Paradigm Consultants, Ltd. v. Builders Mutual Insurance, 228 N.C. App. 314

Paradigm sued BMI for breach of contract, bad faith, and UDTP related to BMI's coverage for settlement proceeds.
Raymonds previously sued Paradigm; BMI issued a reservation of rights indicating no coverage during relevant periods.
Paradigm settled with the Raymonds and sought BMI coverage for the settlement amount.
Trial court granted partial summary judgment to Paradigm on BMI's champerty/maintenance defense but denied other issues; order was interlocutory.
BMI and Paradigm appealed the interlocutory order, which the court dismissed for lack of a substantial right under Rule 54(b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the order appealable as to BMI’s duty to defend	BMI argues the order affects a substantial right.	Paradigm argues Lambe controls and supports appeal.	No substantial right; order not final or certifiable.
Does Lambe Realty apply given the underlying litigation had concluded	BMI cannot rely on ongoing defense duties.	Paradigm relies on Lambe to show immediate appealability.	Lambe not controlling; no substantial right.
Did the trial court err in dismissing champerty and maintenance defense	Dismissal voids the settlement-based basis for BMI's purported duties.	Court appropriately resolved that defense.	Affirmed dismissal of champerty/maintenance defense.
Was Rule 54(b) certification required for appealability	Certification would permit an immediate appeal.	No certification existed.	Lack of certification means interlocutory appeal improper.

Veazey v. City of Durham, 231 N.C. 357 (1950) (defines interlocutory vs final judgments)
Goldston v. Am. Motors Corp., 326 N.C. 723 (1990) (no general right to immediate appeal from interlocutory orders)
Johnson v. Lucas, 168 N.C. App. 515 (2005) (requires substantial-right showing in interlocutory appeals)
Lambe Realty Inv., Inc. v. Allstate Ins. Co., 137 N.C. App. 1 (2000) (duty to defend as a substantial right; distinguishable facts)