Simuel v. N.C. Admin. Off. Of The Courts

CourtCourt of Appeals of North Carolina
DecidedDecember 3, 2025
Docket25-142
StatusUnpublished

This text of Simuel v. N.C. Admin. Off. Of The Courts (Simuel v. N.C. Admin. Off. Of The Courts) 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
Simuel v. N.C. Admin. Off. Of The Courts, (N.C. Ct. App. 2025).

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An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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. COA25-142

Filed 3 December 2025

Wake County, No. 24CV009561-910

JULIO SIMUEL, Administrator of the Estate of Tiyquasha Simuel, and JULIO SIMUEL, Administrator of the Estate of K’yson Kawhi Finley, Plaintiffs,

v.

NORTH CAROLINA ADMINISTRATIVE OFFICE OF THE COURTS, Defendant.

Appeal by plaintiff from order entered 3 November 2024 by Judge Paul C.

Ridgeway in Wake County Superior Court. Heard in the Court of Appeals 14 October

2025.

Kennedy, Kennedy, Kennedy, & Kennedy, LLP, by Harvey L. Kennedy and Harold L. Kennedy, III for plaintiff-appellant.

Attorney General, Jeff Jackson, by Special Deputy Attorney General, Elizabeth Curran O’Brien for defendant-appellee.

DILLON, Chief Judge.

Plaintiff Julio Simuel, as administrator of the Estates of Tiyquasha Simuel and

K’yson Kawhi Finley, appeals from an order granting Defendant North Carolina

Administrative Office of the Courts’s motion to dismiss Plaintiff’s Complaint with

prejudice under Rule 12(b)(6). Plaintiff contends the trial court erred by dismissing SIMUEL V. N.C. ADMIN. OFF. OF THE COURTS

Opinion of the Court

his claim under the North Carolina Constitution.

I. Background

Plaintiff alleges the following facts. At seven and a half months pregnant with

K’yson Kawhi Finley, Decedent Tiyquasha Simuel testified in her ex-boyfriend’s

capital murder trial pursuant to a Buncombe County District Attorney Office

(“BCDA”) subpoena. During this time, two BCDA assistant district attorneys

(“ADAs”) provided Decedent with law enforcement protection and a hotel room.

Following Decedent’s testimony for the BCDA, the BCDA released Decedent from its

subpoena and canceled the accompanying law enforcement protection and hotel

reservation. However, the defense attorney at trial served Decedent with another

subpoena, requiring Decedent to remain in Asheville. During trial, two jurors’ lives

were threatened and, as a result, the trial judge provided those jurors with law

enforcement protection. On or around 13 June 2019, while still in Asheville on the

defense attorney’s subpoena, Decedent was shot and killed while riding in a car on

the way to her friend’s home.

Plaintiff filed claims for wrongful death/negligence in the North Carolina

Industrial Commission under the State Tort Claims Act (the “Act”). On 28 March

2023, the Full Commission dismissed Plaintiff’s claim without prejudice for lack of

subject matter jurisdiction. Plaintiff did not appeal this order.

Approximately a year after the dismissal, on 21 March 2024, Plaintiff

commenced this action in superior court against Defendant, alleging claims based on

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equal protection grounds under Article I, Section 19 of our state constitution.

Defendant moved to dismiss Plaintiff’s Complaint on various grounds. The trial court

entered a Dismissal Order allowing Defendant’s motion to dismiss pursuant to Rule

12(b)(6). Plaintiff appealed.

II. Analysis

The trial court dismissed Plaintiff’s Complaint pursuant to Rule 12(b)(6) with

prejudice for failure to state a claim upon which relief can be granted. In allowing

Defendant’s motion to dismiss, the trial court considered “the pleadings, the

memoranda and arguments of counsel, and relevant case law.” The trial judge did

not state specific grounds for dismissal. On de novo review, we affirm the trial court’s

order, concluding Plaintiff has failed to state a claim upon which relief may be

granted. Assuming, but not deciding, other grounds warrant dismissal, we address

the merits of Plaintiff’s Corum claim.

A. Standard of Review

“Questions of law regarding the applicability of sovereign or governmental

immunity are reviewed de novo.” Lannan v. Bd. of Governors of Univ. of N.C., 387

N.C. 239, 246 (2025) (citing Irving v. Charlotte-Mecklenburg Bd. of Educ., 368 N.C.

