Articles Posted in North Carolina Supreme Court

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The Supreme Court affirmed the decision of the Court of Appeals vacating Defendant’s conviction for felony littering upon concluding that the indictment failed to allege an essential element of the statutory crime and was fatally defective, holding that the indictment was facially invalid. In concluding that the indictment was fatally defect, the Court of Appeals held that the trial court lacked jurisdiction over Defendant, and therefore, the conviction must be vacated. The Supreme Court affirmed, holding that N.C. Gen. Stat. 14-399(a)(1), which requires that the accused be an unauthorized person depositing refuse on land not designated by the State for such a use, is an essential element of the crime of felony littering rather than an affirmative defense. View "State v. Rankin" on Justia Law

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The Supreme Court modified and affirmed the decision of the Court of Appeals concluding that Defendant’s inculpatory statements to law enforcement should have been suppressed but that the error was harmless, holding that the trial court correctly concluded that, under the totality of the circumstances, Defendant’s inculpatory statements were voluntary. On appeal, the Court of Appeals determined that Defendant’s inculpatory statements were involuntary and inadmissible because they were given under the influence of fear or hope caused by the interrogating officers’ statements and actions but that the admission of the statements was harmless beyond a reasonable doubt due to the overwhelming additional evidence of Defendant’s guilt. The Supreme Court modified and affirmed, holding (1) the trial court erred in merging the Miranda and voluntariness inquiries; (2) Defendant did not preserve his argument that officers employed the “question first, warn later” technique to obtain Defendant’s confession; and (3) the trial court correctly concluded that the Miranda requirements were met and that Defendant’s statements to the officers were voluntarily made. View "State v. Johnson" on Justia Law

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The Supreme Court reversed the decision of the Court of Appeals reversing and vacating Defendant’s conviction of being a felon in possession of a firearm and reversing the trial court’s denial of Defendant’s motion to suppress evidence of the firearm, holding that both the search and seizure of Defendant in this case were supported by individualized suspicion and thus did not violate the Fourth Amendment. On appeal, the Court of Appeals held that the search was invalid because it was not supported by reasonable suspicion. The Supreme Court reversed, holding (1) the rule announced in Michigan v. Summers, 452 U.S. 692 (1981), justified the seizure because Defendant posed a real threat to the safe and efficient completion of the search; and (2) the warrantless detention and search of Defendant did not violate the Fourth Amendment. View "State v. Wilson" on Justia Law

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The Supreme Court reversed the decision of the court of appeals vacating the judgment entered by the trial court convicting Defendant of possession of a firearm by a felon and having attained habitual felon status on the grounds that the trial court erred in instructing the jury that it could convict Defendant based upon a constructive possession theory that lacked sufficient evidentiary support. The Supreme Court held that the court of appeals erred by holding (1) challenges to jury instructions allowing juries to convict criminal defendants on the basis of legal theories that lack evidentiary support are not subject to harmless error analysis, and (2) even if such a harmlessness analysis were appropriate, there was a reasonable possibility that the outcome at Defendant’s trial would have been different had the trial court refrained from allowing the jury to convict Defendant on the basis of a constructive possession theory. Specifically, the Court held that there was not a reasonable possibility that, in the absence of the erroneous constructive possession instruction, the jury would have acquitted Defendant. View "State v. Malachi" on Justia Law

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The Supreme Court modified and affirmed the decision of the court of appeals finding no error in Defendant’s convictions and sentences. The Court of Appeals held that Defendant waived her sentencing arguments because Defendant failed to voice any objection to her sentence or the sentencing proceedings in the trial court. The Supreme Court affirmed as modified, holding (1) Defendant waived her Eighth Amendment arguments by failing to raise them before the sentencing court; (2) Defendant’s nonconstitutional sentencing issues were preserved for appellate review by statute despite her failure to lodge a contemporaneous objection but were nonetheless meritless; and (3) discretionary review was improvidently granted as to Defendant’s ineffective assistance claim. View "State v. Meadows" on Justia Law

