North Carolina – including in the Lake Norman area – law requires law enforcement officers to meet high standards of integrity. One of those requirements is that all officers demonstrate and maintain “good moral character.” That standard has been applied for decades to lawyers, judges, and officers — but what exactly does it mean, and how do the courts enforce it?

The Supreme Court of North Carolina’s 2025 decision in Devalle v. North Carolina Sheriffs’ Education and Training Standards Commission illustrates the challenge. The Court reinstated the denial of a deputy sheriff’s certification, holding that substantial evidence supported the Commission’s finding that he lacked the required character.

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Background: From Highway Patrol to Sheriff’s Deputy

• Long Service with the Patrol: Maurice Devalle served nearly 20 years with the North Carolina Highway Patrol, rising to the rank of sergeant.
• Misconduct Allegations: In 2016, a news tip triggered an internal investigation. Investigators found that Devalle had provided a false address to meet residency requirements, falsely reported duty status while staying at home, and submitted inaccurate timesheets. He was terminated in April 2017 for “untruthfulness, neglect of duty, and insubordination”.
• Immediate New Role: Within days, he was hired as a deputy sheriff and school resource officer in Columbus County. He quickly gained the trust of his sheriff, school administrators, and students.
• Certification Denial: Because deputy sheriffs must be certified by the Sheriffs’ Education and Training Standards Commission, Devalle applied for certification. The Commission’s Probable Cause Committee reviewed his Highway Patrol misconduct and denied certification for lack of good moral character.

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The Hearings and Appeals

• Administrative Law Judge (2019): At a contested case hearing, the Columbus County sheriff and a high school principal testified strongly on Devalle’s behalf. They described him as dependable, dedicated, and rehabilitated. But the ALJ found Devalle’s own testimony evasive and lacking candor. Despite this, the ALJ concluded he had been rehabilitated and recommended certification.
• Commission Decision (2020): The Sheriffs’ Commission rejected that recommendation, emphasizing Devalle’s dishonesty both at the Patrol and in his testimony. It indefinitely denied certification.
• Superior Court (2021): A trial judge reversed, finding the Commission’s decision unsupported by substantial evidence.
• Court of Appeals (2023): Affirmed the trial court, holding that the Commission acted arbitrarily by applying inconsistent standards compared to an earlier case.
• Supreme Court (2025): Reversed. The high court held that substantial evidence supported the Commission’s decision to deny certification.

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The Supreme Court’s Reasoning

Chief Justice Newby’s majority opinion emphasized several key points:

1. Honesty and Candor Are Core to Moral Character. The Court reiterated that “good moral character” includes honesty, integrity, sincerity, and forthrightness — qualities familiar to all North Carolinians.
2. Substantial Evidence Test. Courts reviewing agency decisions do not re-weigh evidence but ask only if there is substantial evidence supporting the decision. The Commission’s finding that Devalle was evasive under oath was enough.
3. One Incident Can Be Enough. While character is usually judged holistically, severe misconduct — such as falsifying time records for pay — can justify denial.
4. Timing Matters. The Court clarified that moral character is assessed at the time of the application, not years later after possible rehabilitation. Because Devalle applied just days after his termination, his misconduct weighed heavily against him.

The Court nonetheless encouraged the Commission to provide a clearer definition of “good moral character” in its rules to give officers more guidance.

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The Dissent

Justice Riggs, joined by Justice Earls, disagreed. She argued:

• The Commission failed to investigate Devalle’s more recent service as a deputy and school resource officer.
• His strong record of rehabilitation and community service was discounted unfairly.
• Good moral character should be judged at the time of the Commission’s decision, not only at the time of the application.
• The Commission’s reliance on whether Devalle was “sufficiently self-flagellating” in testimony created a vague and arbitrary standard.

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Lessons from Devalle

1. For Officers: Past dishonesty, particularly falsifying records, can have career-ending consequences. Rehabilitation is possible, but officers must demonstrate forthrightness when testifying.
2. For Agencies: Demeanor at hearings matters. Being evasive or defensive may outweigh even strong community testimony of good character.
3. For Practitioners: Judicial review of Commission decisions is deferential. Courts will uphold the agency if there is “substantial evidence,” even if the reviewing court might have reached a different conclusion.
4. For the Law: While the Court upheld the Commission’s decision, both the majority and dissent acknowledged the need for clearer rules to define “good moral character.”

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Conclusion

Devalle underscores that for law enforcement officers in North Carolina, integrity is non-negotiable. Good moral character is more than the absence of misconduct — it is the consistent practice of honesty and candor, even under pressure.

For those facing certification reviews or disciplinary action, the case serves as a reminder: one serious lapse can overshadow years of good service, and credibility before the Commission is often decisive.

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Adkins Law, PLLC — Huntersville, North Carolina

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