Bounds v. Russell

CourtCourt of Appeals of North Carolina
DecidedJuly 1, 2026
Docket25-729
StatusUnpublished
AuthorJudge Tom Murry

This text of Bounds v. Russell (Bounds v. Russell) 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
Bounds v. Russell, (N.C. Ct. App. 2026).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-729

Filed 1 July 2026

Polk County, No. 23 CVS 000206-740

HEATHER BOUNDS, Plaintiff,

v.

JOHN VICTOR RUSSELL, Defendant.

Appeal by Defendant from judgment entered 12 February 2025 by Judge

Daniel A. Kuehnert in Polk County Superior Court. Heard in the Court of Appeals 12

February 2026.

Allen Stahl & Kilbourne, PLLC, by Matthew J. Giangrosso, Christopher G. Lewis, James K. Kilbourne, Jr., & Derek J. Allen, for Plaintiff–Appellee.

Lindsay Law, PLLC, by Stephen P. Lindsay, for Defendant–Appellant.

PER CURIAM.

John V. Russell (Defendant) appeals a jury verdict finding him liable to

Heather Bounds (Plaintiff) for $100,000 each in compensatory and punitive damages

plus interest. He argues that the trial court erred (1) by not joining ex mero motu a

purported “Bounds–Russell Partnership” as a necessary party to Plaintiff’s action BOUNDS V. RUSSELL

Opinion of the Court

and (2) by granting Plaintiff’s motion to strike Defendant’s supporting affidavit before

trial. For the reasons below, this Court affirms the trial court on both counts.

I. Background

This is a horse dispute of a different color. On 5 July 2023, Defendant shot a

horse during an altercation with his son Lincoln Russell. At some point prior to this

altercation, Lincoln and Plaintiff entered into an agreement whereby she would

purchase “Harry,” a well-bred racehorse, for $70,000 so that Lincoln could train and

showcase it on the racing circuit. If the horse successfully sold, Lincoln would receive

a 10% commission of its gross proceeds and reimbursement for his documented

training fees up to that point. He stored the horse at Defendant’s Columbus, N.C.

farmhouse in the meantime.

Later on 5 July 2023, Defendant arrived at the farm to find an agitated Lincoln

working with the horse. Accounts differ as to the exact chain of events at this point,

but Defendant eventually found himself pinned to his car near the horse. His gun

discharged in the scuffle, fatally injuring it. Lincoln and Defendant then called a local

veterinarian to euthanize the horse to relieve its suffering.

On 31 August 2023, Plaintiff filed a complaint alleging that Defendant

converted and negligently killed the horse, and that she suffered emotional distress

as a result. She also sought punitive damages. Pretrial discovery ensued, with

Defendant responding to depositions and interrogatories with a mix of substantive

responses and Fifth Amendment invocations. Plaintiff then moved for summary

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judgment based on these discovery materials, to which Defendant then responded

with an affidavit he would later characterize at the hearing as an articulation of the

“sudden[-]emergency doctrine.”

At this 22 July 2024 hearing, Plaintiff orally moved to strike that affidavit and

served the motion on Defendant a week later. Although the trial court found enough

materially disputed facts to preclude summary judgment, it granted Plaintiff’s

motion to strike because “Defendant [had] strategically invoked his Fifth Amendment

privilege and the shield it provided in response to Plaintiff’s discovery requests and

the deposition questioning.” The dispute proceeded to a full jury trial, which found

Defendant liable to Plaintiff for $100,000 each in compensatory and punitive damages

resulting from the shooting. Defendant timely appealed this verdict on the

aforementioned grounds.

II. Jurisdiction

This Court has jurisdiction to hear Defendant’s appeal of the trial court’s

judgment because it is the “final judgment of a superior court.”1 N.C.G.S.

§ 7A-27(b)(1) (2025).

