Leech v. State of N.C.

CourtCourt of Appeals of North Carolina
DecidedOctober 1, 2025
Docket24-1113
StatusPublished

This text of Leech v. State of N.C. (Leech v. State of N.C.) 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
Leech v. State of N.C., (N.C. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-1113

Filed 1 October 2025

Person County, No. 23CVS000396-720

SEANPATRICK LEECH, Plaintiff,

v.

STATE OF NORTH CAROLINA, JOSHUA STEIN, in his official capacity as Attorney General of the State of North Carolina, PHILIP BERGER, in his official capacity as President Pro Tempore of the North Carolina Senate, TIMOTHY MOORE, in his official capacity as Speaker of the North Carolina House of Representatives, and MICHAEL WATERS, in his official capacity as District Attorney for the Eleventh Prosecutorial District of North Carolina, Defendants.

Appeal by Plaintiff from order entered 3 June 2024 by Judge Edwin G. Wilson,

Jr. in Person County Superior Court. Heard in the Court of Appeals 13 August 2025.

Ellis & Winters LLP, by Jeffrey S. Warren, Jonathan D. Sasser, Michelle A. Liguori, and Tyler C. Jameson, for the Plaintiff.

Attorney General Jeff Jackson, by Special Deputy Attorney General, Elizabeth Curran O’Brien, for Michael Waters; and Special Deputy Attorney General Michael E. Bulleri, for Philip Berger and Timothy Moore, Defendants- Appellees.

WOOD, Judge.

SeanPatrick Leech (“Plaintiff”) appeals from an order granting Motions to

Dismiss for defendant Michael Waters (“Defendant Waters”) and defendants State of

N.C., Joshua Stein, Philip Berger, and Timothy Moore (collectively “State

Defendants”). On appeal, Plaintiff raises three issues, (1) did the trial court err in LEECH V. STATE OF N.C.

Opinion of the Court

considering the Affidavit of Defendant Waters and other evidence outside the

pleadings when ruling on Defendant’s Motion to Dismiss; (2) did the trial court err in

granting Defendant Water’s Motion to Dismiss for failure to state a claim pursuant

to Rule 12(b)(6); and (3) did the trial court err in granting the State Defendants’

Motion to Dismiss pursuant to Rule 12(b)(6). After careful review of the record, we

vacate the trial court’s order and remand for rehearing.

I. Factual and Procedural Background

The following facts are alleged in Plaintiff’s complaint. In April 2021, the

Roxboro Police Department (“RPD”) received a 911 call about a rape in progress. The

RPD dispatched an officer to the home of the alleged victim to investigate. The officer

arrested the suspect at the scene, and the victim left the home. When the alleged

victim returned home a few days later, she found a boxcutter in her bedroom that she

did not recognize. She called RPD to report what she found, and RPD sent Plaintiff

to interview the victim. Multiple times the victim denied the boxcutter was used

during the alleged rape and stated she did not know from where the boxcutter came.

Plaintiff returned to his patrol car and called his supervisor (“Sergeant”) to explain

the situation. Plaintiff told Sergeant he intended to dispose of the boxcutter if the

original investigating officer confirmed there was no report of a boxcutter during the

rape. According to Plaintiff, Sergeant approved his plan. Plaintiff then met with the

responding officer who confirmed the findings in the report, also denying that a

boxcutter was used in the rape. Having confirmed that a boxcutter was not used

-2- LEECH V. STATE OF N.C.

during the alleged rape nor listed as evidence, Plaintiff disposed of it. Plaintiff did

not knowingly dispose of evidence.

Approximately one week after Plaintiff disposed of the boxcutter, the District

Attorney’s (“DA”) office contacted RPD seeking photographs of the boxcutter.

Plaintiff immediately explained the situation and his disposal of the boxcutter.

On 25 May 2021, the RPD began an internal affairs investigation. Plaintiff

fully cooperated with the investigation and accepted responsibility for his actions. He

was not deceitful or misleading.

On 26 July 2021, Defendant Waters, the District Attorney, informed Plaintiff

that his office was investigating potential impeachment evidence within the meaning

of Giglio v. United States. Defendant Waters met with Plaintiff but did not disclose

what evidence, if any, was under consideration in his Giglio determination.

According to Plaintiff, Defendant Waters did not inform Plaintiff that anyone had

accused him of dishonesty or indicated he believed Plaintiff was being dishonest.

