Ross v. N.C. Dep't of Adult Corr.

CourtCourt of Appeals of North Carolina
DecidedJanuary 21, 2026
Docket24-920
StatusUnpublished
AuthorJudge Christopher Freeman

This text of Ross v. N.C. Dep't of Adult Corr. (Ross v. N.C. Dep't of Adult Corr.) 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
Ross v. N.C. Dep't of Adult Corr., (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An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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. COA24-920

Filed 21 January 2026

North Carolina Industrial Commission, I.C. No. TA-26268

DANIEL HUBERT ROSS, Plaintiff,

v.

NORTH CAROLINA DEPARTMENT OF ADULT CORRECTION, FORMERLY A PART OF THE NORTH CAROLINA DEPARTMENT OF PUBLIC SAFETY, AND THE NORTH CAROLINA STATE BUREAU OF INVESTIGATION, Defendants.

Appeal by plaintiff from decision and order entered 17 April 2024 by the Full

Commission in the North Carolina Industrial Commission. Heard in the Court of

Appeals 21 May 2025.

Law Office of Barry Nakell, by Barry Nakell, for plaintiff.

Attorney General Jeff Jackson, by Assistant Attorney General Daniel J. Burke, for defendants.

FREEMAN, Judge.

Plaintiff Daniel Ross appeals from a decision and order by the Full Commission

of the North Carolina Industrial Commission denying Ross’s claims of negligence

against the North Carolina Department of Public Safety (“DPS”) and the North ROSS V. N.C. DEP’T OF ADULT CORR.

Opinion of the Court

Carolina State Bureau of Investigation (“SBI”). Because Ross failed to challenge

relevant factual findings and conclusions of law on appeal related to SBI, and failed

to allege the required elements of negligence against DPS, we affirm.

I. Factual and Procedural Background

Ross “was convicted of first-degree murder in 1969.” Ross v. N.C. State Bureau

of Investigation, No. COA17-794, 259 N.C. App. 424, 2018 WL 2016405, at *1 (May 1,

2018) (unpublished) (hereinafter “Ross I”). “The Fourth Circuit Court of Appeals set

[Ross’s] conviction aside, declaring it null and void, in 1983.” Id.; see Ross v. Reed,

704 F.2d 705, 709 (4th Cir. 1983). The following year, “[t]he United States Supreme

Court affirmed the Fourth Circuit’s ruling in Reed v. Ross, 468 U.S. 1, 82 L.Ed.2d 1

(1984).” Ross I, 2018 WL 2016405, at *1. On 1 June 1983, the Eastern District of

North Carolina entered an order issuing a writ of habeas corpus, setting aside Ross’s

conviction as “null and void,” and “of no legal effect.” Ross v. Reed, No. 78–62–HC,

order at 2 (E.D.N.C. June 1, 1983).

Following the order setting aside Ross’s conviction, the SBI’s database was

updated to include the comment: “CONVICTION SET ASIDE-NULL AND VOID-OF

NO LEGAL EFFECT.” The parties dispute exactly when this notation was added;

however, SBI specifically alleges “SBI reported Ross’s unconstitutional conviction in

its database from on or about March 1969 until January 27, 2020.”

On 2 November 2004, Ross’s set-aside conviction was expunged. But this

expungement was rescinded in January 2005 because Ross received an expungement

-2- ROSS V. N.C. DEP’T OF ADULT CORR.

for another conviction. See N.C.G.S. § 15A–146(a) (2004) (prohibiting more than one

expungement).

In 2005, Ross petitioned the Industrial Commission for monetary relief related

to his conviction and imprisonment under N.C.G.S. § 148-82; his petition was denied.

Subsequently in 2006, Ross sued the State of North Carolina and the Industrial

Commission in the United States District Court for the Eastern District of North

Carolina, alleging a myriad of constitutional claims and sought federal expungement.

In 2007, the District Court denied Ross’s constitutional claim and stated, “Ross must

seek expungement of his state criminal record through the state court system.” Ross

v. North Carolina, No. 5:06-CV-218D, 2007 WL 4118884, at *8 (E.D.N.C. Jan. 31,

2007), aff’d, 239 F. App’x 782 (4th Cir. 2007).

