By Miles Layton

RALEIGH — A unanimous panel of the North Carolina Court of Appeals on Tuesday upheld the dismissal of a lawsuit filed by Gates County’s longtime elections director, concluding that her claims of tortious interference, illegal surveillance, and racial conspiracy were not supported by sufficient factual allegations.

The three-judge panel affirmed a March 2025 ruling by Cindy King Sturges, a Superior Court judge who had dismissed all claims brought by former Gates County Director of Elections Clytia Riddick against County Manager Scott Sauer and Human Resources Director Warren Perry.

Christy Gaskins is the current Gates County Board of Elections director.

Writing for the court, Judge John S. Arrowood, joined by Chief Judge Chris Dillon and Judge Jefferson Griffin Stading, concluded that Riddick’s complaint failed to meet even the relatively low threshold required at the pleading stage.

The panel’s decision brings to a close, at least for now, a contentious legal dispute rooted in a late-2023 disagreement over pay, timekeeping, and workplace oversight.

Dispute Rooted in Pay and Timekeeping

Riddick, who has served as Director of Elections in Gates County since 2010, filed her lawsuit in August 2024 following a dispute that began in December 2023. At the center of the conflict was how her work hours were recorded and compensated.

According to court filings, Riddick had historically submitted signed time sheets to the chairman of the Gates County Board of Elections, who then forwarded them to the county payroll office. That process, she alleged, came under scrutiny when Perry and Sauer began reviewing her reported hours more closely.

Riddick claimed Perry examined security camera footage from the Board of Elections office parking lot and used it to determine when her vehicle was present. Based on those observations, she alleged, Perry reduced her reported hours and caused deductions from her paycheck.

She further alleged that the actions taken by Perry and Sauer were arbitrary, malicious, and outside the scope of their official duties. Her complaint described what she characterized as “constant, repetitious, and malicious intimidation and harassment.”

Riddick argued that her annual salary of $43,610, set in July 2023, should not have been subject to reduction based on hours worked. However, her complaint did not specify the total amount of wages she claimed were withheld or identify the exact dates of any alleged deductions.

Despite the dispute, Riddick has remained in her position throughout the litigation.

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Court Rejects Contract Interference Claim

One of Riddick’s primary claims was that Perry and Sauer unlawfully interfered with what she argued was a contractual right to a fixed annual salary.

She based that argument on a provision of North Carolina law governing compensation for county elections directors. But the appeals court found her interpretation of the statute unpersuasive.

Instead, the court pointed to the plain language of the law, which requires county commissioners to compensate elections directors “for hours worked in attendance to his or her duties,” subject to a minimum hourly rate.

The panel also noted that Riddick’s own description of her employment practices undermined her claim. By submitting time sheets and having those hours reviewed and approved, she effectively acknowledged that her compensation was tied to hours worked rather than a guaranteed annual sum.

“Reading her pled facts as true, the ‘straightforward’ payment process shows that her compensation was always based upon the hours she worked, or claimed to work,” the court wrote.

The judges further concluded that Riddick failed to demonstrate that Perry and Sauer acted without justification — a necessary element of a tortious interference claim. Under state law, actions taken for legitimate business purposes, such as financial oversight, are generally considered justified.

“This leaves us with only facts that show an administrator balancing the books,” the court stated, rejecting her assertion that malice alone drove the defendants’ actions.

Surveillance Allegations Deemed Insufficient

Riddick also accused the defendants of conducting illegal surveillance, alleging that they used cameras within the Board of Elections office to secretly monitor and record her conversations.

She brought that claim under North Carolina’s Electronic Surveillance Act, which allows civil lawsuits for unlawful interception of communications.

But the appeals court found that her complaint offered little more than speculation.

The only concrete facts she presented, the court noted, were that Perry reviewed parking lot footage to verify her presence at work and that the county hired an information technology employee to service the camera system.

Those facts, the panel held, did not come close to establishing unlawful surveillance. Observing a parking lot does not constitute intercepting a communication, the court explained, and hiring a technician does not imply improper monitoring.

In one of the opinion’s most pointed passages, the court described the surveillance claim as “a repetitive pastiche of paranoia and irrational conjecture.”

The judges also suggested that the county’s use of cameras likely fell within legal exceptions that allow employers to monitor systems they own and maintain, particularly when done for legitimate purposes such as safeguarding public resources.

Civil Rights Allegations Fail

Riddick’s most serious allegation — that Perry and Sauer conspired against her because of her race — was likewise dismissed.

She claimed the defendants harbored animosity toward her as a Black woman and acted to interfere with her ability to earn a living. The lawsuit invoked a state civil rights statute that requires proof of a conspiracy motivated by racial or other protected-class bias, along with acts such as threats, force, or repeated harassment.

The court found that her complaint fell far short of that standard.

“It asserts a civil rights claim without making even one connection between Plaintiff’s facts and her claim that racial hatred motivated Defendants,” the opinion stated.

The judges emphasized that even at the early stages of litigation, plaintiffs must provide at least some factual basis supporting allegations of discrimination. In this case, they found “no such scintilla” of evidence linking the defendants’ actions to racial animus.

The court also pointed out that Riddick described only a single interaction with Perry and none with Sauer, undermining her claim of repeated harassment or coordinated conspiracy.

Additionally, the panel noted that her complaint did not allege that either defendant attempted to remove her from her position, temporarily or permanently — another factor weakening her case.

Finally, the court observed that Riddick had alternative legal remedies available, such as pursuing a wage claim under state law, which further undercut her constitutional claims.

Decision Affirms Lower Court Ruling

In affirming the trial court’s dismissal with prejudice, the Court of Appeals found no error in the earlier ruling by Judge Sturges.

A dismissal “with prejudice” means the claims cannot be refiled, effectively ending this particular case unless further appealed to a higher court.

Riddick was represented by attorney Ralph T. Bryant Jr. of the Ralph Bryant Law Firm, while Perry and Sauer were represented by Mary Craven Adams of the law firm Womble Bond Dickinson.

The case was argued before the appellate panel on February 25 and decided on March 18.

Broader Implications

The ruling underscores the importance of factual specificity in civil litigation, particularly in cases involving serious allegations such as discrimination and illegal surveillance.

While courts generally allow cases to proceed past the initial pleading stage if claims are plausibly supported, the panel made clear that conclusory statements — even when strongly worded — are not enough.

The decision also highlights the authority of local government administrators to monitor employee timekeeping and use available tools, such as security footage, to ensure accountability in the use of public funds.

For county governments across North Carolina, the case may serve as a reference point for how courts view disputes involving payroll oversight and workplace monitoring.

For Riddick, the ruling represents a significant legal setback, though the possibility remains that she could seek review from the Supreme Court of North Carolina.

Absent further appeal, however, the appellate court’s decision brings a definitive end to a lawsuit that raised serious allegations but, in the court’s view, lacked the factual foundation required to move forward.