On 26 September 2021, Defendant Waters sent a Giglio letter to Plaintiff

which stated the DA’s office would “no longer be able to use [Plaintiff] as a witness

for the State of North Carolina in any criminal or traffic case.” Defendant Waters

also sent the letter to Plaintiff’s employer, RPD. The basis stated for the letter was,

(1) Plaintiff mishandled potential evidence in a felony prosecution, and (2) when confronted, identified a fellow officer who reportedly advised that if not used in the crime, disposing of the boxcutter was permissible. The fellow officer denies

-3- LEECH V. STATE OF N.C.

the assertion in any conversation. This assertion by [Plaintiff] is not corroborated by other evidence and this dishonesty has implication beyond the destruction of the boxcutter.

Defendant Waters identified Sergeant as the “other officer.” This assertion of

dishonesty conflicted with the findings of the internal affairs investigation which

determined only “that there was an inconsistency in [Plaintiff’s] and [Sergeant’s]

statement[s].” According to Plaintiff, Sergeant’s statements conflicted during the

investigations. First, Sergeant “denied having a phone call conversation with

[Plaintiff] . . . about the agreement to ‘scrap’ the [boxcutter].” Then, Sergeant changed

his story stating, he “did not recall discussing approval to ‘scrap’ the [boxcutter].”

At the time Defendant Waters published the Giglio letter Plaintiff was not

involved with any current judicial proceedings or criminal processes and there was

no way for Defendant Waters to know whether Plaintiff’s alleged conduct could

“negate the guilt of the accused or mitigate the offense.” Defendant Waters offered no

explanation for how Plaintiff’s conduct would trigger a blanket Brady1 or Giglio2

obligation in the future.

1 Under Brady v. Maryland, 373 U.S. 83, 87, 83 S.Ct. 1194, 1196–97, 10 L.Ed.2d 215, 218

(1963) prosecution has an obligation to disclose evidence favorable to the defense where the evidence is material either to guilt or to punishment. This includes impeachment evidence against government witnesses as well as exculpatory evidence. United States v. Bagley, 473 U.S. 667, 676, 105 S.Ct. 3375, 3380, 87 L.Ed.2d 481, 490 (1985).

2 Giglio created the obligation for prosecutors to disclose evidence that could affect the

credibility of its witnesses even if that evidence is with another prosecutor. Giglio v. United States, 405 U.S. 150, 154, 92 S.Ct. 763, 766, 31 L.Ed.2d 104, 109 (1972).

-4- LEECH V. STATE OF N.C.

On 27 September 2021, Plaintiff received Notice of Pre-Disciplinary

Conference from the RPD which indicated that “based on the findings of each

allegation below, and specifically Allegation 4, Giglio, the recommended disciplinary

action is termination.” The notice explained that Plaintiff had two options: face

termination, which would result in the generation of a public record explaining the

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Giglio v. United States
405 U.S. 150 (Supreme Court, 1972)
United States v. Bagley
473 U.S. 667 (Supreme Court, 1985)
Poor Richard's, Inc. v. Stone
366 S.E.2d 697 (Supreme Court of North Carolina, 1988)
Oberlin Capital, L.P. v. Slavin
554 S.E.2d 840 (Court of Appeals of North Carolina, 2001)
Coley v. North Carolina National Bank
254 S.E.2d 217 (Court of Appeals of North Carolina, 1979)
Weaver v. Saint Joseph of the Pines, Inc.
652 S.E.2d 701 (Court of Appeals of North Carolina, 2007)
In Re WBM
690 S.E.2d 41 (Court of Appeals of North Carolina, 2010)
Jenkins v. Batts
788 S.E.2d 628 (Court of Appeals of North Carolina, 2016)
Ballard v. Shelley
811 S.E.2d 603 (Court of Appeals of North Carolina, 2018)
Holton v. Holton
813 S.E.2d 649 (Court of Appeals of North Carolina, 2018)
In re W.B.M.
202 N.C. App. 606 (Court of Appeals of North Carolina, 2010)
Horne ex rel. Heintzelman v. Town of Blowing Rock
732 S.E.2d 614 (Court of Appeals of North Carolina, 2012)
Lipinski v. Town of Summerfield
750 S.E.2d 46 (Court of Appeals of North Carolina, 2013)

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