Wilson v. North Carolina Department of Commerce

CourtCourt of Appeals of North Carolina
DecidedFebruary 17, 2015
Docket14-975
StatusPublished

This text of Wilson v. North Carolina Department of Commerce (Wilson v. North Carolina Department of Commerce) 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
Wilson v. North Carolina Department of Commerce, (N.C. Ct. App. 2015).

Opinion

NO. COA14-975

NORTH CAROLINA COURT OF APPEALS

Filed: 17 February 2015

MONICA WILSON and WILSON LAW GROUP PLLC, Plaintiffs,

v. Wake County No. 14 CVS 2499 NORTH CAROLINA DEPARTMENT OF COMMERCE; NC DEPARTMENT OF COMMERCE; DIVISION OF EMPLOYMENT SECURITY; SHARON ALLRED DECKER, in her capacity as Secretary of Commerce; and DALE R. FOLWELL, in his capacity as Assistant Secretary of Employment Security, Defendants.

Appeal by defendants from order entered 13 March 2014 by

Judge Paul C. Ridgeway in Wake County Superior Court. Heard in

the Court of Appeals 7 January 2015.

Law Office of James C. White, P.C., by James C. White and Michelle M. Walker, for plaintiffs-appellees.

The North Carolina Department of Commerce Division of Employment Security, by Ted Enarson and Jeremy L. Ray, for defendants-appellants.

INMAN, Judge.

Defendants appeal the order granting plaintiffs a

preliminary injunction compelling the disclosure of unemployment

hearings information. Defendants contend that the interlocutory -2- order is immediately appealable because it involves a

substantial right. Furthermore, they allege that the trial

court erred in entering the preliminary injunction because

plaintiffs are unable to show a likelihood of success on the

merits because federal law prohibits the disclosure of the

unemployment appeals hearing notices. In contrast, plaintiffs

argue that the appeal should be dismissed not only because it is

moot but also because it is interlocutory and does not affect a

substantial right. In the alternative, plaintiffs contend that

the order should be affirmed because it was decided correctly

under the law in effect at the time of the hearing.

After careful review, we vacate the order and remand for

the trial court to enter additional findings and conclusions not

inconsistent with this opinion.

Factual and Procedural Background

This appeal involves the North Carolina Division of

Employment Security’s (“DES’s”) decision to terminate its

practice of providing third parties, specifically plaintiffs

Monica Wilson (“Ms. Wilson”) and her law firm Wilson Law Group

PLLC (“WLG”) (collectively, Ms. Wilson and WLG are referred to

as “plaintiffs”), with daily access to appeals hearing notices

about unemployment claimants (the “hearing notices”). The -3- hearing notices listed all scheduled hearings set before DES

appeals referees and hearing officers and provided various

information about each claimant, including, among other things,

the claimant’s name, address, phone number, information about

her termination, and the last four digits of her social security

number. Since 2004, Ms. Wilson and several other attorneys

received daily hearing notices from DES in exchange for a

monthly fee of $300. Ms. Wilson picked her copy up daily via

courier from DES because the notices provided only 14 days

notice of the scheduled hearings.

On 26 February 2014, in addition to the day’s hearing

notices, DES sent Ms. Wilson an undated letter stating:

Due to security concerns, the process of entering [DES] through the back door of our building near the mail room and outside our security guards [sic] knowledge will no longer be allowed after February 28th. I understand the process of allowing attorneys to pick up appeals hearing notices was established by a former DES General Counsel years ago, but for the safety of our employees and constituents, this will end.

The letter went on to say that the hearing notices would be sent

to the law offices “at least three times per month” and that the

monthly cost would increase from $300 to $600. The letter was

signed by defendant Dale R. Folwell (“Mr. Folwell”), the

Assistant Secretary of DES. According to plaintiffs, this -4- change negatively impacted claimants’ ability to obtain counsel

which resulted in an unfair advantage for employers.

On 28 February 2014, plaintiffs filed a complaint and

request for injunctive relief against DES, Mr. Folwell, the

North Carolina Department of Commerce, and Sharon Decker (“Ms.

Decker”), the Secretary of Commerce (collectively, these parties

are referred to as “defendants”) challenging the withholding of

daily hearing notices.1 Plaintiffs claimed that defendants

violated Chapter 132 of the General Statutes, commonly referred

to as North Carolina’s Public Records Act. Plaintiffs alleged

that the daily hearing notices constituted public records under

N.C. Gen. Stat. § 132-6(a) and that they were entitled to

injunctive relief compelling DES to provide copies of the daily

hearing notices. Plaintiffs further contended that they were

entitled to expedited discovery and to compensation from

defendants for their attorneys’ fees.

1 During the pendency of this appeal, Sharon Decker resigned her position as Secretary of Commerce. This change does not render plaintiffs’ claims moot but may lead to an amendment of the pleadings with regard to acts or omissions after her departure date. See N.C. Gen. Stat. § 1A-1, Rule 25(f) (2013) (“When a public officer is a party to an action in his official capacity and during its pendency dies, resigns or otherwise ceases to hold office, the action does not abate and his successor is automatically substituted as a party.”). -5- Plaintiffs’ request for a temporary restraining order

(“TRO”) was heard by Judge Michael Morgan on 3 March 2014.

After concluding that plaintiffs were likely to prevail on their

claim that DES’s refusal to provide the hearing notices

constituted a violation of section 132-6(a), the trial court

issued a TRO and scheduled a preliminary injunction hearing.

On 10 March 2014, plaintiffs’ petition for a preliminary

injunction came on for hearing before Judge Paul Ridgeway.

Counsel for the respective parties submitted affidavits,

exhibits, and arguments, and the trial court took the matter

under advisement.

On 13 March, the trial court issued an order concluding

that plaintiffs had met their burden of proving the likelihood

that they would succeed in their public records claim and that

injunctive relief was necessary to protect plaintiffs’ rights

until the matter could be resolved. Furthermore, the trial

court required defendants to allow any person access to DES

headquarters “for the purposes of picking up copies of hearing

notices generated that day in accordance with that person’s

previous request.”

Defendants timely appealed. On 27 May 2014, defendants

filed a petition for writ of supersedeas to stay the trial -6- court’s 13 March 2014 order pending outcome of the appeal, which

petition this Court granted.

During the pendency of this appeal, on 25 August 2014, the

General Assembly enacted Session Law 2014-117, “An Act to

Clarify the Confidentiality of Unemployment Compensation

Records,” providing that unemployment appeal hearing notices are

“confidential information” and are specifically exempt from the

Public Records Act.

Analysis

I. Jurisdiction

Initially, we must determine whether the interlocutory

preliminary injunction is immediately appealable. See generally

A.E.P. Indus., Inc. v. McClure, 308 N.C. 393, 400, 302 S.E.2d

754, 759 (1983) (noting that “[a] preliminary injunction is

interlocutory in nature, issued after notice and hearing, which

restrains a party pending final determination on the merits” and

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