Patrick v. Hurdle

Removal of a case for a “fair trial” under the provisions of G.S. 1-84 is limited to removal to an adjoining county. Removal of a case “when the convenience of witnesses and ends of justice would be promoted” under the provisions of G.S. 1-83(2) is not limited to removal to an adjoining county.

Appellees state in their brief: “In any event, as far as the geography of the matter is concerned, Currituck and Pasquotank Counties seemingly adjoin in the Albemarle Sound.” However, it seems from Judge Parker’s order that plaintiffs and the Judge were doubtful that the two counties do adjoin, because…