Justia Criminal Law Opinion Summaries

Articles Posted in North Carolina Supreme Court
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The Supreme Court held that Defendant could not be separately convicted and punished for the offenses of both habitual misdemeanor assault and felony assault inflicting serious bodily injury stemming from the same act. After a jury trial, Defendant was found guilty of habitual misdemeanor assault and felony assault. The court of appeals vacated the trial court's judgment on the offense of habitual misdemeanor assault, holding that the trial court erred in entering judgment and sentencing Defendant for both habitual misdemeanor assault and felony assault given that both offenses arose from the same act. The Supreme Court affirmed as modified, holding that (1) Defendant could not be separately convicted and punished for both misdemeanor assault and felony assault based on the same conduct; but (2) Defendant's conviction for habitual misdemeanor assault should have been arrested rather than vacated. View "State v. Fields" on Justia Law

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For the reasons articulated in State v. Ramseur, N.C. Jun. 5, 2020, the Supreme Court vacated the orders of the trial court concluding that the claims in Defendant's second motion for appropriate relief (MAR) pursuant to the North Carolina Racial Justice Act (RJA) and amended RJA MAR were void due to the repeal of the RJA, holding that the evidentiary provisions contained in the original, unamended RJA applied to the adjudication of Defendant's RJA claims. In 1993, Defendant was convicted of one count of first-degree murder and sentenced to death. In 2010, Defendant filed his second RJA MAR arguing that he was entitled to a sentence of life imprisonment without the possibility of parole. In 2012, the General Assembly amended the RJA. Thereafter, Defendant filed an amendment to his RJA MAR. In 2013, the General Assembly repealed the RJA. Defendant then filed a second amendment to his RJA MAR. The trial court denied as being without merit and as being procedurally barred all of Defendant's claims under the RJA. The Supreme Court vacated the trial court's orders, holding (1) the RJA repeal and the 2012 amendments to the RJA cannot be constitutionally applied in Defendant's case; and (2) the trial court erred by denying Defendant's RJA claims without a hearing. View "State v. Burke" on Justia Law

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The Supreme Court reversed the judgment of the trial court dismissing Defendant's motion seeking relief pursuant to the newly enacted North Carolina Racial Justice Act (RJA) on the basis that the RJA had been repealed before the trial court ruled on Defendant's motion, holding that applying the repeal retroactively violates the constitutional prohibition on ex post facto laws. In 2010, Defendant was convicted of two counts of first-degree murder and sentenced to death. Defendant subsequently brought his RJA motion, claiming that race was a significant factor in the decision to seek or impose the death penalty. In 2012, the General Assembly amended the RJA. In 2013, the General Assembly repealed the RJA in its entirety. The trial court dismissed Defendant's RJA claims, concluding that this repeal rendered Defendant's pending motion void. The Supreme Court reversed, holding that the RJA repeal and the provisions of the amended RJA altering the evidentiary requirements for an RJA claim constitute impermissible ex post facto laws and cannot constitutionally be applied retroactively to Defendant's pending RJA claims. View "State v. Ramseur" on Justia Law

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The Supreme Court modified and affirmed the decision of the court of appeals affirming the trial court's determination that Defendant failed to demonstrate a fair and just reason for the withdrawal of his guilty plea, holding that the trial court did not err in denying Defendant's motion to withdraw his guilty plea. Defendant pled guilty to second-degree murder, robbery with a dangerous weapon, and conspiracy to commit robbery. Defendant later filed a motion to withdraw his guilty plea. The trial court denied Defendant's motion. The court of appeals affirmed after considering and applying the factors identified by the Supreme Court in State v. Handy, 391 S.E.2d 159 (N.C. 1990). The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to withdraw his guilty plea based upon the trial court's ruling that Defendant failed to show any fair and just reason for the withdrawal of his guilty plea; and (2) this Court disavows the dicta contained in the court of appeals' decision regarding the subject of prejudice to the State after the court's stated conclusion that Defendant had not satisfied the Handy factors. View "State v. Taylor" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming superior court judgments denying Defendant's Batson motion, holding that Defendant presented a sufficient record to permit meaningful appellate review of Defendant's Batson challenge and that Defendant established the existence of a prima facie case of discrimination necessary to require the performance of a complete Batson analysis. The trial court allowed Defendant to make a Batson motion but subsequently denied the motion, finding that there was no prima facie showing justifying the Batson challenge. The court of appeals also rejected Defendant's Batson claim, stating that, "[a]ssuming, arguendo, that defendant's argument is properly before us, we find no error in the ruling of the trial court and affirm." The Supreme Court reversed and remanded the case for further proceedings in the superior court, holding (1) the record was sufficient to permit appellate review of the merits of Defendant's Batson claim; and (2) the trial court erred in failing to find the existence of a prima facie showing of racial discrimination. View "State v. Bennett" on Justia Law

