Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions of assault on a female and habitual misdemeanor assault, holding that Defendant received a fair trial free from error.On appeal, Defendant argued that the trial court impermissibly expressed an opinion during jury instructions concerning facts to be decided by the jury. The court of appeals found no error and upheld Defendant's convictions. The Supreme Court affirmed, holding (1) the State presented evidence at trial that satisfied the elements of the predicate assault, and the court's instructions clarified that the jury was solely responsibly for making this determination; and (2) even if it is assumed that the trial court violated the statutory prohibitions against the expression of opinion, Defendant could not show a reasonable possibility of a different result. View "State v. Austin" on Justia Law

The Supreme Court reversed the decision of the court of appeals ruling that the trial court committed plain error by incorrectly instructing the jury on the conspiracy to commit first-degree murder charge against Defendant, holding that Defendant could not show that the error had a probable impact on the jury's finding that she was guilty.Defendant was convicted of attempted first-degree murder, conspiracy to commit first-degree murder, and assault with a deadly weapon with intent to kill inflicting serious injury. The court of appeals granted Defendant a new trial on the charge of conspiracy to commit murder, concluding that the trial court plainly erred by instructing the jury on the conspiracy to commit first-degree murder charge. The Supreme Court reversed, holding that Defendant could not show plain error. View "State v. Chavez" on Justia Law

The Supreme Court vacated the portions of the motion for appropriate relief (MAR) court's order summarily dismissing Defendant's guilt-innocence phase ineffective assistance of counsel (IAC) claims, vacated the portion of the order summarily ruling that Defendant's claim alleging he was impermissibly shackled in view of the jury was procedurally barred, and otherwise affirmed, holding that the court erred in part.Defendant was convicted of first-degree murder and sentenced to death. Defendant later filed an MAR petition and then a supplemental motion for appropriate relief. The MAR court dismissed Defendant's claims. The Supreme Court vacated the MAR court's order in part and remanded the matter to the court, holding (1) Defendant was entitled to an evidentiary hearing on his guilt-innocence phase IAC claims; and (2) Defendant was entitled to an evidentiary hearing to obtain the facts necessary to determine whether Defendant's claim that he was impermissibly shackled was procedurally barred and, if not, whether it had merit. View "State v. Allen" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the trial court denying Defendant's motion to suppress evidence of a bag of narcotics seized from his vehicle during a traffic stop, holding that the trial court properly denied Defendant's motion to suppress.On appeal, Defendant argued that the law enforcement officers conducting a search for weapons on his person and in the areas of his vehicle under his immediate control did not possess the required reasonable suspension to initiate a warrantless search. The Supreme Court disagreed, holding (1) the law enforcement officer who conducted the traffic stop presented articulable facts at the suppression hearing giving rise to a reasonable suspicion that Defendant was armed and dangerous; and (2) the trial court did not err in denying Defendant's request to suppress the controlled substances that were discovered as a result of the search of the areas of Defendant's vehicle which were under his immediate control. View "State v. Johnson" on Justia Law

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