Justia Criminal Law Opinion Summaries

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 B1 level. View "State v. Campbell" on Justia Law

The Supreme Court affirmed the judgment of the trial court concluding that there was no violation of Batson v. Kentucky, 476 U.S. 79 (1986), in the underlying proceedings, holding that the trial court's decision that there was no Batson violation was not clearly erroneous.After Defendant was convicted, the Supreme Court remanded this case to the trial court to conduct further proceedings under Batson. On remand, the trial court conducted a hearing, made extensive findings of fact, and concluded that there was no Batson violation. The Supreme Court affirmed, holding that the trial court's conclusions were not clearly erroneous. View "State v. Hobbs" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that the trial court complied with the procedure implemented in N.C. Gen. Stat. 15A-1201(d)(1) by the legislature for the trial court to consent to Defendant's waiver of his right to a jury trial for the status offense of habitual felon, holding that the court of appeals did not err.After a colloquy on the record, in which Defendant gave notice in open court of his waiver of a jury trial, the trial court proceeded with a bench trial and found Defendant guilty of multiple drug-related offenses. Before the court proceeded with the phase of the trial addressing the habitual felon status offense, Defendant signed and acknowledged under oath another waiver of jury trial form. On appeal, Defendant argued that the trial court abused its discretion in how it personally addressed him and in determining that he fully understood and appreciated the consequences of his decision to waive the right to trial by jury. The Supreme Court affirmed, holding that that the court of appeals did not err by concluding that the trial court complied with the procedure set forth in N.C. Gen. Stat. 15A-1201(d)(1) for the court to consent to Defendant's waiver of his right to a jury trial for the habitual felon offense. View "State v. Rollinson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating Defendant's conviction of second-degree murder on the grounds that the trial court committed prejudicial error by declining to deliver Defendant's proffered jury instruction on involuntary manslaughter, holding that Defendant was entitled to a new trial.Defendant was convicted of the murder of his wife. On appeal, Defendant argued that the trial court erred in failing to submit his requested jury instruction on involuntary manslaughter because the jury could have found that he assaulted his wife in a culpably negligent manner or that his failure to render aid was a culpably negligent omission. The court of appeals agreed and vacated the conviction. The Supreme Court affirmed, holding that the trial court committed prejudicial error by declining Defendant's request to issue a pattern jury instruction on involuntary manslaughter. View "State v. Brichikov" on Justia Law

The Supreme Court affirmed the decision of the court of appeals finding no error in Defendant's sentences, holding that the trial court did not abuse its discretion in declining to reduce Defendant's sentence due to Defendant's rendition of substantial assistance.Defendant pleaded guilty to trafficking a controlled substance and possession of a firearm by a felon. At sentencing, the trial court declined Defendant's invitation to make a downward adjustment to his sentence in light of the assistance he provided to law enforcement officers in their criminal investigation. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in sentencing Defendant. View "State v. Robinson" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court determining that Defendant's behavior was sufficiently egregious to warrant the forfeiture of her right to counsel, holding that Defendant was entitled to a new trial.Defendant was charged with attempting to possess a firearm while subject to an ex parte Domestic Violence Protection Order prohibiting the same. After a trial, at which Defendant proceeded pro se, the jury found Defendant guilty. The court of appeals affirmed. Defendant appealed, arguing that the court of appeals erred in holding that Defendant waived her right to counsel or alternatively forfeited her right to counsel. The Supreme Court agreed and reversed, holding (1) the issue of waiver was inapposite because Defendant expressly requested the appointment of counsel; and (2) the trial court erred in its alternate determination that Defendant's behavior was sufficiently egregious to warrant the forfeiture of the right to counsel. View "State v. Atwell" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the trial court's judgments revoking Defendant's probation entered more than one year after Defendant's term of probation had expired, holding that the trial court did not abuse its discretion.The trial court concluded that good cause existed to revoke Defendant's probation despite the expiration of his probationary period. Defendant appealed, arguing that the "good cause" found by the trial court failed as a matter of law to satisfy N.C. Gen. Stat. 15A-1344(f)(3). The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court (1) possessed the jurisdiction to revoke Defendant's probation after his term of probation had expired; and (2) did not abuse its discretion in determining that good cause existed for the revocation of Defendant's probation after his term of probation had expired. View "State v. Geter" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing one of Defendant's convictions for first-degree kidnapping for lack of sufficient evidence, holding that the trial court erred by denying Defendant's motion to dismiss the second first-degree kidnapping charge.On appeal, Defendant argued that the trial court erred in denying his motion to dismiss the second of two first-degree kidnapping charges for the purpose of facilitating the commission of a first-degree rape because the evidence showed that one of the alleged kidnappings had occurred after the commission of the rape had concluded. The court of appeals agreed and reversed the second of Defendant's first-degree kidnapping convictions. The Supreme Court affirmed, holding that the evidence did not support a finding that Defendant had committed the second first-degree kidnapping charge. View "State v. Elder" on Justia Law

The Supreme Court reversed the decision of the court of appeals upholding Defendant's conviction for violating N.C. Gen. Stat. 14-208.11(a)(4) and remanded the case to the court of appeals for further remand to vacate Defendant's conviction for failure to comply with the sex offender registry, holding that the evidence was insufficient to support an inference that Defendant willfully provided information under false pretenses.Defendant was charged with submitting incorrect address information to the sheriff "willfully" and "under false pretenses." Defendant filed a motion to dismiss the charges on grounds that the State's evidence was insufficient to show that he had the requisite intent to deceive. The trial court denied the motion to dismiss and convicted Defendant of violating The Supreme Court reversed, holding that the evidence was insufficient to support an inference that Defendant willfully provided information under false pretenses. View "State v. Lamp" on Justia Law

The Supreme Court reversed the decision of the court of appeals determining that the trial court committed prejudicial error in denying Defendant's request for a jury instruction on justification as a defense to the charge of possession of a firearm by a felon, holding that the trial court did not err.After a jury trial, Defendant was convicted of second-degree murder and possession of a firearm by a felon. The court of appeals reversed the conviction and remanded for a new trial, holding that the trial court committed prejudicial error by denying Defendant's requested instruction on justification. The Supreme Court reversed, holding (1) this case did not support all four elements of the justification defense as required by State v. Mercer, 838 S.E.2d 359 (N.C. 2020); and (2) therefore, the court of appeals erred in reversing Defendant's conviction and remanding for a new trial. View "State v. Swindell" on Justia Law