Sara Lee Corp. v. Carter

In Sara Lee Corp. v. Carter, 351 N.C. 27, 35, 519 S.E.2d 308, 313 (1999), "overwhelming evidence presented at trial led the trial court to conclude, inter alia, that defendant engaged in fraud, breach of fiduciary duty, and unfair and deceptive acts or practices. The trial court then ordered that 'a constructive trust for the benefit of plaintiff is hereby imposed over any and all workers' compensation benefits that defendant is or shall be entitled to receive.'" On appeal, the defendant argued that G.S. 97-21 barred the trial court's imposition of a constructive trust. The North Carolina Supreme Court disagreed, holding that the statutory language "does not preclude the trial court from imposing the equitable remedy of a constructive trust . . . under this extraordinary and unique set of facts." Id. at 35-36, 519 S.E.2d at 313-14. The holding in Sara Lee was based on the "extraordinary and unique" facts of that case, and upheld the trial court's imposition of the equitable remedy of a constructive trust, not a claimant's advance assignment of workers' compensation benefits.