subsequent reference to race-neutral reasons for its challenges because the inquiry should have ended after the trial court’s determination in the first step and because the trial court did not rule on the ultimate question of intentional discrimination. The matter was reversed and remanded to the Court of Appeals for consideration of whether the trial court clearly erred in determining that no prima facie case had been established. State v. Wilson , No. 307PA23 (N.C. Oct. 17, 2025) (Author: Justice Phil Berger, Jr.)

Fatal chiller explosion—unforeseeable event—lack of proximate cause—In a wrongful death action filed by decedent's estate against individual employees (defendants) in the HVAC and maintenance department of a state university, the trial court properly granted summary judgment in favor of defendants where there was no genuine issue of material fact regarding whether defendants proximately caused decedent's fatal injuries when an industrial chiller exploded. The evidence established that decedent's death was the result of an unforeseeable sequence of events, since defendants could not have reasonably foreseen that their failure to fill the chiller's tubes with antifreeze during winter maintenance would have resulted in the unit becoming pressurized and causing any harm to decedent. The chiller's pressurization was unexpected because it was not connected to electricity or water and, further, the chiller's manual and labels, even had defendants read them, did not contain any warnings about bodily danger to individuals working on a pressurized chiller. Long v. Fowler , No. 303A20-2 (N.C. Oct. 17, 2025) (Author: Justice Phil Berger, Jr.)

Exclusionary rule—cell-site location information—good faith exception—statutory and constitutional analyses—In a prosecution for drug trafficking and possession, the trial court did not err by denying defendant's motion to suppress evidence obtained from cell-site location information (CSLI) as authorized by an order (issued pursuant to 18 U.S.C. § 2703(d); hereinafter, Section 2703(d) Order) that was later determined to be unsupported by probable cause. First, the statutory good faith exception to the exclusionary rule (contained in N.C.G.S. § 15A-974(a)(2)) did not apply to prevent the suppression of the CSLI because that evidence was not obtained in substantial violation of Chapter 15A of the General Statutes. However, exclusion was not required under the federal or state constitutions. Since the detective's reliance on the Section 2703(d) Order was objectively reasonable, the challenged evidence was subject to the federal constitutional good faith exception to the exclusionary rule arising out of the Fourth Amendment. The Supreme Court expressly overruled State v. Carter, 322 N.C. 709 (1988)–which held that Article I, section 20 of the North Carolina Constitution contains an exclusionary rule–but assumed without deciding that such a rule does arise under the state constitution and, moreover, that the rule contains a good faith exception equivalent to the federal exception. Since exclusion was not required under either constitution, the decision of the Court of Appeals overruling the trial court and granting defendant a new trial was reversed. State v. Rogers , No. 377PA22 (N.C. Oct. 17, 2025) (Author: Chief Justice Paul Newby)

Motion to suppress—warrant—information in accompanying affidavit sufficient—In a prosecution on numerous charges–arising from the theft of, among other items, cash, cigarettes, and lottery tickets from a market–the trial court properly denied defendant's motion to suppress evidence discovered during the execution of a search warrant for his vehicle where, even disregarding the information obtained during a "knock-and-talk" that defendant challenged as unconstitutional, the affidavit accompanying the warrant application contained information supporting a fair probability that contraband would be discovered in the vehicle, including: security video footage showing a vehicle transporting a woman to and from a convenience store where she unsuccessfully attempted to redeem one of the stolen lottery tickets, an officer responding to the store's alert spotted a similar vehicle in a driveway, and the officer determining that the vehicle (eventually determined to be registered to defendant) had a fictitious license plate, a ploy known in the officer's experience to be used by criminals to avoid identification by law enforcement. State v. Norman , No. 151A24 (N.C. Oct. 17, 2025) (Author: Chief Justice Paul Newby)