Chris Edwards, a North Carolina State Bar Board Certified Specialist in Appellate Practice and co-chair of Ward and Smith's Appellate Practice, will present the opening session on sanctions at the North Carolina Bar Association's From Objection to Opinion: 2026 Appellate Practice and Litigation Sections Joint Program on Friday, May 15.
Chris will lead the opening section on appellate sanctions, during which he will address questions that trial lawyers and appellate practitioners deal with regularly but that receive less attention than they should: When are sanctions available on appeal in North Carolina? What sanctions are available? And when should practitioners seek them?
These are not hypothetical questions. Under North Carolina Rule of Appellate Procedure 34, an appellate court can impose sanctions, including dismissal, double costs, and reasonable attorney's fees, when it determines that an appeal was not well grounded in fact, was taken for an improper purpose, or involved filings that grossly violated appellate court rules. Much like, N.C.G.S. § 6-21.5, which allows a trial court to award attorney fees to a prevailing party where there was a complete absence of a justiciable issue, attorneys litigating in North Carolina's appellate courts should understand how Rule 34 operates at the appellate level to avoid risking exposure for their clients and, in some cases, themselves.
"Sanctions on appeal are one of those areas where the stakes are real but the guidance is not clear," Chris says. "Practitioners need to know not just that sanctions exist, but what type of conduct triggers them and how to protect against them. That is what this session is designed to address."
The full-day program, hosted by NCBA's Appellate Practice and Litigation Sections, brings together leading judges and practitioners for a lineup covering the full arc of appellate work. Other sessions include an Appellate Court Update with Justice Richard D. Dietz of the North Carolina Supreme Court and Chief Judge R. Christopher Dillon of the North Carolina Court of Appeals; a forward-looking discussion on AI in legal practice; a deep dive into stays, concurrent litigation, and remands; an ethics session examining the professional responsibility issues unique to appeals; and a panel discussion on effective amicus advocacy.
The program runs from 8:55 a.m. to 4:40 p.m. and offers 6.0 MCLE hours, including 1.0 ethics credit and 1.0 technology training credit. It qualifies for NC State Bar Appellate Practice Specialization credit.
Register here to attend.
- Date: May 15, 2026
- Time: 8:55 a.m. – 4:40 p.m.
- Location: Live Webcast