Lucas v. Childress

CourtCourt of Appeals of North Carolina
DecidedOctober 15, 2025
Docket25-227
StatusPublished

This text of Lucas v. Childress (Lucas v. Childress) 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
Lucas v. Childress, (N.C. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-227

Filed 15 October 2025

Mecklenburg County, No. 23CVS010275-590

ALAN RAY LUCAS, Plaintiff,

v.

VIRGINIA BRADLEY CHILDRESS, an individual, Defendant.

Appeal by Defendant from order entered 27 August 2024 by Judge Hugh B.

Lewis in Mecklenburg County Superior Court. Heard in the Court of Appeals 28

August 2025.

Law Office of Habekah B. Cannon, PLLC, by Habekah B. Cannon, for Plaintiff-Appellee.

Poyner Spruill LLP, by J. Nicholas Ellis and Sydney P. Davis, for Defendant-Appellant.

COLLINS, Judge.

This appeal arises out of a defamation lawsuit instituted by Plaintiff Alan Ray

Lucas against Defendant Virginia Bradley Childress. Defendant appeals from the

trial court’s interlocutory order denying her motion for summary judgment.

Defendant argues that her appeal is properly before this Court because the trial

court’s order affects a substantial right and that the trial court erred in various ways

by denying her motion for summary judgment. Because Defendant has failed to show

that the interlocutory order denying her motion for summary judgment affects a LUCAS V. CHILDRESS

Opinion of the Court

substantial right, we dismiss Defendant’s appeal.

I. Background

Defendant’s father, John Roger Bradley, was killed in the early morning hours

of 8 May 1992. On 30 July 1993, Plaintiff was arrested and charged with Bradley’s

murder, conspiracy to commit robbery with a dangerous weapon, and robbery with a

dangerous weapon. A Wilson County grand jury later returned true bills of

indictment against Plaintiff on those charges.

On 7 February 1995, Plaintiff pled guilty to four counts of second-degree

burglary for events not related to Bradley’s murder and was sentenced to 86 years’

imprisonment. That same day, the charges against Plaintiff stemming from

Bradley’s murder were dismissed because he agreed to plead guilty to four counts of

second-degree burglary and the “evidence in this case not strong enough to sustain a

conviction.”

Approximately twenty-seven years later, on or around 7 July 2022, Plaintiff

was released on parole. That same day, The Wilson Times published an article on the

Restoration NewsMedia website titled “Wilson man’s killer released on parole after

30 years” that included the following statements made by Defendant:

We have fought many years to keep [Plaintiff] in prison for his role in Dad’s murder.

....

Even though he is being paroled to another county, hours away from Wilson, we still must live with the fact that he

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is out there . . . enjoying life’s milestones like weddings, births and birthdays. There is that chance that one day, I could sit down in a restaurant, walk down an aisle in a store, look next to me at a stop light and I could be looking into the eyes of the man that took away my father’s life. (ellipses in original).

The same article, entitled “Murder convict paroled,” was published on the front page

of The Wilson Times on 8 July 2022. The article was retracted and corrected, and an

apology was issued, on 23 November 2022.

Plaintiff commenced this action by filing a complaint on 20 June 2023 against

Defendant, The Wilson Times reporter Janelle Clevinger, and Restoration

NewsMedia LLC. In the complaint, Plaintiff alleges “defamation libel per se” and

“malice.” Clevinger and Restoration NewsMedia filed a motion to dismiss pursuant

to North Carolina Rules of Civil Procedure 12(b)(2), (4), and (5). Defendant filed a

motion to dismiss for failure to state a claim upon which relief can be granted

pursuant to Rule 12(b)(6). The trial court granted Clevinger and Restoration

NewsMedia’s motion to dismiss for issues related to improper service; the trial court

denied Defendant’s motion to dismiss.

Defendant filed her answer and affirmative defenses, and on 10 July 2024,

Defendant filed a motion for summary judgment. After a hearing, the trial court

entered a written order denying Defendant’s motion for summary judgment.

Defendant appeals.

