Justia Criminal Law Opinion Summaries

The Supreme Court reversed the decision of the court of appeals vacating Defendant's conviction of felony obstructing of justice, holding that there was sufficient evidence to support the jury's verdict finding Defendant guilty of felony obstruction of justice.After a nearly three-week-long jury trial, Defendant was convicted of, among other offenses, obtaining property by false pretenses and felony obstruction of justice. The court of appeals reversed in part, concluding that the State did provide substantial evidence of obstruction to support the felony obstruction of justice conviction. The Supreme Court reversed and reinstated the felony obstruction of justice conviction, holding that there was sufficient evidence to convict Defendant of felony obstruction of justice. View "State v. Bradsher" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating the judgments entered upon Defendant's convictions for multiple serious felonies, including first-degree murder, holding that the record did not support the trial court's determination that Defendant's actions were sufficiently obstructive to constitute a forfeiture of his right to counsel.Defendant was indicted on charges of first-degree murder, attempted first-degree murder, and other crimes. The trial court decided before trial that Defendant's actions forfeited his opportunity to have assigned counsel, and Defendant proceeded pro se. The jury returned guilty verdicts on all offenses, and Defendant was sentenced to life imprisonment for the murder conviction. The court of appeals awarded Defendant a new trial, determining that the trial court deprived Defendant of his constitutional right to counsel by concluding that he had forfeited that right. The Supreme Court affirmed, holding that Defendant was entitled to a new trial because he did not engage in the type of egregious misconduct that would permit the trial court to deprive him of his constitutional right to counsel. View "State v. Harvin" on Justia Law

The Supreme Court modified the decision of the court of appeal affirming the denial of Defendant's petition for a writ of certiorari to the extent that this Court affirms the outcome reached by the lower appellate court without prejudice to Defendant to pursue any other legal remedy that has not been determined by the Court's opinion, holding that the superior court properly acted within its discretion in denying Defendant's petition for a writ of certiorari.The court of appeals determined that only the superior court's order denying Defendant's certiorari petition, and not the order denying Defendant's motion to reinstate charges, was properly before the appellate court. The Supreme Court affirmed as modified, holding (1) a criminal defendant does not possess the right to compel the district attorney, who has the authority to place the defendant’s unresolved criminal charges in a dismissed-with-leave status, to reinstate the dismissed charges and to place the charges on a trial court’s criminal case calendar for resolution; and (2) a trial court lacks the authority to order that criminal charges that have been dismissed with leave by the district attorney be reinstated and placed on a trial court’s criminal case calendar against the will of the district attorney. View "State v. Diaz-Tomas" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals ruling that Defendant waived the right to appellate review of the trial court's denial of Defendant's request for a self-defense instruction, holding that Defendant properly preserved his challenge and that the trial court did not err by refusing to deliver the requested self-defense instruction.After the conclusion of the jury instruction conference and prior to the delivery of the trial court's instructions to the jury defense counsel requested that an instruction on self-defense to be given to the jurors. The trial court denied the request. The jury subsequently returned verdicts convicting Defendant of assault by strangulation and other offenses. Defendant appealed, challenging the trial court's rejection of his self-defense instruction. The court of appeals affirmed, holding that Defendant waived appellate review on the issue. The Supreme Court affirmed as modified, holding (1) Defendant's challenge to the trial court's refusal to issue a self-defense instruction was properly preserved for appellate review; and (2) the trial court did not err in declining to instruct the jury on self-defense. View "State v. Hooper" on Justia Law

The Supreme Court affirmed the decision of the court of appeals determining that the trial court correctly denied Defendant's motion for a transcript of a prior trial and a motion to continue, holding that the trial court likely erred, but the error was harmless beyond a reasonable doubt.Defendant was charged with multiple driving offense arising from impaired driving. The first trial ended in a mistrial. Before the second trial, Defendant filed a motion for transcript seeking to obtain a transcript of the previous trial and a motion to continue. The trial court denied both motions, and a jury found Defendant guilty of all charges. The Supreme Court affirmed, holding that the trial court likely erred in failing to apply the two-party Britt test upon Defendant's requests for a transcript of the previous proceeding, but the error was harmless beyond a reasonable doubt. View "State v. Gaddis" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals upholding the revocation of Defendant's probation, holding that Defendant's confrontation argument under N.C. Gen. Stat. 15A-1345(e) was not preserved.Defendant pleaded guilty to discharging a weapon into occupied property and possession of a firearm by a convicted felon. Later, Defendant's probation was revoked following a determination that he had committed new criminal offenses. On appeal, Defendant argued that the trial court violated his constitutional right to confront witnesses against him at the probation hearing. The court of appeals affirmed, holding that there was no Sixth Amendment violation in this case. The Supreme Court modified and affirmed the judgment below, holding (1) a defendant's arguments under N.C. Gen. Stat. 15A-1345(e) are preserved when a defendant lodges a proper objection or the trial court does not permit confrontation and fails to make a finding of good cause; and (2) the condition requiring a finding of good cause was not satisfied in this case. View "State v. Jones" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals affirming an order of the superior court resentencing Defendant on his first-degree murder conviction to life with the possibility of parole after twenty-five years and running his first-degree kidnapping sentence consecutively with his murder sentence, holding that Defendant failed to show prejudice.Defendant filed a motion for appropriate relief seeking sentencing under Miller v. Alabama, 567 U.S. 460 (2012). The trial court allowed the motion and resentenced Defendant. On appeal, the court of appeals rejected Defendant's claim that he received ineffective assistance of counsel at sentencing. The Supreme Court affirmed as modified, holding (1) the reasoning below is rejected to the extent it incorrectly suggested that the resentencing court lacked authority to run Defendant's first-degree murder sentence concurrently with his robbery with a dangerous weapon sentences; and (2) the court of appeals correctly concluded that Defendant could not demonstrate prejudice. View "State v. Oglesby" on Justia Law

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

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

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