In 2013, the New Hanover County Commission voted 3-2 to remove Commissioner Brian Berger from office during an amotion hearing, with Berger and Commissioner Jonathan Barfield voting against the decision. While North Carolina does not allow for the recall of elected officials, the board used a centuries-old common law process known as “amotion” to oust Berger from his seat. However, just four months later, a Superior Court judge overturned the decision, reinstating Berger to the board.

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