Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant, a former chorus teacher at a middle school, of first-degree rape and first-degree statutory sexual offense with a child, Ellen, a middle school student, holding that Defendant was not entitled to relief on his allegations of error.At issue on appeal, among other things, was whether evidence of Defendant's alleged rape of another student, Kathleen, was properly admitted during trial under N.C. R. Evid. 404(b). The Supreme Court reversed the decision of the court of appeals to vacate Defendant's sentence and otherwise affirmed, holding that the trial court (1) did not err in admitting Kathleen's Rule 404(b) testimony; and (2) did not improperly consider Defendant's choice not to plead guilty and exercise his right to a jury trial when it imposed Defendant's sentence or when it imposed consecutive sentences on Defendant. View "State v. Pickens" on Justia Law

The Supreme Court affirmed a portion of the decision of the court of appeals upholding the trial court's ruling that Defendants' proffered evidence that speculatively imputed blame for the charged offenses to other potential suspects could not be presented to the jury, holding that there was no error.Defendants were charged with first-degree murder, attempted robbery with a dangerous weapon, and assault with a deadly weapon. At issue was the refusal of the trial court to allow Defendants to introduce evidence that Defendants asserted would show that two other individuals, not themselves, had committed the crimes. The court of appeals affirmed. The Supreme Court affirmed, holding (1) while the proffered evidence was relevant to the issues presented for the jury's resolution, the potential evidence for the jury's consideration was not admissible; and (2) the court of appeals correctly applied the pertinent legal principles in concluding that the exclusion of Defendants' proffered evidence did not constitute prejudicial or reversible error. View "State v. Abbitt" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding Defendant's voluntary manslaughter conviction after determining that if the trail court erred in refusing to admit certain cell phone evidence the error was not sufficiently prejudicial to warrant a new trial, holding that the trial court's decision did not constitute an abuse of discretion.On appeal, Defendant argued that the trial court committed reversible error by refusing to allow the jury to consider photographs and text messages found on the victim's cellular phone. The court of appeals affirmed, concluding that Defendant received a fair trial free of prejudicial error. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in admitting the evidence and that admitting the disputed evidence almost certainly would not have changed the outcome of Defendant's trial. View "State v. McKoy" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's second-degree murder conviction, holding that the evidence was sufficient to support a jury finding that Defendant was the aggressor when she shot and killed the victim, and therefore, the trial court did not err in giving an instruction on the aggressor doctrine.At issue was the proper application of North Carolina's castle doctrine statute. See N.C. Gen. Stat. 14-51.2(b). Defendant and the victim in this case had a tumultuous relationship, and on the day of the murder Defendant had warned the victim not to come to her residence. The victim came anyway and was shot and killed. Defendant was convicted of second-degree murder. The court of appeals remanded the case for a new trial, holding that the trial court improperly instructed the jury on the aggressor doctrine. The Supreme Court reversed, holding that the trial court properly instructed the jury that if it found that Defendant was the aggressor, the presumption in section 14-51.2 was no longer available for her. View "State v. Hicks" on Justia Law

The Supreme Court affirmed the jury verdict that Defendant was guilty of the first-degree murder of a young child as well as of first-degree kidnapping, sexual offense with a child and felony child abuse inflicting serious injury, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to disqualify the trial judge; (2) the trial court erroneously admitted at trial a full-body photograph of the victim during certain testimony, but the error was not prejudicial; (3) the trial court may have improperly allowed certain witnesses to testify about their emotional reactions to seeing the victim's injuries, but the evidence was not prejudicial; (4) the trial court erred in denying Defendant's second motion to suppress a statement he made to law enforcement officers at a hospital, but there was no prejudice; (5) there was no cumulative prejudice; (6) there was no error in the trial court's rulings related to Defendant's attempt to establish a prima facie case of racial or gender-based discrimination; (7) North Carolina's death sentence system is constitutional; and (8) Defendant received a fair trial and capital sentencing proceeding. View "State v. Richardson" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's conviction for possession of a firearm by a felon because the State failed to obtain a separate indictment for that offense under N.C. Gen. Stat. 14-415.1(c), holding that a violation of the mandatory separate indictment provision is not fatally defective.The State brought an indictment charging Defendant with possession of a firearm and two related offenses. The State did not obtain a separate indictment for Defendant's offense of possession of a firearm by a felon. The trial court convicted Defendant of possession of a firearm by a felon, possession of a firearm with an altered or removed seal number, and carrying a concealed weapon. The court of appeals reversed in part because the State failed to obtain a separate indictment for Defendant's conviction for possession of a firearm by a felon. The Supreme Court reversed, holding that the court of appeals erroneously applied its precedent in State v. Wilkins, 737 S.E.2d 791 (N.C. App. 2013), and that Wilkins is hereby specifically overruled. View "State v. Newborn" on Justia Law

