In re A.B.T., 2026 N.C. App. LEXIS 36 (N.C. Ct. App. 2026)

The North Carolina Court of Appeals reversed an adjudication of disorderly conduct based on insufficient evidence. The court stated in relevant part:

“Considering the evidence in the light most favorable to the State and giving the State the benefit of every reasonable inference, Rose, 339 N.C. at 192, 451 S.E.2d at 223 (citation omitted), the evidence is insufficient to show Annie committed a substantial interference with the operation of the school. Rather, Annie’s conduct resembles what this Court has described as a “momentary lapse[ ] in behavior[,]” as opposed to behavior warranting a conviction for Disorderly Conduct. In re Brown, 150 N.C. App. at 131, 562 S.E.2d at 586. Based on the limited set of facts before us, we cannot say the evidence shows Annie’s behavior was “more than ordinary misbehavior or rule-breaking.” In re S.M., 190 N.C. App. at 584, 660 S.E.2d at 656.”