Articles Posted in North Carolina Supreme Court

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The Supreme Court affirmed Defendant’s conviction for first-degree murder but vacated his sentence of death and remanded the case to the superior court for a new capital sentencing hearing. The Court held (1) there was no error in the trial court proceedings, including jury selection or the guilt phase, that led to Defendant’s conviction; (2) the evidence was sufficient to support the conviction; (3) the trial court did not err by denying Defendant’s motion to set aside the jury’s verdict in favor of the State with respect to the issue of Defendant’s alleged intellectual disability; (4) the trial court erred by failing to submit the statutory mitigating circumstance enumerated in N.C. Gen. Stat. 15A-2000(f)(6), which addresses the extent to which Defendant’s capacity to appreciate the criminality of his conduct or to conform his conduct to the law was impaired, to the jury at Defendant’s capital hearing. View "State v. Rodriguez" on Justia Law

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A police officer’s decision to briefly detain Defendant for questioning was supported by a reasonable suspicion of criminal activity. Defendant was indicted for robbery with a dangerous weapon. Defendant moved to suppress evidence obtained as a result of his seizure by the police officer, asserting that he had been unlawfully detained, in violation of his constitutional rights. The trial court denied the motion to suppress, and Defendant was subsequently convicted of common law robbery. The court of appeals ordered a new trial, concluding that the trial court committed prejudicial error by denying Defendant’s suppression motion and that the police officer lacked reasonable suspicion to detain Defendant for questioning. The Supreme Court reversed, holding that the undisputed facts established reasonable suspicion necessary to justify Defendant’s seizure. View "State v. Nicholson" on Justia Law

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The Supreme Court reversed the decision of the court of appeals in vacating the judgments entered by the trial court based upon Defendant’s convictions for first-degree murder and attempted first-degree murder on the grounds that certain evidence had been admitted in violation of the Confrontation Clause. The court of appeals concluded that the statements at issue were admitted in violation of Defendant’s constitutional right to confront the State’s witnesses against him. The Supreme Court reversed, holding that the trial court did not err by overruling Defendant’s confrontation-based objection and allowing the admission of the challenged evidence. View "State v. Miller" on Justia Law

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The absence of a procedural rule limits neither the court of appeals’ jurisdiction nor its discretionary authority to issue writs of certiorari. Defendant was charged with driving while impaired. After the trial court denied Defendant’s motion to dismiss Defendant pleaded guilty to driving while impaired. Under the plea agreement, Defendant retained the right to appeal the denial of her motion to dismiss. Defendant then filed a notice of appeal and petitioned the court of appeals for review by writ of certiorari. The court of appeals denied Defendant’s petition for writ of certiorari and dismissed the appeal, holding that although it had jurisdiction to issue the writ, it lacked a procedural mechanism under Rule 21 of the North Carolina Rules of Appellate Procedure to do so without further exercising its discretion to invoke Rule 2 to suspend the Rules. The Supreme Court reversed, holding that the court of appeals had both the jurisdiction and the discretionary authority to issue Defendant’s writ of certiorari. View "State v. Ledbetter" on Justia Law

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Defendant’s Fourth Amendment claims were not reviewable on direct appeal, even for plain error, because Defendant completely waived them. A police officer found cocaine in Defendant’s coat pocket during a traffic stop. Defendant did not move in liming to suppress evidence of the cocaine, nor did Defendant object to the State’s use of the cocaine evidence at any point during his trial. On appeal, Defendant argued that the trial court plainly erred by admitting evidence of the cocaine and that the seizure of the cocaine violated his rights under the Fourth Amendment. The court of appeals ordered a new trial, concluding that the trial court committed plain error by admitting evidence of the cocaine. The Supreme Court reversed, holding that Defendant waived his Fourth Amendment claims by not moving to suppress evidence of the cocaine before or after trial. The Court remanded the case for consideration of Defendant’s ineffective assistance of counsel claim because the court of appeals did not reach this claim. View "State v. Miller" on Justia Law

