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Hale v. Afro-American Arts International

Supreme Court of North Carolina
Dec 1, 1993
335 N.C. 231 (N.C. 1993)

Summary

holding that "a party upon whom service of notice of appeal is required may waive the failure of service by not raising the issue by motion or otherwise and by participating without objection in the appeal"

Summary of this case from In re M.D.

Opinion

No. 291A93

Filed 3 December 1993

Appeal and Error 8 (NCI4th) — waiver of service of notice of appeal — jurisdiction of Court of Appeals Plaintiff waived service of notice of defendants' appeal by not raising the issue by motion or otherwise and by participating without objection in the appeal, and the Court of Appeals thus had jurisdiction of the appeal and should have considered the case on its merits.

Am Jur 2d, Appeal and Error 316 et seq.

Appeal by defendants pursuant to N.C.G.S. 7A-30(2) from the decision of a divided panel of the Court of Appeals, 110 N.C. App. 621, 430 S.E.2d 457 (1993), dismissing defendants' appeal from a judgment signed 28 March 1991 and an order signed 24 February 1992 by Albright, J., presiding in Superior Court, Guilford County. Heard in the Supreme Court 15 November 1993.

Lee D. Andrews for plaintiff-appellee.

James W. Swindell for defendant-appellants.


A majority of the Court of Appeals on its own motion dismissed defendants' appeal after the record on appeal had been served on the appellee and docketed without objection in the Court of Appeals and after all briefs had been duly filed. The basis for the dismissal was that while the record on appeal contained the proper notice of appeal, "[n]othing in the notice . . . shows that plaintiff was given notice of the appeal through service as required by [Appellate] Rule 26(b)." 110 N.C. App. 621, 623, 430 S.E.2d 457, 458. The majority concluded that this was a jurisdictional defect which both the parties and the court were powerless to remedy.

Judge Wynn, dissenting, concluded that failure to serve the notice of appeal was a defect in the record analogous to failure to serve process. Therefore, a party upon whom service of notice of appeal is required may waive the failure of service by not raising the issue by motion or otherwise and by participating without objection in the appeal, as did the plaintiff here. Judge Wynn concluded that plaintiff had thereby waived service of the notice of appeal and that the Court of Appeals had jurisdiction of the appeal and should consider the case on its merits.

For the reasons given in Judge Wynn's dissenting opinion, we reverse the decision of the Court of Appeals dismissing defendants' appeal and remand the case to that court for consideration on the merits.

REVERSED AND REMANDED.


Summaries of

Hale v. Afro-American Arts International

Supreme Court of North Carolina
Dec 1, 1993
335 N.C. 231 (N.C. 1993)

holding that "a party upon whom service of notice of appeal is required may waive the failure of service by not raising the issue by motion or otherwise and by participating without objection in the appeal"

Summary of this case from In re M.D.

stating that "a party upon whom service of notice of appeal is required may waive the failure of service by not raising the issue by motion or otherwise and by participating without objection in the appeal"

Summary of this case from In re K.D.C.

In Hale v. Afro-Am. Arts Int'l, Inc., 335 N.C. 231, 436 S.E.2d 588 (1993), our Supreme Court held that the failure to include a certificate of service with the notice of appeal is a defect that may be waived by the appellee's failure to object or otherwise raise the issue and by participating in the appeal.

Summary of this case from In re G.M.C., T. L.C.

In Hale v. Afro-American Arts Int'l, 335 N.C. 231, 436 S.E.2d 588 (1993), the appellant filed a notice of appeal, but failed to include in the record a certificate of service of the notice of appeal upon the appellee.

Summary of this case from Lee v. Winget Road, LLC

In Hale v. Afro-Am. Arts Int'l, Inc., 335 N.C. 231, 436 S.E.2d 588 (1993), our Supreme Court addressed the issue of whether compliance with the service requirements of Rule 26(b) were required to confer jurisdiction on the Court of Appeals. The Supreme Court reversed per curiam the Court of Appeals' majority opinion, 110 N.C. App. 621, 430 S.E.2d 457 (1993) (Greene, J.), for the reasons set forth in the dissent.

Summary of this case from Henlajon, Inc. v. Branch Highways, Inc.

In Hale, the record on appeal contained a "notice of appeal" but "[n]othing in the notice... shows that plaintiff was given notice of the appeal through service as required by Rule 26(b)."

Summary of this case from Henlajon, Inc. v. Branch Highways, Inc.
Case details for

Hale v. Afro-American Arts International

Case Details

Full title:EDWARD L. HALE v. AFRO-AMERICAN ARTS INTERNATIONAL, INC. and RICK SLADE

Court:Supreme Court of North Carolina

Date published: Dec 1, 1993

Citations

335 N.C. 231 (N.C. 1993)
436 S.E.2d 588

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¶ 30 In Hale v. Afro-Am. Arts Int'l., Inc. , this Court "dismissed defendants’ appeal after the record on…

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