Articles Posted in North Carolina Supreme Court

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The North Carolina Supreme Court held that the State failed to carry its burden of presenting sufficient evidence to support the trial court's decision to revoke defendant's probation based upon a finding that defendant willfully absconded probation. Therefore, the court affirmed the decision of the court of appeals. However, the court disavowed the portion of the opinion analyzing the pertinence of the fact that defendant's probationary term expired prior to the date of the probation violation hearing and holding "that the trial court lacked jurisdiction to revoke defendant’s probation after his case expired." View "State v. Krider" on Justia Law

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The Supreme Court held that the court of appeals erred in reversing the trial court’s denial of Defendant’s motion to suppress, holding that the suppression motion contained sufficient findings of fact to support the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights pursuant to N.C. Gen. Stat. 7B-2101 before making certain incriminating statements. The court of appeals determined that the totality of the circumstances set forth in the record did not fully support the trial court’s conclusion that Defendant knowingly, willingly, and understandingly waived his juvenile rights. The Supreme Court reversed, holding (1) the trial court’s findings of fact had adequate evidentiary support, and those findings supported the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights; and (2) in reaching a contrary conclusion, the court of appeals failed to focus upon the sufficiency of the evidence to support the trial court’s findings of fact and to give proper deference to those findings. View "State v. Saldierna" on Justia Law

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The Supreme Court held in this criminal case that while the claim asserted in Defendant’s motion for appropriate relief was not subject to the procedural bar established by N.C. Gen. Stat. 15A-1419(a)(3), the trial court did not err by denying Defendant’s motion for the reasons stated by the court of appeals. The jury returned a verdict convicting Defendant of first-degree murder, and the trial court sentenced Defendant to a term of life imprisonment without parole. Defendant later filed a motion for appropriate relief asserting, among other things, that his constitutional right to effective, conflict-free trial counsel had been violated. The trial court denied Defendant’s motion after conducting an evidentiary hearing. The Supreme Court concluded that Defendant’s ineffective assistance of counsel claim was not procedurally barred and overturned the trial court’s order denying Defendant’s motion for appropriate relief. The Supreme Court affirmed in part and reversed in part, holding (1) Defendant was not subject to the procedural bar created by N.C. Gen. Stat. 15A-1419(a)(3) with respect to his ineffective assistance of counsel claim; but (2) the trial court properly denied Defendant’s motion for appropriate relief. View "State v. Hyman" on Justia Law

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The Supreme Court held that the habitual felon indictment returned against Defendant was not fatally defective, and therefore, the court of appeals erred in ordering that the judgment regarding the habitual conviction be vacated. Defendant was charged with assault with a deadly weapon with the intent to kill, attempted first-degree murder, having attained habitual felon status, and other charges. The jury found Defendant guilty as charged. On appeal, Defendant argued that the habitual felon indictment that had been returned against him was facially defective. The court of appeals agreed and ordered that the case be remanded for resentencing on the underlying felonies without the habitual felon enhancement. The Supreme Court reversed, holding that the habitual felon indictment returned against defendant was not fatally defective. View "State v. Langley" on Justia Law

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The Supreme Court held that the trial court correctly denied Defendant’s motion to dismiss as to the charge of keeping or maintaining a vehicle which is used for the keeping or selling of controlled substances, holding that it can be reasonably be inferred from the evidence that Defendant had kept the car that he was driving and that he was using that car to store crack cocaine when he was arrested. Defendant was pulled over by law enforcement officers during a drug investigation. The officers discovered two bags of crack cocaine hidden behind the gas-cap door of the car that Defendant was driving. Defendant was indicted for several offenses. The trial court granted Defendant’s motion to dismiss as to the possession-of-cocaine charge but denied the motion as to all other remaining charges. The jury found Defendant guilty of all of these charges. The court of appeals reversed Defendant’s conviction for keeping or maintaining a vehicle which is used for the keeping or selling of a controlled substance, concluding that there was insufficient evidence to support the charge. The Supreme Court disagreed, holding that viewing the evidence in the light most favorable to the State and drawing all reasonable inferences from that evidence, a reasonable jury could find that Defendant committed the crime at issue. View "State v. Rogers" on Justia Law

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The Supreme Court held that the two-year statute of limitations in N.C. Gen. Stat. 15-1 did not bar the State from prosecuting Defendant for the misdemeanor offense of driving while impaired (DWI) when the State did not charge Defendant by indictment or presentment and did not commence prosecution with the two-year period because other valid criminal pleadings listed in N.C. Gen. Stat. 15A-921 tolled the section 51-1 statute of limitations. The district court granted Defendant’s motion to dismiss, determining that the statute of limitations in section 15-1 barred further prosecution of Defendant. The court of appeals affirmed, concluding that the State was barred from prosecuting this action due to expiration of the statute of limitations. The Supreme Court reversed, holding (1) any criminal pleading that establishes jurisdiction in the district court should toll the two-year statute of limitations in section 15-1; and (2) the citation issued to Defendant for DWI tolled the statute of limitations in this case. View "State v. Curtis" on Justia Law

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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