The Supreme Court vacated the opinion of the court of appeals reversing Defendant's conviction of drug-related charges arising out of an incident that occurred when law enforcement officers observed Defendant moving in between buildings of a housing community and eventually found a white, powdery substance in his backpack, holding that remand was required.The court of appeals reversed Defendant's conviction for trafficking by possession of an opiate on the grounds that the trial court erroneously ruled that the State's expert was qualified to testify that fentanyl is an opiate. At issue was the impact of State v. Garrett, 2021-NCCOA-214, on this case. The Supreme Court vacated the court of appeals, holding that the trial court erred in concluding that whether fentanyl is an opiate is a question of fact, requiring remand. View "State v. Gibbs" on Justia Law

The Supreme Court held that, within the particular facts and overall context of this criminal case, the trial court did not violate either the United States Constitution or the North Carolina General Statutes by declining to conduct further inquiry into Defendant's capacity to proceed following his apparent suicide attempt on the morning of the sixth day of trial.Defendant's suicide attempt occurred before the jury was given its instructions but after the jury had heard closing arguments from both sides. To determine whether Defendant had forfeited his right to be present for the trial's ongoing proceedings the trial court received evidence concerning his medical history and state of mind at the time of his apparent suicide attempt. The court ultimately concluded that Defendant's injuries were entirely caused by his own voluntary actions, and therefore, Defendant had voluntarily absented himself from the trial proceedings. The trial was continued in his absence, and the trial court entered judgments against Defendant. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not erroneously decline to make further inquiry into Defendant's capacity to proceed during the trial proceedings. View "State v. Flow" on Justia Law

The Supreme Court reversed the final order and judgment of the trial court in this case involving challenges to N.C. Gen. Stat. 13-1, the statute setting forth the criteria that felons must satisfy to be eligible for re-enfranchisement, holding that the trial court erred in entering an order allowing all felons not in jail or prison to register and vote.Nearly fifty years after the legislature rewrote section 13-1 to make re-enfranchisement automatic for all eligible felons Plaintiffs brought this action challenging the requirement that felons complete their probation, parole, or post-release supervision before they regain their voting rights. Plaintiffs alleged that this requirement was intended to discriminate African Americans. The trial court ruled for Plaintiffs. The Supreme Court reversed, holding (1) there was insufficient evidence to prove that legislators intended their reforms to section 13-1 to disadvantage African Americans; and (2) Plaintiffs were not entitled to relief on their other constitutional claims. View "Community Success Initiative v. Moore" on Justia Law

The Supreme Court reversed the judgment of the court of appeals vacating the judgment of the superior court sentencing Defendant at the Class B1 felony level in connection with his conviction of second-degree murder, holding that the trial court properly sentenced Defendant at the Class B1 level.In 2019, Defendant was convicted of second-degree murder. At issue was whether Defendant should have been sentenced at the lower Class B2 felony level given the jury's conclusion that Defendant acted, in part, with depraved-heart malice. The Supreme Court reversed Defendant's sentence, holding that, under the circumstances, the jury's completed verdict form was not ambiguous, and Defendant was properly sentenced at the Class B2 level. View "State v. Borum" on Justia Law