State v. Bliss

CourtCourt of Appeals of North Carolina
DecidedJune 4, 2025
Docket24-92
StatusUnpublished

This text of State v. Bliss (State v. Bliss) 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
State v. Bliss, (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An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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. COA24-92

Filed 4 June 2025

Buncombe County, Nos. 21CRS090691-100, 21CRS090695-100

STATE OF NORTH CAROLINA

v.

MATILDA RAE BLISS and MELISSA ANN COIT, Defendants.

Appeal by Defendants from judgment entered 16 June 2023 by Judge J.

Thomas Davis in Buncombe County Superior Court. Heard in the Court of Appeals

11 September 2024.

Attorney General Jeff Jackson, by Special Deputy Attorney General Matthew Tulchin, for the State.

First Amendment Clinic at Duke University School of Law, by Sarah H. Ludington, C. Amanda Martin, and Kyle H. Compton; Law Offices of Ben Scales, by Ben C. Scales Jr.; and Alan Stuart Graf, for Defendants-Appellants.

Elizabeth Jasmund Soja, for Reports Committee for Freedom of the Press, amicus curiae.

CARPENTER, Judge.

Matilda Rae Bliss (“Defendant-Bliss”) and Melissa Ann Coit (“Defendant-

Coit”) (collectively, “Defendants”) appeal from judgment entered after a jury found STATE V. BLISS

Opinion of the Court

them guilty of second-degree trespass. On appeal, Defendants argue the trial court

erred by denying their motion to dismiss based on their as-applied First Amendment

challenge and instructing the jury in response to the jury’s questions regarding the

applicability of the First Amendment and Defendants’ press status. After careful

review, we discern no error.

I. Factual and Procedural Background

Defendants were journalists for The Asheville Blade, a newspaper. The

Asheville Blade is known for criticizing the Asheville Police Department’s methods of

clearing homeless encampments and corresponding protests. On 19 December 2021,

a multi-day protest began in Aston Park (the “Park”), a public park owned and

operated by the City of Asheville, North Carolina. The Park is governed by the

Asheville City Code of Ordinances (the “City Code”). Section 12-41 of the City Code

(the “Park Curfew”) provides that all parkgoers are required to leave the Park by

10:00 p.m. See Asheville, N.C., Code § 12-41 (2023) (“All public parks . . . shall be

closed to the general public between the hours of 10:00 p.m. and 6:00 a.m.”). The

purpose of the protest was to demand that the city allow “sanctuary camping” in the

Park for the local homeless population.

On the first day of the protest, in the evening hours, officers warned protestors

that they would be subject to arrest if they remained in the Park after 10:00 p.m.

Officers, however, did not take any action against the protestors on the first day of

the protest. Defendant-Bliss was not present on the first day of the protest, but

-2- STATE V. BLISS

Defendant-Coit was in attendance for approximately one hour.

On 20 December 2021, Defendant-Bliss visited the protests. She remained in

the Park for approximately an hour or two and reported on her observations for The

Asheville Blade. Defendant-Bliss returned to the Park on 21 and 22 December to

continue observing and taking photographs. The Asheville Blade published her

photographs on its social media platforms. Defendant-Coit also returned to the Park

on several occasions.

On 25 December 2021, Defendants were at the Park. Defendant-Bliss arrived

at approximately 4:00 p.m., and Defendant-Coit arrived later that evening.

Defendant-Bliss left the Park for a brief period of time and returned sometime

between 9:30 p.m. and 10:00 p.m. to continue recording video footage and taking

photographs. Shortly after 10:00 p.m., officers began dismantling protestors’ tents

and artwork. Officers also instructed everyone in the Park, including Defendants, to

vacate the Park. Officers told Defendants they could continue reporting from outside

the Park. Defendants, however, did not leave the Park and around 10:30 p.m.,

following additional requests by officers to vacate the Park, officers arrested

Defendants for second-degree trespass.

Defendants were first tried and convicted of second-degree trespass in district

court. Following their convictions, Defendants appealed to superior court. On 30

May 2023, Defendants filed a motion to dismiss, arguing the Park Curfew was facially

unconstitutional. On 6 June 2023, the trial court heard arguments on Defendants’

-3- STATE V. BLISS

motion to dismiss. The trial court denied Defendants’ motion, concluding the Park

Curfew was not facially unconstitutional.

On 12 June 2023, Defendants’ case proceeded to trial. At the close of the State’s

evidence, Defendants moved to dismiss the charges, arguing the Park Curfew was

unconstitutional as-applied to them. The trial court denied the motion. At the close

of all of the evidence, Defendants renewed their motion, which the trial court denied

in a written order entered after trial. During the charge conference, Defendants

requested that the trial court change the “without authorization” language in the

second-degree trespass instruction to “without legal right.” The State objected, but

the trial court allowed the change. Then, Defendants requested a First Amendment

affirmative defense instruction, which the trial court denied.

During deliberations, the jury submitted a note to the trial court stating the

following, in pertinent part: “We would like clarification as to if there was an

instruction on the applicability of the First Amendment” (the “First-Amendment

Question”) and “We would like clarification as to if we are allowed to consider the

[D]efendants’ status as members of the press as potential exemption from the

applicable ordinance” (the “Press-Status Question”). Thereafter, outside the presence

of the jury, the parties conferred regarding the jury’s questions. The trial court

informed the parties how it would re-instruct the jury and defense counsel did not

object to the trial court’s proposed instructions. Thereafter, the trial court instructed

the jury as follows:

-4- STATE V. BLISS

Trial court: The answer to [the First-Amendment Question] is, no, there was not such an instruction. The issue of whether or not the defendants’ First Amendment constitutional rights, particularly the free speech, is a question of law that will be decided by the Court, not the jury. ... Trial court: Now, as to the [Press-Status Question] . . . My instruction to you is, you are entitled to consider all the evidence in this case in determining the guilt or innocence of the defendants.

On 15 June 2023, the jury found Defendants guilty of second-degree trespass.

The trial court sentenced Defendants to a $100 fine plus court costs. Defendants gave

oral notice of appeal in open court.

II. Jurisdiction

This Court has jurisdiction under N.C. Gen. Stat. § 7A-27(b)(1) (2023).

III. Issues

The issues are whether the trial court erred by denying Defendants’ as-applied

constitutional challenge and responding to the jury’s note seeking instruction on the

applicability of the First Amendment and Defendants’ press status.

IV. Analysis

A. First Amendment Challenge

First, Defendants assert the trial court erred by denying their motion to

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State v. Bliss, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bliss-ncctapp-2025.