Justia Criminal Law Opinion Summaries

Articles Posted in North Carolina Supreme Court
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The Supreme Court affirmed the decision of the court of appeals concluding that the General Assembly did not intend for the means of proof mentioned in the Habitual Felons Act, N.C. Gen. Stat. 14-7.4, to be exclusive, holding that the methods of proof listed in section 14-7.4 are not exclusive.Defendant was indicted on charges of interfering with an electronic monitoring device and attaining the status of habitual felon. Defendant was found guilty of interfering with an electronic monitoring device. During the habitual felon phase of the trial, the court introduced into evidence a computer printout from the Automated Criminal / Infraction System (ACIS) showing that Defendant had been convicted of felonious breaking and entering. The jury found that Defendant had attained the status of a habitual felon. On appeal, Defendant argued that the trial court erred by allowing into evidence the ACIS printout as proof of his prior conviction for the purpose of establishing that he was a habitual felon. The court of appeals affirmed. The Supreme Court affirmed, holding that section 14-7.4 is permissive, rather than mandatory, with respect to the issue of how a defendant's prior convictions may be established and that such convictions may be proven by means of any admissible evidence. View "State v. Waycaster" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing Defendant's convictions, holding that the State presented sufficient evidence at trial to show that Defendant possessed the felonious intent necessary to support his convictions.Defendant was convicted of conspiracy to commit robbery with a dangerous weapon, felonious breaking or entering, and discharging a weapon into an occupied property. During trial, Defendant had moved to dismiss the charges against him for insufficiency of the evidence, but the trial court denied the motion. The court of appeals reversed Defendant's conviction for conspiracy to commit robbery with a dangerous weapon and for felonious breaking or entering on the basis of insufficiency of the evidence. The Supreme Court reversed, holding that, due to the existence of sufficient evidence regarding felonious intent, the trial court properly denied Defendant's motions to dismiss the charges against him. View "State v. Cox" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing Defendant's convictions and granting Defendant a new trial, holding that the trial court erred by declining to give Defendant's requested jury instruction on self defense and the defense of habitation.After a jury trial, Defendant was found guilty of assault with a deadly weapon inflicting serious injury and possession of a firearm by a felon. The court of appeals reversed, holding that the trial court erred by failing to give Defendant's requested jury instructions on the law of self-defense with the stand-your-ground provision and the law of the defense of habitation. The Supreme Court affirmed, holding (1) there was sufficient evidence presented at trial to support the submission of Defendant's requested instructions to the jury on self-defense and the defense of habitation; and (2) there was a reasonable possibility that had the trial court not committed prejudicial error in its presentation of instructions to the jury a different result would have been reached at the trial. View "State v. Coley" on Justia Law

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The Supreme Court held that the retroactivity provision of the Racial Justice Act (RJA) Repeal violated the double jeopardy protections of the North Carolina Constitution.Defendant was convicted of first-degree murder and sentenced to death. After the North Carolina General Assembly enacted the RJA, Defendant filed a motion for appropriate relief pursuant to the RJA. After a hearing, the trial court concluded that race was a significant factor in the decisions of prosecutors to exercise peremptory challenges to strike African-American jurors and resentenced Defendant to life imprisonment without the possibility of parole. After three more defendants showed that their death sentences were sought or imposed on the basis of race the General Assembly repealed the RJA. The trial court concluded that the RJA Repeal retroactively voided the defendants' claims and dismissed each of the defendants' motions for appropriate relief. The Supreme Court vacated the trial court's order, holding that the retroactivity provision of the RJA Repeal violates double jeopardy protections and that, in any event, the State lacked the statutory authority to appeal that judgment. View "State v. Robinson" on Justia Law

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The Supreme Court modified and affirmed the decision of the court of appeals upholding Defendant's convictions for two counts of engaging in sexual activity with a student, holding that Defendant sufficiently preserved for appellate review whether the State presented sufficient evidence of each element of the crime for which he was convicted, but, nonetheless, the trial court properly denied Defendant's motion to dismiss.On appeal, Defendant argued that the trial court erred in denying his motion to dismiss based on insufficient evidence, arguing that the evidence at trial did not establish that he was a "teacher" within the meaning of N.C. Gen. Stat. 14-27.7(b). The court of appeals concluded that Defendant had failed to preserve his arguments for appellate review. The Supreme Court affirmed as modified, holding (1) Defendant sufficient preserved for appellate review all sufficiency of the evidence issues through his motion to dismiss at trial; and (2) Defendant fell within the "teacher" category under the statute. View "State v. Smith" on Justia Law

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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