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The Supreme Court reversed the decision of the Court of Appeals upholding Defendant’s conviction for attempted murder, holding that Defendant’s motion to dismiss was improperly denied. A jury found Defendant guilty of attempted first-degree murder and solicitation to commit first-degree murder. The Court of Appeals concluded that the trial court did not err in denying Defendant’s motion to dismiss the attempted murder charge because there was “sufficient evidence of an overt act to permit the case to go to the jury.” The Supreme Court reversed, holding (1) the Court of Appeals’ reliance upon cases from other jurisdictions, all of which had statutory frameworks different from this Court’s, provided inadequate support for its decision; and (2) the evidence did not show an “overt act” amounting to attempt as defined by North Carolina law. View "State v. Melton" on Justia Law

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The Supreme Court affirmed the decision of the Court of Appeals finding that the citation that charged the offense for which Defendant was convicted was legally sufficient to properly invoke the trial court’s subject-matter jurisdiction, holding that the trial court had subject-matter jurisdiction to enter judgment in this criminal proceeding. Defendant was convicted of operating a motor vehicle when having an open container of alcohol in the passenger compartment while alcohol remained in his system. On appeal, Defendant argued that the trial court lacked jurisdiction in this criminal matter because the citation purporting to charge him of the charged offense failed to allege all of its essential elements. The court of appeals affirmed. The Supreme Court affirmed, holding that the citation included sufficient criminal pleading contents in order to properly charge Defendant with the misdemeanor offense for which he was found guilty. View "State v. Jones" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals concluding that the trial court committed prejudicial error in three of its rulings during the trial proceedings and that Defendant was entitled to a new trial, holding that the court of appeals erred in finding error on two of the three issues but properly found prejudicial error on the first issue. A jury found Defendant guilty of assault with a deadly weapon inflicting serious injury. The court of appeals reversed, concluding that the trial court committed prejudicial error by (1) omitting the relevant stand-your-ground language from jury instructions on self-defense, (2) excluding evidence at trial of specific incidents of the victim’s violent past conduct, and (3) denying Defendant’s motion to continue. The Supreme Court reversed in part, holding (1) the Court of Appeals correctly found that Defendant was entitled to a new trial on the basis that the trial court committed reversible error in omitting the relevant stand-your-ground language from the jury instructions; but (2) the trial court did not err in excluding specific instances of the victim’s violent conduct or in denying Defendant’s motion to continue. View "State v. Bass" on Justia Law

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The Supreme Court reversed the decision of the court of appeals concluding that Defendant’s stipulation to a certain type of second-degree murder was an improper stipulation, holding that Defendant properly stipulated to the facts underlying his conviction and the conviction itself. As part of a plea agreement, Defendant stipulated to the sentencing worksheet showing his prior offenses, one of which was a second-degree murder conviction designated as a B1 offense. In so stipulating, Defendant acknowledged that the factual basis of his conviction involved general second-degree murder, a B1 classification, and did not implicate the exception for less culpable conduct involving an inherently dangerous act or omission or a drug overdose, a B2 classification. The court of appeals vacated the trial court’ judgment and set aside Defendant’s guilty plea, concluding that Defendant improperly stipulated to a matter of “pure legal interpretation.” The Supreme Court reversed, holding (1) Defendant’s stipulation was properly understood to be a stipulation to the facts of his prior offense, and those facts supported the offense’s B1 classification; and (2) the trial court properly accepted the stipulation. View "State v. Arrington" on Justia Law

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The Supreme Court reversed the decision of the court of appeals awarding Defendant a new trial because of a plain error in a jury instruction on aiding and abetting, holding that the trial court erred in giving the aiding and abetting instruction but that the error did not amount to plain error. The jury convicted Defendant of several drug crimes. The Court of Appeals granted Defendant a new trial, holding that the trial court committed plain error in giving the aiding and abetting instruction. The Supreme Court reversed, holding (1) the Court of Appeals erred in reasoning that, absent the improper aiding and abetting instruction, the jury probably would have reached a different result and erred in applying the correct stander for plain error; and (2) given the evidence of Defendant’s guilt, the trial court’s error in giving the aiding and abetting instruction did not amount to plain error. View "State v. Maddux" on Justia Law