Justia Criminal Law Opinion Summaries

Articles Posted in North Carolina Supreme Court
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The Supreme Court reversed the decision of the court of appeals reversing the trial court's denial of Defendant's motion to suppress, holding that the trial court's findings of fact were supported by competent evidence and that Defendant's search and seizure did not violate the Fourth Amendment of the United States Constitution.Following the trial court's denial of Defendant's motion to suppress Defendant pleaded guilty to various drug offenses. The court of appeals vacated the convictions, concluding that the trial court erred in denying Defendant's motion to suppress. The Supreme Court reversed, holding (1) competent evidence supported the trial court's findings of fact; (2) Defendant was lawfully detained pursuant to Michigan v. Summers, 452 U.S. 692 (1981) and State v. Williams, 490 S.E.2d 583 (N.C. 1997); and (3) the frisk of Defendant was reasonable under the totality of the circumstances. View "State v. Tripp" on Justia Law

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The Supreme Court modified and affirmed the decision of the court of appeals concluding that Defendant's sentence violated the Eighth Amendment to the United States Constitution, holding that it violates both the Eighth Amendment to the United States Constitution and N.C. Const. art. I, 27 to sentence a juvenile homicide officer who has been determined to be neither incorrigible nor irredeemable to life without parole.Defendant was seventeen years old when he was indicted for participating in murders. Defendant pled guilty to two counts of first-degree murder and ordered to serve two consecutive sentences of life without the possibility of parole. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), the trial court expressly found that Defendant was "neither incorrigible nor irredeemable" but nevertheless ordered him to serve two consecutive sentences of life with the possibility of parole. The court of appeals reversed. The Supreme Court affirmed as modified, holding (1) Defendant's sentence was a de facto sentence of life without parole under article I, section 27; and (2) because Defendant was found to be neither incorrigible nor irredeemable, his sentence was unconstitutional. View "State v. Kelliher" on Justia Law

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The Supreme Court affirmed the order of the trial court partially denying Officer Matt Blackman's motion for summary judgment with respect to Bruce Bartley's claims against him in his individual capacity based on the defense of public official immunity, holding that Officer Blackman was not entitled to summary judgment based upon the defense of public official immunity.Bartley filed a civil suit against Officer Blackman, in both his official and individual capacities, and against the City of High Point for malicious prosecution, false imprisonment/arrest, and assault and battery. The trial court dismissed the claims against the City and Officer Blackman in his official capacity on the ground that sovereign immunity barred those claims but denied summary judgment as to the claims against Officer Blackman in his individual capacity. The Supreme Court affirmed, holding that there was a genuine issue of material fact as to whether Officer Blackman acted with malice in carrying out his official duties. View "Bartley v. City of High Point" on Justia Law

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The Supreme Court held that juvenile offenders who have received sentences of life imprisonment with the possibility for parole must have the opportunity to seek an early release afforded by the prospect of parole after serving no more than forty years' incarceration.Defendant was fifteen years old when he received sentences of 240 to 348 months' imprisonment for a rape conviction and life imprisonment with the possibility of parole for a murder conviction, ordered by the trial court to run consecutively. The Supreme Court held that, while juvenile offenders who have received sentences of life imprisonment with the possibility of parole are not guaranteed parole at any point during their terms of incarceration, to compel Defendant to serve a term of incarceration in excess of forty years upon the trial court's determination that Defendant was neither incorrigible nor irredeemable would constitutionally constitute a de facto life sentence. View "State v. Conner" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the order of the trial court denying Defendant's motion to dismiss and vacating the judgment entered in the superior court convicting Defendant of first-degree murder and robbery with a dangerous weapon on the grounds that the trial court erred by denying Defendant's motion to dismiss, holding that the trial court properly denied the motion to dismiss.Defendant moved to dismiss the charges against him at the close of the State's evidence and then again at the close of the evidence, arguing that the evidence was insufficient to prove that he was guilty. The trial court denied the motions to dismiss and sentenced Defendant to life imprisonment without parole. The court of appeals reversed, concluding that the trial court erred by denying Defendant's motion to dismiss. The Supreme Court reversed, holding that substantial evidence supported the reasonable inference that Defendant murdered the victim and took $3,000. View "State v. Dover" on Justia Law

