State v. Mohammed

CourtCourt of Appeals of North Carolina
DecidedOctober 17, 2023
Docket23-198
StatusPublished

This text of State v. Mohammed (State v. Mohammed) 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. Mohammed, (N.C. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA23-198

Filed 17 October 2023

Durham County, No. 20 CR 050362

STATE OF NORTH CAROLINA

v.

YOUSEF BARAKAT MOHAMMED, DEFENDANT 1ST ATLANTIC SURETY COMPANY, SURETY

Appeal by Durham Public Schools Board of Education from order entered 16

November 2022 by Judge Clayton Jones, Jr., in Durham County District Court.

Heard in the Court of Appeals 20 September 2023.

Tharrington Smith, LLP, by Stephen G. Rawson and Richard A. Paschal, for Durham Public Schools Board of Education-Appellant.

The Law Offices of Elston, Donnahoo & Williams, P.C., by Brian D. Elston, for Surety-Appellee.

COLLINS, Judge.

Durham Public Schools Board of Education (“Board”) appeals from an order

granting 1st Atlantic Surety Company’s (“Surety”) petition for relief from a final

judgment of bond forfeiture. The Board argues that the trial court abused its

discretion by granting relief because Surety failed to make a showing of extraordinary

circumstances as required by statute. Because the record contains no evidence that

extraordinary circumstances existed, the order is reversed. STATE V. MOHAMMED

Opinion of the Court

I. Background

Yousef Barakat Mohammed (“Defendant”) was arrested on 19 February 2020.

On 29 February 2020, Defendant was released on $5,000 secured bond under bail

agent Ashraf M. Mubaslat (“Mubaslat”) and Surety’s custody. Defendant failed to

appear for court on 13 January 2022, and the trial court issued a bond forfeiture

notice on 14 January 2022 with a final judgment date of 16 June 2022.

On 16 June 2022, Mubaslat filed a motion to set aside the forfeiture, indicating

that “[t]he defendant died before or within the period between the forfeiture and this

Motion, as evidenced by the attached copy of the defendant’s death certificate.”

Mubaslat did not attach a death certificate to the motion, but instead he attached a

hand-written note that stated, “Defendant died and we are getting a copy of death

certificate.” The Board objected to Mubaslat’s motion and moved for sanctions

against Surety for failure to provide actual documentation of Defendant’s death. On

14 July 2022, the trial court denied Mubaslat’s motion to set aside the forfeiture. The

trial court entered a separate order finding grounds for sanctions and ordering Surety

to pay $2,500. Surety paid the bond but did not pay the sanctions.

On 26 August 2022, the State moved to abate the criminal charges against

Defendant on the ground that Defendant had died on or about 23 February 2022. The

trial court allowed the State’s motion and ordered that the case be dismissed. On 29

August 2022, Mubaslat and Surety filed a petition seeking relief from the final

judgment of forfeiture, arguing:

-2- STATE V. MOHAMMED

7. The Defendant died before or within the period between the forfeiture and this Motion, as evidenced by the attached copy of the defendant’s death certificate. 8. Filed Motion to set aside knowing the Defendant had died but was not able to produce documentation. 9. Surety Paid Bond 10. Surety was able to produce the death certificate after the final Judgment date and Bond was paid.

A photograph of Defendant’s death certificate issued by the Cook County Clerk in

Chicago, Illinois, was attached to the petition. On 14 September 2022, Surety

withdrew and refiled the petition.1

The matter was heard on 9 November 2022. At the hearing, Surety’s counsel

argued that Mubaslat was unable to obtain a copy of Defendant’s death certificate

and had to find Defendant’s family members to get a copy of his death certificate.

However, Mubaslat was not present at the hearing, and no sworn testimony or

affidavits were presented to the court. On 16 November 2022, the trial court entered

an order granting Surety relief from the final judgment of forfeiture. The trial court

found, in relevant part:

4. On or about February 13, 2022, Defendant Mohammed died. 5. Surety filed a motion to set aside on June 16, 2022, but did not attach a death certificate to the motion. The Board attorney filed an objection to said motion and motion for sanctions and noticed same for hearing on July 13, 2022. At the July 13, 2022 hearing, the Honorable Judge Dorothy

1 The petition was originally signed by Mubaslat. The refiled petition was signed by counsel for Surety.

-3- STATE V. MOHAMMED

Mitchell entered an order denying the motion to set aside and an order awarding sanctions to the Board in the amount of 50% of the bond for failure to attach the required documentation. Neither of those orders was appealed. 6. The bond was paid in full on July 15, 2022. The sanctions had not been paid as of November 9, 2022. 7. On September 14, 2022, counsel for the Surety filed a Petition for Relief from Final Judgment and included a photograph of the death certificate for Defendant Mohammed. 8. At the November 9, 2022, hearing on Surety’s Petition to Remit, counsel for the Surety argued that the bail agent was unable to obtain the death certificate from the Cook County, Illinois clerk in time to attach it to the original motion to set aside, and had to find family members of the deceased in order to get a copy of the record. 9. The Court finds that the Defendant died during the 150-day period following the failure to appear, and that the Surety’s difficulty in getting the death certificate from Cook County along with efforts to contact the Defendant’s family to obtain the same represent extraordinary circumstances that entitle the Surety to relief from the final judgment of forfeiture. 10. Because the July 13, 2022, sanctions order was not appealed, the Court finds that it has no ability to revisit that judgment.

Based upon its findings of fact, the trial court concluded that the 13 July

sanctions order should remain in place, but “[t]he circumstances described by Surety

constitute extraordinary circumstances . . ., and the Surety is entitled to relief in full

from the final judgment of forfeiture.” The Board appealed.

-4- STATE V. MOHAMMED

II. Discussion

A. Standard of Review

A trial court’s decision to grant relief based on the existence of extraordinary

circumstances is reviewed for abuse of discretion. State v. Edwards, 172 N.C. App.

821, 825, 616 S.E.2d 634, 636 (2005) (citation omitted). “A trial court may be reversed

for abuse of discretion only upon a showing that it[s ruling] was so arbitrary that it

could not have been the result of a reasoned decision.” State v. Escobar, 187 N.C.

App. 267, 271, 652 S.E.2d 694, 698 (2007) (quotation marks and citation omitted).

B. Extraordinary Circumstances

The Board argues that the trial court abused its discretion by granting Surety’s

petition for relief because Surety presented no evidence of extraordinary

circumstances that prevented it from obtaining and furnishing Defendant’s death

certificate with its initial motion to set aside the judgment.

A trial court may grant relief from a final judgment of forfeiture if

“extraordinary circumstances exist that the court, in its discretion, determines should

entitle that person to relief.” N.C. Gen. Stat. § 15A-544.8(b)(2) (2022).

“Extraordinary circumstances in the context of bond forfeiture has been defined as

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Related

State v. Edwards
616 S.E.2d 634 (Court of Appeals of North Carolina, 2005)
State v. Collins
478 S.E.2d 191 (Supreme Court of North Carolina, 1996)
State v. Escobar
652 S.E.2d 694 (Court of Appeals of North Carolina, 2007)

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Bluebook (online)
State v. Mohammed, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mohammed-ncctapp-2023.