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The Supreme Court affirmed Defendant’s convictions for first-degree murder, sexual offense of a child by a adult offender, and other crimes and his sentence of death, holding that there was no error in Defendant’s trial or sentencing and that Defendant’s death sentence was not disproportionate to his crimes. Among other things, the Supreme Court held (1) Defendant failed to meet his burden under Strickland v. Washington, 466 U.S. 668 (1984), of establishing that he received ineffective assistance of counsel; (2) Defendant failed to identify any error in the trial court’s evidentiary rulings; (3) the trial judge did not abuse his discretion in denying Defendant’s motions for a mistrial based upon an improper remark by the prosecutor during closing arguments; (4) there was no error in the jury instructions; (5) Defendant received a capital sentencing proceeding free of prejudicial error; and (6) the death sentence was not excessive or disproportionate. View "State v. McNeill" on Justia Law

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At issue was the validity of the procedures prescribed in N.C. Gen. Stat. 15A-1340.19A - 15A-1340.19(D) (the Act) for the sentencing of juveniles convicted of first-degree murder in light of Miller v. Alabama, 467 U.S. 460 (2012) and its progeny. Defendant was convicted of first-degree murder and other crimes he committed when he was sixteen years old. Defendant was sentenced to life imprisonment without the possibility of parole for the murder conviction, a sentence that was then mandatory. After Miller was decided, the trial court resentenced Defendant to life imprisonment without parole. On appeal, Defendant challenged the constitutionality of the Act. The Court of Appeals upheld the constitutionality of the Act but reversed the resentencing judgment, concluding that the trial court failed to make adequate findings of fact to support its decision to impose the sentence. The Supreme Court modified and affirmed, holding (1) the Act does not incorporate a presumption in favor of a sentence of life without parole upon juveniles convicted of first-degree murder on the basis of a theory other than the felony murder rule; (2) the Act is not impermissibly vague, conducive to the imposition of arbitrary punishments, or an unconstitutional ex post facto law; and (3) further sentencing proceedings are required in this case. View "State v. James" on Justia Law

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There was sufficient evidence of restraint that was separate and apart from that inherent in the commission of Defendant’s first-degree sexual offense to support Defendant's second-degree kidnapping conviction. Defendant was convicted of several offenses, including felonious breaking or entering, first-degree sexual offense, second-degree kidnapping, misdemeanor assault inflicting serious injury, and intimidating a witness. The court of appeals vacated Defendant’s conviction for second-degree kidnapping, concluding that the evidence was insufficient to prove that any restraint was separate and apart from the force necessary to facilitate the sex offense. The Supreme Court reversed, holding that the State presented sufficient evidence of the element of restraint that was separate and apart from that inherent in the commission of the sex offense. View "State v. China" on Justia Law

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The Supreme Court reversed the decision of the court of appeals determining that the trial court did not err in excluding evidence of the complainant’s history of sexually transmitted diseases (STDs) pursuant to N.C. R. Evid. 412(b)(2) where other evidence showed that Defendant was not infected with those STDs. Defendant was found guilty of first-degree sex offense with a child. On appeal, Defendant argued that the trial court erred by excluding evidence of the complainant’s history of STDs because its inclusion would have made sexual contact between the complainant and Defendant less likely, thereby qualifying for the Rule 412(b)(2) exception. The court of appeals disagreed, concluding that the exception was not applicable in this case. The Supreme Court reversed, holding that Defendant’s offer of proof indicated that the STD evidence fell within the Rule 412(b)(2) exception, and therefore, the court of appeals erred in ruling that there was no error in the trial court’s exclusion of the evidence. View "State v. Jacobs" on Justia Law

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The Supreme Court reversed the decision of the court of appeals determining that the trial court did not err in excluding evidence of the complainant’s history of sexually transmitted diseases (STDs) pursuant to N.C. R. Evid. 412(b)(2) where other evidence showed that Defendant was not infected with those STDs. Defendant was found guilty of first-degree sex offense with a child. On appeal, Defendant argued that the trial court erred by excluding evidence of the complainant’s history of STDs because its inclusion would have made sexual contact between the complainant and Defendant less likely, thereby qualifying for the Rule 412(b)(2) exception. The court of appeals disagreed, concluding that the exception was not applicable in this case. The Supreme Court reversed, holding that Defendant’s offer of proof indicated that the STD evidence fell within the Rule 412(b)(2) exception, and therefore, the court of appeals erred in ruling that there was no error in the trial court’s exclusion of the evidence. View "State v. Jacobs" on Justia Law