Happel v. Guilford Cnty. Bd. of Educ.

CourtCourt of Appeals of North Carolina
DecidedJune 17, 2026
Docket23-487-2
StatusPublished
AuthorJudge April Wood

This text of Happel v. Guilford Cnty. Bd. of Educ. (Happel v. Guilford Cnty. Bd. of Educ.) 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
Happel v. Guilford Cnty. Bd. of Educ., (N.C. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA23-487-2

Filed 17 June 2026

Guilford County, No. 22CVS007024-400

EMILY HAPPEL, individually, Tanner Smith, a minor, and EMILY HAPPEL on behalf of TANNER SMITH as his mother, Plaintiffs,

v.

GUILFORD COUNTY BOARD OF EDUCATION and OLD NORTH STATE MEDICAL SOCIETY, INC., Defendants.

On remand by majority opinion of the Supreme Court of North Carolina in

Happel v. Guilford Cnty. Bd. of Educ., 387 N.C. 186, 913 S.E.2d 174 (2025), affirming

in part, reversing in part, and remanding a published opinion by a unanimous panel

of the Court of Appeals in Happel v. Guilford Cnty. Bd. of Educ., 292 N.C. App. 563,

899 S.E.2d 387 (2024). The case originates from an appeal by plaintiff from an order

entered on 1 March 2023 by Judge Lora C. Cubbage in Superior Court, Guilford

County, granting defendant’s motion to dismiss. Originally heard in the Court of

Appeals on 28 November 2023.

Walker Kiger, PLLC, by David Steven Walker, for Plaintiffs-Appellants.

Tharrington Smith, LLP, by Stephen G. Rawson, for Guilford County Board of Education, Defendants-Appellees.

Rossabi Law Partners, by Gavin J. Reardon and Amiel J. Rossabi, for Old North State Medical Society, Inc., Defendants-Appellees.

WOOD, Judge.

This case returns on remand from the Supreme Court of North Carolina for HAPPEL V. GUILFORD CNTY. BD. OF EDUC.

Opinion of the Court

our consideration of whether Plaintiffs’ complaint sufficiently alleges constitutional

claims under the North Carolina Constitution. Specifically, our Supreme Court

remanded two questions for our consideration: (1) “whether plaintiffs’ complaint

sufficiently alleged that defendant [ONS Medical Society (“ONSMS”)] was a state

actor[;]” and (2) “whether plaintiffs have an adequate state remedy available for their

constitutional claims.” Happel v. Guilford Cnty. Bd. of Educ., 387 N.C. 186, 216, 913

S.E.2d 174, 198 (2025). We address these two issues as directed. After careful

consideration, we conclude Plaintiffs sufficiently alleged state constitutional claims

and remand this matter to the trial court for consideration of those claims.

I. Factual and Procedural History

On 14 August 2021, Tanner Smith (“Tanner”) was fourteen years old and a

football player at Western Guilford High School, a school within the Guilford County

Schools system. By letter dated 19 August 2021, Guilford County Schools informed

Emily Happel (“Emily”), Tanner’s mother, and Brett Happel (“Brett”), Tanner’s

stepfather, that Tanner may have been exposed to a “recent COVID-19 cluster”

involving football team members at his school and that the Guilford County Public

Health Department recommended and requested COVID-19 testing for individuals

potentially infected, regardless of vaccination status. The letter stated that unless

parents allowed their children to be tested, Guilford County Schools would not allow

the players “to return to practice until cleared by a public health professional.” The

letter further stated COVID-19 testing would be available on 20 August 2021 at no

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cost at Northwest Guilford High School, conducted by ONSMS and “consent for

testing is required.” In addition to COVID-19 testing, ONSMS also administered

COVID-19 Vaccinations at the Northwest Guilford High School site.

On 20 August 2021, Brett drove Tanner to the testing site at Northwest

Guilford High School. Brett remained inside his vehicle while Tanner went into the

testing facility. Once inside, clinic workers gave Tanner a form to fill out, which he

believed to be something related to the COVID-19 test. While Tanner sat in the

waiting area, a clinic worker tried unsuccessfully to contact Emily by phone to obtain

consent for ONSMS to administer a COVID-19 vaccine to him. Clinic workers did

not attempt to contact Brett, who waited outside in his car, to obtain permission to

administer the COVID-19 vaccine to Tanner. After failing to reach Tanner’s mother

by phone, one of the clinic workers instructed the other clinic worker to “give it to him

anyway.” Tanner stated he did not want a vaccine and was only there to be tested;

however, one of the clinic workers administered a Pfizer COVID-19 vaccine to him

over his objection and without parental consent.

Plaintiffs initiated this lawsuit on 19 August 2022, alleging three causes of

action: (1) battery; (2) violations of Emily’s constitutional liberty and parental rights,

and of Tanner’s bodily autonomy rights under N.C. Const. art. I, §§ 1, 13, and 19; and

(3) violations of both Plaintiffs’ federal constitutional rights. On 21 November 2022,

the Guilford County Board of Education (“Board”) filed its answer, a motion to

dismiss pursuant to Rules 12(b)(1) and (6), and a cross-claim against ONSMS. On

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30 December 2022, ONSMS filed its answer and a motion to dismiss pursuant to

Rules 12(b)(1) and (6).

The trial court held a hearing on 30 January 2023. On 1 March 2023, the trial

court entered an order dismissing Plaintiffs’ complaints as to both Defendants. On 9

March 2023, Plaintiffs filed timely written notice of appeal pursuant to N.C. Gen.

Stat. § 7A-27(b). On appeal, Plaintiffs abandoned their federal constitutional claims,

appealing only their individual state constitution claims and the battery claim. This

Court affirmed the trial court’s ruling on both claims based on the broad scope of

immunity provided by the PREP Act. Happel v. Guilford Cnty. Bd. of Educ., 292 N.C.

App. 563, 571-72, 899 S.E.2d 387, 394 (2024).

Our Supreme Court granted discretionary review pursuant to N.C. Gen. Stat.

§ 7A-31 and issued an opinion on 21 March 2025. Happel v. Guilford Cnty. Bd. of

Educ., 387 N.C. 186, 913 S.E.2d 174 (2025). The Supreme Court affirmed this Court’s

holding as to the trial court’s dismissal of Plaintiffs’ tort claim for battery based on

the immunity provided by the PREP Act. Id. at 216, 913 S.E.2d at 198. However,

the Supreme Court reversed this Court’s holding as to the trial court’s dismissal of

the state constitutional claims stating, “[t]he PREP Act’s plain text leads us to

conclude that its immunity only covers tort injuries. Because tort injuries are not

constitutional violations, the PREP Act does not bar plaintiffs’ constitutional claims.”

Id. at 187-88, 913 S.E.2d at 180. The Supreme Court remanded the matter to this

Court for our consideration of whether Plaintiffs’ complaint sufficiently alleges

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constitutional claims under our state’s constitution.

II. Analysis

Where there is a right, there is a remedy. This is a foundational principle of every common law legal system, including ours. We have long called it a time-honored maxim. It is even enshrined in the North Carolina Constitution. To protect this principle—to ensure that every right does indeed have a remedy in our court system—this Court created what are known as ‘Corum claims.’

Washington v. Cline, 385 N.C. 824, 825, 898 S.E.2d 667, 668-69 (2024) (cleaned up)

(citing Corum v. Univ. of N.C., 330 N.C. 761, 413 S.E.2d 276 (1992)).

In order to allege a sufficient Corum claim three criteria must be met: (1) the

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