It happened around 11 a.m. at the conclusion of a hearing when a deputy was escorting two female defendants because of concerns about potential retaliation from a previous incident.
As they left the courtroom, a group in the hallway began to assault the two women, the sheriff's office said, and someone in the crowd deployed pepper spray.
Jellese Chance, 32, Nickitta Chance, 28 and Tatianna Osborne, 25, were charged with simple assault.
The sheriff's office said it believed all the people involved knew each other and that the brawl was linked to a separate, ongoing criminal investigation in Durham.
Nickitta Chance was being held at the Durham County Detention Center because of pending charges in an unrelated criminal case. Jellese Chance and Osborne were released on a written promise to appear.
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