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The Supreme Court held that the trial court erred by failing to summarily deny the applications for the issuance of a writ of habeas corpus submitted by Petitioners, Carlos Chavez and Luis Lopez, for its consideration in this case. A sheriff entered into an agreement with the United States Immigration and Customs Enforcement pursuant to section 287(g) of the Immigration and Nationality Act, 8 U.S.C. 1357, that certified deputies to perform specific immigration enforcement functions, including the detention of undocumented aliens. Petitioners, who were being held in pretrial detention pursuant to immigration-related arrest warrants and detainers, filed petitions seeking the issuance of a writ of habeas corpus. The trial court issued writs of habeas corpus. The court of appeals vacated the trial court orders, concluding that the trial court lacks jurisdiction to issue writs of habeas corpus for alien petitions not in state custody and held under federal authority. The Supreme Court reversed in part, holding that state judicial officials acting in counties in which the sheriff has entered into a 287(g) agreement with the federal government do not have the authority to grant applications for the issuance of writs of habeas corpus for and to order the release of individuals held pursuant to immigration-related arrest warrants and detainers. View "Chavez v. McFadden" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction for solicitation by computer or electronic device of a person believed to be fifteen years of age or younger for the purpose of committing an unlawful sex act and appearing at the location where he was supposed to meet the person he believed was a child, holding that the trial court committed prejudicial error by failing to instruct the jury on the defense of entrapment. On appeal, the court of appeals held that the trial court's refusal to instruct the jury on entrapment was not error because the evidence failed to support the instruction. The Supreme Court reversed, holding (1) Defendant presented evidence which a reasonable juror could find credible to demonstrate that he did not have a willingness or predisposition to engage in sexual activity with a minor; (2) Defendant's arguments at trial were consistent with the defense of entrapment and should not bar the availability of the defense; and (3) the trial court's failure to instruct the jury on entrapment was prejudicial, and Defendant was entitled to a new trial. View "State v. Keller" on Justia Law

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The Supreme Court reversed the decision of the court of appeals that vacated Defendants' convictions for certain charges, holding that when the prosecutor moved to amend the arrest warrant to correctly state the name of the property owner and did so by filing a statement of charges form after arraignment, the superior court properly considered and allowed the change. At issue was whether the prosecutor lost the right to amend the criminal warrant in this case when the amendment was filed on a statement of charges form after Defendant's arraignment. The court of appeals held that because Defendant was tried under a statement of charges that was filed after arraignment and because the sufficiency of the original arrest warrant had not been contested, the statement of charges was untimely and the superior court had no jurisdiction to try the case under that charging document. The Supreme Court reversed, holding (1) regardless of the label, such a change is still an amendment and no statutory provision limits the filing of a statement of charges in this way; and (2) therefore, the trial court did not err in proceeding under the amended pleading. View "State v. Capps" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the order of the trial court denying Defendant's motion to suppress evidence seized during the execution of a search warrant, holding that the warrant supported by probable cause. Defendant pled guilty to the offense of trafficking in cocaine while preserving his right to appeal the denial of his motion to suppress. On appeal, Defendant argued that the trial court erred in denying his motion to suppress because the facts contained in the affidavit were insufficient to establish probable cause to search his residence. The court of appeals affirmed. The Supreme Court affirmed, holding that the affidavit contained facts that were sufficient to provide a nexus between the residence and suspected criminal activity, and therefore, the warrant was supported by probable cause. View "State v. Bailey" on Justia Law

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The Supreme Court reversed Defendant's conviction, holding that the trial court clearly erred in ruling that Defendant failed to prove purposeful discrimination with respect to the State's use of peremptory challenges to strike three jurors without considering all of the evidence presented by Defendant. Defendant was found guilty of one count of first-degree murder and other crimes. On appeal, Defendant argued that the trial court erred by failing to grant three objections that he made under Batson v. Kentucky, 476 U.S. 79 (1986). The court of appeals affirmed Defendant's convictions. The Supreme Court reversed, holding (1) the court of appeals erred in its analysis of Defendant's Batson claims with respect to the three jurors; and (2) as to all three jurors, remand was required for reconsideration of whether Defendant proved purposeful discrimination in each case. View "State v. Hobbs" on Justia Law