Court of Appeals Clarifies Limits of Legislative Immunity at Rule 12 Stage

In Holsey-Hyman v. Edens (N.C. Ct. App. Apr. 15, 2026), the North Carolina Court of Appeals addressed the boundary between protected legislative acts and unprotected administrative or political conduct by local officials. Although the Court dismissed the appeal on jurisdictional grounds, its analysis sends a clear message: allegations within a complaint that officials acted outside legitimate legislative purposes or for personal or political retaliation will defeat legislative immunity at the... By: Cranfill Sumner LLP