Alexander v. NC State Bd. of Elections

CourtCourt of Appeals of North Carolina
DecidedFebruary 1, 2022
Docket21-77
StatusPublished

This text of Alexander v. NC State Bd. of Elections (Alexander v. NC State Bd. of Elections) 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
Alexander v. NC State Bd. of Elections, (N.C. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2022-NCCOA-52

No. COA 21-77

Filed 1 February 2022

Wake County, No. 19 CVS 11321

KELLY ALEXANDER, Jr., DONALD R. CURETON, Jr., ALICIA D. BROOKS, KIMBERLY Y. BEST, LAURENE L. CALLENDER, and LATRICIA H. WARD, Plaintiffs,

v.

NORTH CAROLINA STATE BOARD OF ELECTIONS, STELLA ANDERSON, JEFF CARMON III, STACY EGGERS IV, WYATT T. TUCKER, Sr., DAMON CIRCOSTA, KAREN BRINSON BELL, PHILLIP E. BERGER, and TIMOTHY K. MOORE (all in official capacities only), Defendants.

Appeals by plaintiffs from order entered 25 September 2020 and by defendants

from order entered 23 November 2020 by Judges Wayland J. Sermons, Jr., Lora C.

Cubbage, and R. Gregory Horne in Wake County Superior Court. Heard in the Court

of Appeals 3 November 2021.

Higgins Benjamin, PLLC, by Robert Neal Hunter, Jr., for Plaintiffs.

Attorney General Joshua H. Stein, by Special Deputy Attorney General Paul M. Cox, for State Board Defendants.

Ogletree Deakins Nash Smoak & Stewart P.C., by Thomas A. Farr, for Legislative Defendants.

CARPENTER, Judge.

¶1 Kelly Alexander, et al., (“Plaintiffs”) appeal pursuant to N.C. Gen. Stat. § 7A- ALEXANDER V. NC STATE BOARD OF ELECTIONS

Opinion of the Court

27 from an order of a three-judge panel in Wake County Superior Court dismissing

Plaintiffs’ claims as moot. On appeal, Plaintiffs argue their claims are not moot or,

in the alternative, that their claims fall into the public interest and “capable of

repetition, yet evading review” exceptions to mootness. The North Carolina State

Board of Elections, et al., (“Defendants”) appeal pursuant to N.C. Gen. Stat. § 7A-

27(b)(3)(c) (2019) from an order granting Plaintiffs attorney’s fees. On appeal,

Defendants argue the three-judge panel did not have jurisdiction to grant the award

or, in the alternative, that Plaintiffs do not qualify as a prevailing party under 42

U.S.C. § 1988. After careful review, we affirm the three-judge panel’s dismissal of

Plaintiffs’ claims as moot and hold the claims do not meet any exceptions to the

mootness doctrine. We agree with Defendants’ contention the three-judge panel

lacked jurisdiction to grant Plaintiffs’ request for attorney’s fees, and we vacate and

remand this order.

I. Factual and Procedural Background

¶2 In 2018, the North Carolina General Assembly enacted a law that converted

district court judicial elections in Mecklenburg County from countywide to district-

based elections. See S.L. 2018-14 § 2(a). The law divided Mecklenburg County into

eight districts, and the county’s twenty-one district court seats were allocated

amongst these eight electoral districts. Id. Previously, all twenty-one seats were

filled through a single countywide election. The law also divided Wake County into ALEXANDER V. NC STATE BOARD OF ELECTIONS

districts for district court judicial elections; however, no challenge was raised to that

portion of the law.