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The Supreme Court vacated the decision of the court of appeals dismissing Defendant's appeal of his conviction for two counts of manufacturing methamphetamine, holding that the trial court erred in denying Defendant's motion to suppress.Defendant filed two motions to suppress evidence obtained during two searches of Defendants home in 2014 and 2015. Both motions were denied. Defendant appealed, but the court of appeals dismissed the appeal and denied his petition for a writ of certiorari. The Supreme Court remanded the case for reconsideration in light of State v. Ledbetter, 371 N.C. 192 (2018) and State v. Stubbs, 368 N.C. 40 (2015). On remand, the court of appeals again denied the petition, indicating that Defendant's failure to provide timely notice of his intent to appeal was fatal to his petition. The Supreme Court vacated the decision below, holding that the court of appeals had the jurisdiction and authority to issue the writ of certiorari. View "State v. Killette" on Justia Law

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The Supreme Court reversed the decision of the court of appeals vacating the order of the trial court denying Defendant's motion to dismiss, holding that the trial court did not err.Defendant was charged with one count of driving while impaired and one count of reckless driving. Defendant filed a motion to suppress evidence obtained at a Harnett County checking station. The trial court denied the motion to dismiss, and Defendant later pleaded guilty to driving while impaired. The court of appeals vacated the trial court's order denying Defendant's motion to suppress, concluding that the trial court could not assess whether the public interest in the checking station outweighed its infringement on Defendant's Fourth Amendment privacy interests. The Supreme Court reversed, holding that the unchallenged findings of fact supported the trial court's conclusion that the public interest served by the checking station outweighed the intrusion on Defendant's liberty interests. View "State v. Cobb" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing the order of the trial court and vacating Defendant's convictions on the grounds that the delay in his case was unjustified and violated his Sixth Amendment right to a speedy trial, holding that remand was required.After a jury trial, Defendant was convicted of felony hit and run resulting in serious injury or death, two counts of second-degree murder, and attaining violent habitual felon status. The court of appeals reversed and vacated Defendant's convictions, holding that the trial court erred in denying Defendant's pretrial motion to dismiss based on speedy trial grounds. The Supreme Court reversed in part, holding (1) the trial court improperly admitted the testimony of Defendant's prior attorney where there was no waiver of the attorney-client privilege; and (2) the case is remanded for a rehearing on Defendant's speedy trial claim. View "State v. Farook" on Justia Law

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The Supreme Court modified the decision of the court of appeals, which held that the trial court lacked a sufficient factual basis to accept Defendant's guilty plea, holding that the trial court lacked a sufficient factual basis to accept Defendant's guilty plea but that the guilty plea must be accepted or rejected as a whole, not in part.The trial court sentenced Defendant to separate and consecutive sentences based on several assault charges arising from one assaultive episode. The court of appeals reversed, concluding that the State did not provide a sufficient factual basis for the trial court to enter judgments on multiple assault charges. The court then remanded the case with instructions to arrest two lesser judgments and to repentance Defendant on the remaining charges. The Supreme Court affirmed as modified, holding (1) the facts presented at the plea hearing did not establish that a distinct interruption occurred between assaults, and therefore, the court of appeals properly found that the trial court lacked a sufficient factual basis to accept Defendant's guilty plea; and (2) there was no basis for rejecting Defendant's guilty plea in part. View "State v. Robinson" on Justia Law

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The Supreme Court reversed the decision of the court of appeals vacating Defendant's conviction for driving while impaired, holding that even if the admission of certain testimony was erroneous under N.C. R. Evid. 701, Defendant failed to meet his burden of showing that such assumed error was prejudicial.At issue was the testimony of Officer Henry Carssow, who responded at the scene of a moped accident in which Defendant was involved. Officer Carssow applied for a search warrant to obtain a sample of Defendant's blood to check his blood alcohol concentration. A magistrate executed and signed the application. After Defendant's blood was drawn he was charged and ultimately convicted of unlawfully and willfully operating a motor vehicle while subject to an impairing substance. The court of appeals vacated Defendant's conviction, ruling that the trial court committed prejudicial error by admitting Officer Carssow's lay witness opinion that Defendant was driving the moped at the time of the accident. The Supreme Court reversed, holding (1) Officer Carssow's testimony was properly preserved for appeal; and (2) even if the admission of the testimony was erroneous, Defendant failed to show that such assumed error was prejudicial. View "State v. Delau" on Justia Law