In 2013, Ross was hired as a security guard in Virginia; however, this

employment was contingent on him passing a criminal background check. The

requesting agency contacted the FBI and the FBI provided that agency with Ross’s

criminal history. These documents included Ross’s set-aside murder conviction, but

there was no indication that the conviction was set aside, null and void, or of no legal

effect. Consequently, Ross lost his job as a security guard.

In 2015, Ross filed a complaint in the Industrial Commission under the State

Tort Claims Act, alleging the SBI negligently maintained his criminal record. See

Ross v. N.C. State Bureau of Investigation, No. COA20-599, 279 N.C. App. 107, 2021

WL 3625362 (Aug. 17, 2021) (unpublished). Ross argued that SBI breached their

-3- ROSS V. N.C. DEP’T OF ADULT CORR.

duty to update their system after his habeas proceeding, which caused him to lose his

job. Id. at *1.

Ross’s claim was heard by a deputy commissioner in February 2016. At this

hearing, SBI presented evidence of Ross’s conviction record, dated 2015, which

included the proper annotation. Id. SBI further provided “an accompanying affidavit

and testimony from an SBI agent who stated under oath that the annotation of the

murder conviction was entered on Ross’s record in the SBI’s system ‘on or before

August 19, 2011.’ ” Id. The deputy commissioner denied Ross’s claim, concluding

that SBI fulfilled its duty to maintain Ross’ record. Id.

Subsequently, Ross appealed to the Full Commission, and in 2017, the Full

Commission affirmed the deputy commissioner’s denial of Ross’s claim. Id. at *2. The

Full Commission “concluded that Ross failed to satisfy his burden of proof to show

that the SBI was negligent because the SBI fulfilled its statutory duty to maintain

[Ross’s] criminal record when it added the annotation to his conviction in 2011.” Id.

Further, “any error in a database search and dissemination of the resulting

information on the part of the FBI was not attributable to the SBI.” Id.

Ross then appealed to this Court. See Ross I, 2018 WL 2016405. We affirmed

the Commission’s decision and specifically held that SBI “presented competent

evidence showing [it] accurately updated and maintained [Ross’s] criminal record.”

Id. at *4.

Later that same year, Ross brought an injunction action in United States

-4- ROSS V. N.C. DEP’T OF ADULT CORR.

District Court for the Eastern District of North Carolina to enforce the “null and void”

order asking SBI to delete or expunge his set-aside murder conviction from his

criminal history records. See Ross v. Hooks & Schurmeier, No. 5:17-CV-510-H

(E.D.N.C. 2019). The District Court stated in its subsequent order, to “carry out the

intent of its prior order,” Ross’s 1969 murder conviction was to be expunged from his

criminal record. Id. Further, the District Court expressly noted that “[t]he Industrial

Commission found that SBI was not negligent in the maintenance of its records.” Id.

Following that order, Ross’s unconstitutional conviction was expunged by an

order issued in North Carolina Superior Court. Jodi Harrison, Deputy General

Counsel for DPS, submitted an affidavit describing that as of 27 January 2019, all

criminal records related to Ross’s 1969 set-aside conviction were expunged from DPS

and SBI databases.

After, Ross submitted motions to the Industrial Commission under Rule

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Reed v. Ross
468 U.S. 1 (Supreme Court, 1984)
McGee v. North Carolina Department of Revenue
520 S.E.2d 84 (Court of Appeals of North Carolina, 1999)
Kawai America Corp. v. University of North Carolina at Chapel Hill
567 S.E.2d 215 (Court of Appeals of North Carolina, 2002)
Gibson v. Ussery
675 S.E.2d 666 (Court of Appeals of North Carolina, 2009)
Simmons v. North Carolina Department of Transportation
496 S.E.2d 790 (Court of Appeals of North Carolina, 1998)
Holt v. N.C. Dep't of Transp.
781 S.E.2d 697 (Court of Appeals of North Carolina, 2016)
Gilliam v. Perdue Farms
435 S.E.2d 780 (Court of Appeals of North Carolina, 1993)
Allred v. Exceptional Landscapes, Inc.
743 S.E.2d 48 (Court of Appeals of North Carolina, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Ross v. N.C. Dep't of Adult Corr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ross-v-nc-dept-of-adult-corr-ncctapp-2026.