¶3 Plaintiffs, at time of filing, were: two district court judges, a former district

court judge, a member of the General Assembly, and two voters. All Plaintiffs resided

in Mecklenburg County. The complaint named as defendants the Governor of North

Carolina (“Governor”), the North Carolina State Board of Elections and its appointed

members, the Speaker of the North Carolina House of Representatives, and the

President Pro Tempore of the North Carolina Senate (collectively, “Defendants”). The

Governor and Defendants moved to dismiss the claims against them. The trial court

granted the Governor’s motion to dismiss and denied Defendants’ motions in an order

entered on 18 November 2019. The trial court’s order also transferred the case to a

three-judge panel in Wake County Superior Court pursuant to N.C. Gen. Stat. § 1-

267.1 and Rule 42(b)(4) of the North Carolina Rules of Civil Procedure.1

¶4 On 20 November 2019, Plaintiffs moved for a temporary restraining order

seeking to enjoin operation of S.L. 2018-14 § 2(a) during candidate filing, set to begin

on 2 December 2019, in anticipation of the 2020 general election. The three-judge

panel held a hearing on Plaintiffs’ motion on 22 November 2019. Following the

1 When a trial court transfers a facial challenge raised as to the validity of a statute

to a three-judge panel sitting in Wake County Superior Court, the trial court retains jurisdiction of all other collateral matters pending resolution of the facial challenge. See N.C. R. Civ. P. 42(b)(4) (2019). ALEXANDER V. NC STATE BOARD OF ELECTIONS

hearing, the parties entered an agreement to temporarily suspend the operation of

the law during the 2020 general election cycle, and the three-judge panel entered a

consent order formalizing the agreement on 27 November 2019.

¶5 On 1 July 2020, the General Assembly repealed the challenged law. See S.L.

2020-84, § 2. In response, on 13 July 2020, the three-judge panel ordered the parties

to submit briefs detailing what issues, if any, remained in the matter. On 11 August

2020, Plaintiffs moved for summary judgment, seeking a declaratory judgment

stating the repealed law had been unlawful. On 21 August 2020, Plaintiffs moved to

tax costs and fees against Defendants. Defendants submitted briefs arguing

Plaintiffs’ claims were moot. On 25 September 2020, the three-judge panel entered

an order denying the motion for declaratory judgment and dismissing Plaintiffs’

claims as moot but reserving the issue of attorney’s fees. Plaintiffs filed written notice

of appeal on 23 October 2020. On 23 November 2020, the three-judge panel entered

an order granting Plaintiffs’ motion for attorney’s fees and costs in the amount of

$165,114.44. Defendants filed notice of appeal.

II. Jurisdiction

¶6 Plaintiffs appeal from a final order dismissing their claims as moot pursuant

to N.C. Gen. Stat. § 7A-27 (2019). Defendants appeal from an order awarding

attorney’s fees, pursuant to N.C. Gen. Stat. § 7A-27(b)(1) (2019) or, in the alternative,

N.C. Gen. Stat. § 7A-27(b)(3)(c). ALEXANDER V. NC STATE BOARD OF ELECTIONS

¶7 Plaintiffs argue the three-judge panel’s order awarding attorney’s fees is

interlocutory and does not affect a substantial right, thereby rendering Defendants’

appeal improper. Defendants argue the order granting attorney’s fees is final, as it

resolved the only outstanding matter left in the case or, alternatively, if held to be

interlocutory, the order affects a substantial right. We disagree with Plaintiffs and

find the order is not interlocutory having resolved the issue of attorney’s fees, the sole

remaining issue between the parties. We therefore deny Plaintiffs’ motion to dismiss

Defendants’ cross appeal.

¶8 An order is interlocutory if it does not determine the issues but directs some

further proceeding preliminary to a final decree. Waters v. Qualified Pers., Inc., 294

N.C. 200, 207, 240 S.E.2d 338, 343 (1978). Moreover, “an order that completely

decides the merits of an action constitutes a final judgment for purposes of appeal

even when the trial court reserves for later determination collateral issues such as

attorney’s fees and costs.” In re Cranor, 247 N.C. App. 565, 568-69, 786 S.E.2d 379,

382 (2016) (quoting Duncan v. Duncan, 366 N.C.

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