Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's convictions of felony trafficking in methamphetamine and misdemeanor simple possession of marijuana, holding that a defendant does not forfeit her Fifth Amendment right to silence if she complies with N.C. Gen. Stat. 15A-905(c)(1) and gives notice of intent to offer an affirmative defense.Prior to trial, Defendant filed a notice of her intent to rely upon the affirmative defense of duress pursuant to section 15A-905(c)(1). The jury found Defendant guilty after a trial. The court of appeals affirmed, concluding that because Defendant gave notice of her intent to assert the affirmative defense of duress before she testified, the trial court did not err in admitting, during the State's case-in-chief, a detective's testimony of Defendant's silence at the scene. The Supreme Court reversed, holding (1) a defendant does not forfeit her Fifth Amendment right to silence if she gives pretrial notice of her intent to offer the affirmative defense of duress under section 15A-905(c)(1); and (2) the State may not preemptively impeach a defendant during its case-in-chief. View "State v. Shuler" on Justia Law

The Supreme Court affirmed Defendant's conviction of speeding ninety-four miles per hour in a sixty-five mile-per-hour zone, holding that Defendant knowingly and voluntarily waived his constitutional right to a jury trial.In affirming Defendant's conviction, a divided panel of the Court of Appeals concluded that, even though the trial court failed to follow the statutory procedure for waiver of Defendant's right to a jury trial, Defendant was not prejudiced. The Supreme Court affirmed, holding (1) although the trial court's colloquy was untimely, the facts demonstrated that Defendant understood he was waiving his right to a trial by jury and the consequences of that decision; and (2) Defendant did not meet his burden of demonstrating that there was no reasonable possibility that had the error not been committed a different result would have been reached in a bench trial or a jury trial. View "State v. Hamer" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals finding Defendant guilty of possession of a firearm by a felon, holding that there was no error in Defendant's conviction.After the jury returned its verdict Defendant pleaded guilty to attaining habitual felon status. Defendant appealed, arguing that the prosecutor's statements during closing argument did not constitute prejudicial error and that Defendant failed to show that the trial court erred in not intervening ex mero motu. The court of appeals affirmed. The Supreme Court affirmed, holding that the misstatements made by the prosecutor during closing arguments were not extreme or grossly improper and that the trial court did not abuse its discretion in declining to intervene ex mero motu. View "State v. Parker" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals finding no plain error in the judgment of conviction of Defendant for three counts of indecent liberties with a child, holding that Defendant received a fair trial, free from prejudicial error.A divided court of appeals affirmed Defendant's conviction, holding that there was no prejudicial error in the trial proceedings. The dissent, however, argued that several errors were committed during trial and that the cumulative effect of the errors required reversal of the convictions. The Supreme Court disagreed and affirmed the majority decision of the court of appeals, holding (1) even if certain testimony was admitted in error, the error was not prejudicial; (2) the trial court did not err by allowing the State's witnesses to use the term "disclose"; and (3) the trial court did not plainly err by allowing past domestic violence evidence. View "State v. Betts" on Justia Law

The Supreme Court affirmed the majority decision of the court of appeals finding no error in Defendant's trial and conviction, holding that the trial court did not err in denying Defendant's motion to dismiss the charge of possession with intent to sell or deliver methamphetamine.On appeal, Defendant argued that the evidence presented by the State was sufficient to support a charge of possession of methamphetamine but was insufficient to send to the jury the greater charge of possession with intent to sell or deliver methamphetamine. The court of appeals majority disagreed and affirmed. The Supreme Court affirmed, holding that the State presented sufficient direct and circumstantial evidence of Defendant's intent to sell or deliver methamphetamine. View "State v. Blagg" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for first-degree murder by starvation and negligent child abuse inflicting serious bodily injury and Defendant's sentence of life imprisonment without the possibility of parole, holding that there was no prejudicial error.Before the Supreme Court, Defendant argued that the trial court erred by failing to dismiss the first-degree murder charge on the grounds that the record failed to contain sufficient evidence to support a finding that the child victim's death was proximately caused by starvation. The Supreme Court disagreed, holding that the trial court had ample justification for concluding that the victim died as a proximate result of starvation. View "State v. Cheeks" on Justia Law

The Supreme Court reversed the judgment of the court of appeals ordering a new trial in this case on the grounds that the prosecutor's commentary on Defendant's decision to plead not guilty was so unfair it violated Defendant's due process rights, holding that the prosecutor's comments did not so prejudice Defendant so as to warrant a new trial.Defendant was found guilty of several offenses after a jury trial. On appeal, Defendant argued that the trial court committed reversible error in failing to intervene ex mero motu when the prosecutor made improper remarks about Defendant's decision to plead not guilty during closing arguments. The court of appeals agreed and ordered a new trial. The Supreme Court reversed, holding that Defendant failed to show that he was prejudiced as a result of the prosecutor's improper closing arguments. View "State v. Goins" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony breaking or entering a motor vehicle, misdemeanor larceny, and misdemeanor possession of stolen property, holding that the trial court did not err when it declined to instruct the jury on voluntary intoxication.The court of appeals affirmed Defendant's conviction on direct appeal, concluding that Defendant failed to produce sufficient evidence of voluntary intoxication, and therefore, the district court did not err in refusing to instruct the jury on voluntary intoxication. The Supreme Court affirmed, holding that there was not substantial evidence to require a voluntary intoxication instruction. View "State v. Meader" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for second-degree murder, holding that the court of appeals erred in concluding that the trial court erred by denying Defendant's motion to suppress evidence generated from his blood but that the error was not prejudicial.In denying Defendant's suppression motion the court of appeals held that the trial court erred by not excluding Defendant's blood test results but that Defendant failed to carry his burden to show that the denial of his motion to suppress resulted in prejudicial error. The Supreme Court reversed, holding that the court of appeals applied the incorrect standard for determining prejudice resulting from the violation of Defendant's rights under the United States Constitution. View "State v. Scott" on Justia Law

The Supreme Court reversed the decision of the court of appeals finding no error in the judgments of conviction in this case, holding that the court of appeals erred in concluding that Defendants' claims had not been properly preserved for appeal.Three defendants were tried together as co-defendants for the involvement in a crime where armed robbers stole nearly half a million dollars from Raleigh's Walnut Creek Amphitheater. Following their convictions two defendants appealed, arguing that the trial court erred in denying their motions for separate trials. The court of appeals affirmed the convictions, concluding that because the grounds for severance argued that the beginning of trial were different from the grounds relied upon by Defendants on appeal, Defendants' claims had not been properly preserved for appeal. The Supreme Court reversed, holding that the court of appeals erred in analyzing the case as one involving severance of offenses rather than severance of defendants. View "State v. Melvin" on Justia Law