440, 448 (2016)). De novo review also applies to a lower court’s ruling on a Rule

12(b)(6) motion to dismiss. Lannan, 387 N.C. at 246 (citing Arnesen v. Rivers Edge

Golf Club & Plantation Inc., 386 N.C. 440, 448 (2015)). A Rule 12(b)(6) motion treats

the factual allegations in a complaint as true, and based on such, tests whether a

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complaint states a legal claim. Sutton v. Duke, 277 N.C. 94, 98 (1970). Generally,

our system of “notice pleading” provides a liberal construction of complaints, making

a motion to dismiss easy to survive. See N.C.G.S. § 1A-1, Rule 8(a); Ladd v. Est. of

Kellenberger, 314 N.C. 477, 481 (1985).

However, Corum claims have unique pleading requirements. Our Supreme

Court has stated, “it is not enough for a claimant to simply assert that a claim is valid

under Corum . . . [at the outset], the complaint must ‘sufficiently allege’ a Corum

claim.” Kinsley v. Ace Speedway, 386 N.C. 418, 423 (2024) (citing Deminski v. State

Bd. of Educ., 377 N.C. 406, 407 (2021)). The Court in Ace Speedway then stated the

three requirements of a sufficiently alleged Corum claim, namely, (1) a state actor

constitutional violation, (2) a colorable claim, and (3) no adequate state remedy. Ace

Speedway, 386 N.C. at 423.

B. State Constitutional Claim

Plaintiff asserts the equal protection claim under Article I, Section 19 of our

state constitution is a “Corum claim.” Our constitution sets out in its Declaration of

Rights “[n]o person shall be denied the equal protection of the laws[.]” N.C. Const.

art. I, § 19. A claimant may bring a direct claim under the state constitution under

the framework of Corum. A Corum claim requires a plaintiff to colorably allege a

state actor violated constitutional rights to which there is no adequate state remedy.

Corum v. Univ. of N.C., 330 N.C. 761, 782 (1992). According to Plaintiff’s Complaint,

two ADAs, as employees of Defendant, denied Decedent equal protection of the law

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because of her gender.

Plaintiff’s claim, however, fails because he has failed to state a colorable claim.

A colorable constitutional claim requires sufficient facts to support an alleged

violation of a protected right under the state Constitution. Deminski, 377 N.C. at

413–14. Whether a claim is colorable focuses only on the allegations in a complaint.

Id. at 412. The complaint allegations are “treated as true” and this Court examines

whether the allegations, if proven, would constitute a violation of a right protected by

our state constitution. Id.

Plaintiff contends the standard for alleging a proper Corum claim is “notice

pleading.” See N.C.G.S. § 1A-1, Rule 8(a). Plaintiff is incorrect. As previously

mentioned, our Supreme Court stated, “it is not enough for a claimant to simply assert

that a claim is valid under Corum . . . the complaint must ‘sufficiently allege’ a Corum

claim.” Ace Speedway, 386 N.C. at 423 (citing Deminski, 377 N.C. at 407). The Court

in Ace Speedway then goes on to state the three requirements of a Corum claim. Id.

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Related

Engquist v. Oregon Department of Agriculture
553 U.S. 591 (Supreme Court, 2008)
Sutton v. Duke
176 S.E.2d 161 (Supreme Court of North Carolina, 1970)
Ladd v. Estate of Kellenberger
334 S.E.2d 751 (Supreme Court of North Carolina, 1985)
Department of Transportation v. Rowe
549 S.E.2d 203 (Supreme Court of North Carolina, 2001)
Toomer v. Garrett
574 S.E.2d 76 (Court of Appeals of North Carolina, 2002)
Application of Ellis
178 S.E.2d 77 (Supreme Court of North Carolina, 1970)
Corum v. University of North Carolina
413 S.E.2d 276 (Supreme Court of North Carolina, 1992)
Village of Willowbrook v. Olech
528 U.S. 562 (Supreme Court, 2000)
Arnesen v. Rivers Edge Golf Club and Plantation, Inc.
781 S.E.2d 1 (Supreme Court of North Carolina, 2015)
J. E. B. v. Alabama ex rel. T. B.
511 U.S. 127 (Supreme Court, 1994)

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