Abdo v. Jones

CourtCourt of Appeals of North Carolina
DecidedNovember 15, 2022
Docket22-271
StatusPublished

This text of Abdo v. Jones (Abdo v. Jones) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abdo v. Jones, (N.C. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2022-NCCOA-740

No. COA22-271

Filed 15 November 2022

Johnston County, No. 20 CVS 1536

LUAI ABDO, Plaintiff,

v.

KEMAL ALI JONES, Defendant.

Appeal by Plaintiff from order entered 28 October 2021 by Judge D. Jack

Hooks, Jr., in Johnston County Superior Court. Heard in the Court of Appeals 4

October 2022.

David J. Martin for Plaintiff-Appellant.

Sue, Anderson & Bordman, LLP, by Stephanie W. Anderson, for Unnamed Defendant-Appellee Erie Insurance Exchange.

Russ, Worth & Cheatwood, PLLC, by Philip H. Cheatwood, for Unnamed Defendant-Appellee United Services Automobile Association.

COLLINS, Judge.

¶1 Plaintiff Luai Abdo appeals an order granting Unnamed Defendant Erie

Insurance Exchange’s motion for sanctions and dismissing Plaintiff’s complaint with

prejudice as to Defendant Kemal Ali Jones and Unnamed Defendants Erie and

United Services Automobile Association (“USAA”). Plaintiff makes no argument that

the trial court erred by dismissing the complaint against Jones. After careful review, ABDO V. JONES

Opinion of the Court

we conclude the trial court did not err by dismissing Plaintiff’s complaint against

Erie. However, we conclude the trial court erred by dismissing Plaintiff’s complaint

against USAA. Accordingly, we affirm in part and reverse in part, and remand for

further proceedings.

I. Procedural History and Factual Background

¶2 Plaintiff was involved in an automobile accident with Jones in July 2017. In

June 2020, Plaintiff filed an amended complaint against Jones, which included claims

against Erie and USAA for underinsured motorist coverage. Erie answered and

served its “First Request for Production of Documents” and “First Set of

Interrogatories” on Plaintiff in early June. USAA answered in early July.

¶3 Plaintiff responded to Erie’s discovery requests by the end of July but failed to

provide all the requested documents. Erie notified Plaintiff by email on 31 August

that his responses were deficient and requested supplemental discovery, including

Plaintiff’s pre-accident medical records. When Erie had not received a response to its

supplemental discovery request by December 2020, Erie filed a motion to compel.

Plaintiff served supplemental discovery responses in March 2021 but objected to

Erie’s request for pre-accident medical records. The trial court entered a Consent

Order on 24 March 2021, signed by Plaintiff’s attorney and Erie’s attorney, ordering

Plaintiff to produce the requested documents by 24 May 2021.

¶4 Shortly after the Consent Order was entered, Plaintiff’s attorney separated ABDO V. JONES

from his law firm. The law firm withdrew its representation of Plaintiff, and

Plaintiff’s attorney individually entered a notice of appearance on Plaintiff’s behalf

on 12 May 2021.

¶5 On 25 August 2021, by which time Plaintiff still had not produced the

court-ordered discovery, Erie filed an Amended Motion for Sanctions or, in the

Alternative, to Dismiss for Failure to Prosecute, “pursuant to Rules 26, 33, 34, 37,

and 41 of the North Carolina Rules of Civil Procedure,” requesting “entry of an order

dismissing [Plaintiff’s] case as sanctions for failing to comply with the Court’s Order

to Compel Discovery or, in the alternative, to dismiss [Plaintiff’s] case for failure to

prosecute.” The trial court heard Erie’s motion on 27 September 2021. Plaintiff and

Erie argued at the hearing; neither Defendant nor USAA made an appearance at the

hearing.

