Justia Criminal Law Opinion Summaries

The Supreme Court of North Carolina heard a case regarding a traffic checkpoint where the defendant, Alvarez, was stopped, searched, and found in possession of illegal drugs. He moved to suppress the evidence, arguing that it was collected at an unconstitutional checkpoint. The trial court agreed with the defendant, ruling that the checkpoint violated the Fourth Amendment as the State failed to provide a valid primary programmatic purpose for it. The Court of Appeals affirmed this decision.However, the Supreme Court of North Carolina disagreed, holding that the officers at the checkpoint had an independent reasonable suspicion to stop Alvarez's vehicle, thus no violation of his Fourth Amendment rights occurred. This suspicion was based on Alvarez's behavior and driving, including his failure to maintain lane control. The court emphasized that reasonable suspicion is an issue separate from the constitutionality of the checkpoint.The court concluded that the trial court erred in granting the motion to suppress and that the Court of Appeals erred in affirming the trial court's order. As a result, the court reversed the decision of the Court of Appeals and remanded the case for further proceedings. The court declined to comment on the constitutionality of the traffic checkpoint due to the presence of independent reasonable suspicion. View "State v. Alvarez" on Justia Law

In April 2017, Isaiah Scott Beck, Daniel Silva, and Javier Holloway planned to rob a drug dealer in Boone, North Carolina. They initially did not have a specific target in mind. However, through a series of text messages, the trio agreed to rob a particular dealer, Mackenzie Beshears. On the day of the robbery, Silva met Beshears in her apartment while Beck and Holloway, wearing all black clothing and face coverings, broke into the apartment. The North Carolina Supreme Court had to determine whether there was substantial evidence to support Beck's conviction for conspiracy to commit robbery with a dangerous weapon and conspiracy to commit felonious breaking or entering.The Court found that the evidence showed that the original plan was to rob Beshears in the parking lot, but that a new plan was formed in the time between Silva’s first and second appearances at the apartment complex. This new plan involved Silva entering Beshears’ apartment for the meeting, and Beck and Holloway breaking into the apartment. Therefore, a rational juror could find that Beck entered into two separate conspiracies: one to commit robbery with a dangerous weapon and another to commit felonious breaking or entering.As such, the Court concluded that the trial court did not err in denying Beck's motion to dismiss the charges against him, including the charge of conspiracy to commit robbery with a dangerous weapon. The Court therefore directed the Court of Appeals to reinstate Beck's conviction for conspiracy to commit robbery with a dangerous weapon. View "State v. Beck" on Justia Law

In this case, the Supreme Court of North Carolina was tasked with interpreting N.C.G.S. § 14-208.12A, which allows for the removal of a registered sex offender from the North Carolina Sex Offender Registry ten years after initial registration. The defendant, Larry Fritsche, had argued that since he had registered as a sex offender in Colorado more than ten years ago, he was eligible for removal from the North Carolina registry. However, the trial court, using precedent set by the case In re Borden, denied his petition, stating that the ten-year period must be completed in North Carolina. The Court of Appeals affirmed this decision.Upon review, the Supreme Court also affirmed the lower courts' decisions. The court determined that the term "county" in the relevant statutes refers to a county in North Carolina, not any state. The court also noted that the purpose of the Sex Offender Protection Registration Programs was to protect North Carolina communities, and this protection could not be ensured if sex offenders could avoid registering in North Carolina due to time spent on another state's registry. Therefore, the court held that the term "initial county registration" in section 14-208.12A requires ten years of registration in North Carolina, not simply ten years of registration in any state. View "State v. Fritsche" on Justia Law

In the case before the Supreme Court of North Carolina, the defendant, Jahzion Wilson, was charged with first-degree murder under the felony-murder theory, with the underlying felony being attempted robbery with a dangerous weapon. Wilson argued that he was entitled to a jury instruction on second-degree murder as a lesser-included offense of first-degree murder. However, the court held that in order for a defendant to be entitled to an instruction on a lesser-included offense, there must be a conflict in the evidence of the underlying felony and the evidence must support the lesser-included offense. The defendant's own statements denying his involvement in the crime are not sufficient to create a conflict in the evidence. In this case, the court found that there was no conflict in the evidence supporting the underlying felony of attempted robbery with a dangerous weapon, thus, Wilson was not entitled to an instruction on second-degree murder. The court modified and affirmed the decision of the Court of Appeals. View "State v. Wilson" on Justia Law

In North Carolina, Melvin Woolard Jr. was arrested by Captain Rodney Sawyer for driving while impaired (DWI). Before his trial, Mr. Woolard filed a motion to suppress evidence seized during the arrest, arguing that the officer lacked probable cause to suspect him of drunk driving. The District Court agreed and granted his motion. The State appealed the decision to the Superior Court, which also found that the arrest violated the Fourth Amendment. The case was then taken to the Supreme Court of North Carolina.The Supreme Court of North Carolina examined the evidence and found that Captain Sawyer had probable cause to arrest Mr. Woolard for impaired driving. The court noted that Mr. Woolard had been driving erratically, swerving over the centerline multiple times, and veering onto the road's shoulder. Additionally, the officer smelled alcohol on Mr. Woolard's breath and inside his truck, observed his red and glassy eyes, and heard his admission to having consumed some beers before driving. Mr. Woolard also exhibited all six possible indications of impairment on a Horizontal Gaze Nystagmus (HGN) test administered by the officer.Based on these facts, the court concluded that an objectively reasonable officer in Captain Sawyer’s position would have suspected Mr. Woolard of impaired driving. Consequently, Mr. Woolard’s arrest satisfied the Fourth Amendment. The court therefore reversed the District Court's decision to suppress the evidence and remanded the case for further proceedings. View "State v. Woolard" on Justia Law

In the case before the Supreme Court of North Carolina, the defendant, Darren O'Brien Lancaster, was charged with multiple offenses, including two counts of "going armed to the terror of the public." The charges stemmed from incidents at two locations where Lancaster was reported to be waving a firearm and causing a disturbance. He was found guilty and sentenced to a minimum of fifteen months and a maximum of twenty-seven months in prison.On appeal, the Court of Appeals found that the indictment charging Lancaster with "going armed to the terror of the public" was deficient because it did not allege that the crime occurred on a public highway, which the Court of Appeals considered to be a necessary element of the crime based on its previous decision in State v. Staten. As a result, the Court of Appeals vacated Lancaster's conviction for this charge and remanded the case for resentencing.The Supreme Court of North Carolina reversed the decision of the Court of Appeals. The Supreme Court held that the crime of "going armed to the terror of the public" does not require the conduct to occur on a public highway. Rather, the elements of this common law crime are that the accused (1) went about armed with an unusual and dangerous weapon, (2) in a public place, (3) for the purpose of terrifying and alarming the peaceful people, and (4) in a manner which would naturally terrify and alarm the peaceful people. The Supreme Court found that the indictment against Lancaster adequately alleged facts supporting each of these elements. Therefore, the indictment was not deficient, and Lancaster's conviction for "going armed to the terror of the public" was reinstated. View "State v. Lancaster" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's denial of Defendant's motion to suppress and finding no error in her criminal trial, holding that the search for evidence in this case violated the Fourth Amendment and that remand was required.Defendant was convicted of trafficking in methamphetamine, possession with intent o manufacture, sell, or deliver methamphetamine, and possession of methamphetamine. The court of appeals affirmed. The Supreme Court reversed, holding (1) the search and subsequent seizure of contraband did not comport with the Fourth Amendment; and (2) remand was required for the trial court to determine if the evidence should be suppressed pursuant to the exclusionary rule. View "State v. Julius" on Justia Law

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