1 Defendant also asserts that the trial court lack the subject-matter jurisdiction to preside over the trial in the first instance because the purported “Bounds–Russell Partnership” rendered Lincoln Russell a necessary party to Plaintiff’s action. Although he may raise this sort of claim “for the first time on appeal,” Plaintiff’s “failure to join a necessary party does not result in a lack of” subject-matter jurisdiction per se. Stancil v. Bruce Stancil Refrig’n, Inc., 81 N.C. App. 567, 573–74 (1986) (first citing N.C. R. Civ. P. 12(h)(3); and then citing 5 Wright & Miller’s Federal Practice & Procedure § 1359 (1st ed. 1969)). Because the “failure to join a party under Rule 19 is not a

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III. Analysis

On appeal, Defendant argues that the trial court erred (1) by failing to join the

purported “Bounds–Russell Partnership” to Plaintiff’s action before proceeding to

trial and (2) by granting Plaintiff’s motion to strike his affidavit despite previously

“la[ying] down [his F]ifth [A]mendment shield.” We review a trial court’s initial

joinder-propriety assessment only for an abuse of “sound discretion,”2 Crosrol

Carding Devs., Inc. v. Gunter & Cooke, Inc., 12 N.C. App. 448, 451 (1971), but review

questions of legal and constitutional magnitude de novo, see Herndon v. Herndon, 368

N.C. 826, 829 (2016). Based on these considerations and the reasons below, we

disagree with Defendant on both issues and thus affirm the trial court.

A. Partnership Joinder

First, Defendant argues that his son and Plaintiff formed a “Bounds–Russell

Partnership” necessary for this lawsuit to proceed to trial in the first instance. He

suggests that this alleged partnership—and not Plaintiff herself—owned the

racehorse de jure, thus requiring the partnership’s procedural joinder to her

complaint. But Defendant did not raise it as an issue “at the trial on the merits” at

any point whatsoever, N.C. R. Civ. P. 12(h)(2), and only “raise[s] the issue for the first

jurisdictional matter,” we reject this particular claim and instead hold that the trial court had the subject-matter jurisdiction to hear Plaintiff’s action. Id. (quotation omitted).

2 By “joinder propriety,” we mean only the decision of whether to join a proper party to a particular action. We do not contest a trial court’s blackletter lack of “discretion as to whether to add a necessary party.” Wenninger v. Wenninger, 293 N.C. App. 791, 795 (emphasis added), petition for discr’y rev. denied, 386 N.C. 960 (2024).

-4- BOUNDS V. RUSSELL

time” here, Stancil v. Bruce Stancil Refrig’n, Inc., 81 N.C. App. 567, 574 (1986). We

decline to reach the merits of this unpreserved issue and dismiss it as a result. See

N.C. R. Civ. P. 10(a)(1).

B. Fifth Amendment Shield

Second, Defendant argues that the trial court erred by striking his pretrial

affidavit in response to his previous invocation of the Federal Fifth Amendment right

against self-incrimination. We disagree. Defendant mischaracterizes a discretionary

ruling on trial evidence as a constitutional claim. He also failed to raise this issue at

trial. See id.

We review constitutional claims de novo, see Herndon, 368 N.C. at 829, but

witness-testimony claims only for an abuse of the trial court’s “wide latitude of

discretion when making a determination about the admissibility of expert testimony,”

State v. Bullard, 312 N.C.

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Related

State v. Hennis
372 S.E.2d 523 (Supreme Court of North Carolina, 1988)
State v. Bullard
322 S.E.2d 370 (Supreme Court of North Carolina, 1984)
Crosrol Carding Developments, Inc. v. Gunter & Cooke, Inc.
183 S.E.2d 834 (Court of Appeals of North Carolina, 1971)
Stancil v. Bruce Stancil Refrigeration, Inc.
344 S.E.2d 789 (Court of Appeals of North Carolina, 1986)
Herndon v. Herndon
785 S.E.2d 922 (Supreme Court of North Carolina, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Bounds v. Russell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bounds-v-russell-ncctapp-2026.