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Case Summaries: Fourth Circuit Court of Appeals (April 2023)

This post summarizes published criminal and related decisions released by the Fourth Circuit Court of Appeals during April 2023. Cases that may be of interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit decisions are available here.

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Is NC’s Disorderly Conduct at Schools Statute Unconstitutionally Vague?

I started wondering about that question after reading a recent decision by the Fourth Circuit Court of Appeals, Carolina Youth Action Project v. Wilson, 60 F.4th 770 (4th Cir. 2023) (summarized here). There, the court struck down two South Carolina state laws aimed in large part at regulating conduct and speech in and around schools. Those laws are similar to our version of disorderly conduct by disrupting schools. This post examines the holding of Carolina Youth Action Project and its potential implications for North Carolina law.

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