¶6 By written order entered 28 October 2021 (“Dismissal Order”), the trial court

found, in pertinent part:

11. That as of the date of the hearing on September 27, 2021, [Plaintiff] had not served the unnamed defendant with any of the documents that he agreed to provide to the unnamed defendant in the March 24, 2021 Consent Order; 12. That at the hearing of this matter, [Plaintiff’s attorney] appeared and provided no evidence to the Court that he had attempted to obtain any of the documents that were agreed to in the March 24, 2021 Consent Order; 13. That [Plaintiff’s attorney] has willfully failed to comply with the March 24, 2021 Consent Order; ABDO V. JONES

14. That the Court has considered less severe sanctions than dismissal in ruling on these motions but believes dismissal appropriate as this matter [w]as handled by [Plaintiff’s attorney] in its entirety and he has willfully failed to comply. While understanding the file was perhaps under the supervision of another partner or attorney during its tenure with the [former law firm], all official actions have been signed and handled by [Plaintiff’s attorney]. Thus he has been aware at all times, even if he was subordinate while at the [former law firm]. He was certainly aware on May 12, when he filed his appearance with the Court.

Based on its findings, the trial court ordered that, “in the Court’s discretion and after

having considered less severe sanctions than dismissal, the unnamed defendant

Erie’s Motion for Sanctions is hereby GRANTED and that [Plaintiff’s] Complaint is

hereby dismissed with prejudice as to all defendants and unnamed defendants.”

Plaintiff timely appealed.

II. Discussion

¶7 Plaintiff argues the following: dismissal was not proper under Rule 37 because

Plaintiff was not engaged in systematic violations of court orders and lesser sanctions

were available; the trial court failed to make the requisite findings of fact to support

dismissal under Rule 41; and the trial court erred by dismissing Plaintiff’s complaint ABDO V. JONES

against Defendant and USAA.1

A. Rule 37

¶8 Rule 37 of the North Carolina Rules of Civil Procedure authorizes a trial court

to impose sanctions, including dismissal, upon a party that “fails to obey an order to

provide or permit discovery[.]” N.C. Gen. Stat § 1A-1, Rule 37(b)(2) (2021). “[T]rial

courts are vested with broad discretion in ordering sanctions under Rule 37(b).” GEA,

Inc. v. Luxury Auctions Mktg, Inc., 259 N.C. App. 443, 452, 817 S.E.2d 422, 429-30

(2018) (citation omitted). “Not only is the decision to impose Rule 37(b) sanctions

within the sound discretion of the trial court, but so too is the choice of Rule 37(b)

sanctions to impose.” Id. at 452, 817 S.E.2d at 430 (citation omitted).

¶9 “[B]efore dismissing a party’s claim with prejudice pursuant to Rule 37, the

trial court must consider less severe sanctions.” Hursey v. Homes by Design, Inc., 121

N.C. App. 175, 179, 464 S.E.2d 504, 507 (1995) (citing Goss v. Battle, 111 N.C. App.

173, 177, 432 S.E.2d 156, 159 (1993)). However, “[a] trial court is not required to list

and specifically reject each possible lesser sanction prior to determining that

dismissal is appropriate.” Honeycutt Contractors, Inc. v. Otto, 209 N.C. App. 180, 185,

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Related

White v. White
324 S.E.2d 829 (Supreme Court of North Carolina, 1985)
Goss v. Battle
432 S.E.2d 156 (Court of Appeals of North Carolina, 1993)
Hursey v. Homes by Design, Inc.
464 S.E.2d 504 (Court of Appeals of North Carolina, 1995)
Baker v. Rosner
677 S.E.2d 887 (Court of Appeals of North Carolina, 2009)
Honeycutt Contractors, Inc. v. Otto
703 S.E.2d 857 (Court of Appeals of North Carolina, 2011)
Gea, Inc. v. Luxury Auctions Mktg., Inc.
817 S.E.2d 422 (Court of Appeals of North Carolina, 2018)

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Abdo v. Jones, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abdo-v-jones-ncctapp-2022.