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By Ed Boltz, 17 April, 2026

N.C. Ct. of App.: Yurk v. Terra Center- Possession may be 9/10ths of the Law, but Holding It Hostage Gets Expensive

Summary:

The Court of Appeals largely affirmed a substantial judgment against a storage operator that:

Took and held a debtor’s property for over three years
Moved it multiple times
Refused return unless the owner signed a liability release

Result:

Conversion, trespass to chattels, and UDTPA → affirmed

By Ed Boltz, 16 April, 2026

N.C. Ct. of App.: Figueroa v. Monsivais: When Dirt Meets Equity: Unrecorded Deals, “Desperate” Sellers, and the Limits of North Carolina’s Race Recording Statute

Summary:

The Figueroa v. Monsivais decision reads like a law school exam question—but with very real consequences for families who paid cash, moved in, and still ended up without title.

The Setup: Cash Paid, Possession Taken—But Nothing Recorded

By Ed Boltz, 2 April, 2026

N.C. Ct. of App.: Israel v. Zachary- Landlord Interference With Tenant’s Property Leads to Conversion Liability (Damages Remanded)

Summary:

In Israel v. Zachary, the North Carolina Court of Appeals affirmed that a landlord who interferes with a tenant’s efforts to retrieve property after eviction can be liable for conversion and unjust enrichment, though the court vacated the damages award for lack of sufficient valuation evidence.

By Ed Boltz, 13 March, 2026

N.C. Ct. of App.: Harris v. McLeod — Equitable Mortgages, Foreclosure Equity, and What Bankruptcy Could Have Done

In Harris v. McLeod (N.C. Ct. App. Feb. 4, 2026) (unpublished), the Court of Appeals reversed summary judgment in a dispute over whether an elderly homeowner’s deed to his nephew was an outright conveyance or merely security for a small tax debt—an equitable mortgage in substance if not in form.

By Ed Boltz, 12 March, 2026

N.C. Ct. of Appeals: Ray v. TitleMax of Virginia- itleMax’s Cross-Border Title Loans Create Personal Jurisdiction in North Carolina

Summary:

In Ray v. TitleMax, the North Carolina Court of Appeals affirmed the denial of a Rule 12(b)(2) motion to dismiss, holding that North Carolina courts may exercise specific personal jurisdiction over out-of-state TitleMax-affiliated lenders who made high-interest title loans to North Carolina residents—even where loan documents were signed across state lines.

By Ed Boltz, 23 January, 2026

N.C. Ct. of App.: Eagles v. Integon Indemnity Corp.: Receivership as the End-Run (Again), Standing Still Matters, and Bankruptcy’s Shadow Looms Large

Summary:

By Ed Boltz, 5 January, 2026

N.C. Ct. of App.: The Law Office of Robert Forquer v. Arcuri- Co-Signer on Deed Not Liable for Mortgage Payoff

Summary:

This case began as an interpleader filed by a closing attorney caught in the middle of a family property dispute — wisely deciding not to referee a fight over sale proceeds while trying to deliver clear title.

By Ed Boltz, 30 December, 2025

N.C. Ct. of App.: Horne v. Ginkgo Aurora- Chapter 75, Debt Collection, and the Problem of Injury

While this decision is, on its face, a fairly ordinary residential rental dispute—replete with mold allegations, maintenance requests, and implied-warranty skirmishing—the part that should actually catch the attention of consumer and bankruptcy attorneys is the Court’s treatment of the North Carolina Unfair and Deceptive Trade Practices Act and its companion Debt Collection Act provisions.

By Ed Boltz, 29 December, 2025

N.C. Ct. of App.: Roach v. Wells Fargo Bank, N.A. — When “That’s Not Right” Still Isn’t Enough (and Timing Is Everything)

In Roach v. Wells Fargo Bank, N.A., the North Carolina Court of Appeals again draws a hard line between conduct that feels unfair and conduct that is legally actionable under Chapter 75. The court affirmed summary judgment for Wells Fargo Bank, N.A., holding that the borrowers’ grievances — however sympathetic — did not amount to unfair and deceptive trade practices.

This is a foreclosure case with a long backstory, and that backstory matters.

By Ed Boltz, 28 December, 2025

N.C. Ct. of App.: Zuleger v. Clore- Life Estates on Paper vs. Life Estates in Bankruptcy Court

At first blush, Zuleger v. Clore looks like a pure state-law property dispute about life estates, remainders, and an aging house that no one can afford to fix. But for bankruptcy practitioners—especially in North Carolina—it quietly sharpens an issue we wrestle with all the time:

How do you value a life estate or remainder interest when the law allows liquidation in theory, but the market reality says otherwise?

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