-3- LUCAS V. CHILDRESS

II. Appellate Jurisdiction

Defendant appeals from an interlocutory order. “An order or judgment is

interlocutory if it is made during the pendency of an action and does not dispose of

the case but requires further action by the trial court in order to finally determine

the entire controversy.” N.C. Dept. of Transp. v. Page, 119 N.C. App. 730, 733 (1995)

(citation omitted). As a general rule, there is no right of immediate appeal from an

interlocutory order. Jeffreys v. Raleigh Oaks Joint Venture, 115 N.C. App. 377, 379

(1994). “The reason for this rule is to prevent fragmentary, premature[,] and

unnecessary appeals by permitting the trial court to bring the case to final judgment

before it is presented to the appellate courts.” Fraser v. Di Santi, 75 N.C. App. 654,

655 (1985) (citation omitted).

However, a party may immediately appeal an interlocutory order under certain

circumstances, including “when the order deprives the appellant of a substantial

right which would be jeopardized absent a review prior to a final determination on

the merits.” Jeffreys, 115 N.C. App. at 379 (quotation marks and citations omitted).

Such a determination “usually depends on the facts and circumstances of each case

and the procedural context of the orders appealed from.” Estrada v. Jaques, 70 N.C.

App. 627, 642 (1984) (citation omitted).

The burden rests on the appellant to establish the deprivation of a substantial

right as the basis for an interlocutory appeal. Dailey v. Popma, 191 N.C. App. 64, 68

(2008). Accordingly, the appellant must include in her opening brief a “statement of

-4- LUCAS V. CHILDRESS

the grounds for appellate review” containing “sufficient facts and argument to

support appellate review on the ground that the challenged order affects a substantial

right.” N.C. R. App. P. 28(b)(4); see Beroth Oil Co. v. N.C. Dep’t of Transp., 256 N.C.

App. 401, 411 (2017) (emphasizing that an appellant generally “must present more

than a bare assertion that the order affects a substantial right; they must

demonstrate why the order affects a substantial right”) (cleaned up).

In her Statement of the Grounds for Appellate Review, Defendant

acknowledges that she appeals from an interlocutory order and correctly sets forth

relevant law. This Court has held that “[a]n order implicating a party’s First

Amendment rights affects a substantial right.” Sherrill v. Amerada Hess Corp., 130

N.C. App. 711, 719 (1998) (citation omitted). We have also “recognized, when

considering a motion for summary judgment, a misapplication of the actual malice

standard could have a chilling effect on a defendant’s right to free speech and

implicates a substantial right.” Topping v. Meyers, 270 N.C. App. 613, 617-18 (2020)

(citation omitted).

Defendant then asserts, without supporting facts or argument, that “th[is]

interlocutory appeal based on the misapplication of the actual malice standard is

properly before this Court.” This “bare assertion” fails to allege, much less

demonstrate, how the trial court misapplied the actual malice standard in this case

such that her First Amendment rights were implicated. See Beroth Oil Co., 256 N.C.

App. at 411.

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Related

New York Times Co. v. Sullivan
376 U.S. 254 (Supreme Court, 1964)
Estrada v. Jaques
321 S.E.2d 240 (Court of Appeals of North Carolina, 1984)
Dailey v. Popma
662 S.E.2d 12 (Court of Appeals of North Carolina, 2008)
Fraser v. Di Santi
331 S.E.2d 217 (Court of Appeals of North Carolina, 1985)
Gaunt v. Pittaway
534 S.E.2d 660 (Court of Appeals of North Carolina, 2000)
North Carolina Department of Transportation v. Page
460 S.E.2d 332 (Court of Appeals of North Carolina, 1995)
Jeffreys v. Raleigh Oaks Joint Venture
444 S.E.2d 252 (Court of Appeals of North Carolina, 1994)
Sherrill v. Amerada Hess Corp.
504 S.E.2d 802 (Court of Appeals of North Carolina, 1998)
Beroth Oil Co. v. N.C. Dep't of Transp.
808 S.E.2d 488 (Court of Appeals of North Carolina, 2017)

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Lucas v. Childress, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lucas-v-childress-ncctapp-2025.