Case Summaries: N.C. Court of Appeals (May 21, 2025)

This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on May 21, 2025. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present. Indirect criminal contempt proceeding is similar to a criminal trial, but is not a misdemeanor subject to statute of limitations. State Board of Examiners of Plumbing, Heating and Fire Sprinkler Contractors v. Hudson, COA24-136, ___ N.C. App. ___ (May 21, 2025). In this Burke County case, defendant appealed the order holding him in indirect criminal contempt, arguing error in denying his motion to dismiss, lack of jurisdiction, and that the statute of limitations barred the contempt proceeding. The Court of Appeals found no error and affirmed the order. In 2001, the State Board of Examiners of Plumbing, Heating, and Fire Sprinkler Contractors (State Board) obtained an injunction against defendant barring him from engaging in any plumbing, heating, or fire sprinkler business without a license from the State Board. Over the years, the State Board investigated complaints against defendant, most recently in 2021 where investigators turned up evidence defendant performed work on an HVAC unit. After a show cause hearing in 2023, the trial court entered an order holding defendant in indirect criminal contempt for violating the injunction. The trial court initially issued an oral ruling and filed a form document titled “Order in Indirect Criminal Contempt Proceeding” in July 2023. This was followed in August 2023 by the “Order [...]