Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals vacating Defendants' convictions of second-degree murder and ordering a new trial, holding that the trial court committed prejudicial error in excluding evidence that was highly relevant as to Defendants' self-defense claims.Defendants, Thomas Martens and his daughter, Molly Corbett, were found guilty of murdering Molly's husband, Jason Corbett. During trial, Defendants maintained that they had lawfully used deadly force to defend themselves while under a reasonable apprehension that they were facing an imminent threat of deadly harm during an interaction initiated by Jason. The Supreme Court remanded the case to the trial court for a new trial, holding that the trial court erroneously excluded certain evidence, thus depriving Defendants of their ability to present a full and meaningful defense. View "State v. Corbett" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for felonious obstruction of justice, holding that the record contained sufficient evidence that Defendant acted with deceit and intent to defraud to support her conviction.Defendant's daughter had been sexually abused by Defendant's husband. Defendant's conviction arose from her actions in interfering with the ability of social workers and law enforcement officers to have access to her daughter. Defendant appealed, arguing that the evidence was insufficient to support her conviction. The court of appeals upheld the conviction. The Supreme Court affirmed, holding that the record evidence provided sufficient support for a jury to find that Defendant precluded investigating officials from accessing her daughter with deceit and the intent to defraud. View "State v. Ditenhafer" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction, holding that the trial court erred by failing to conduct a competency hearing under the circumstances of this case.After a jury trial, Defendant was found guilty of felony embezzlement. At issue on appeal was whether the trial court erred in declining to hold a competency hearing when Defendant attempted suicide one evening after her trial had recessed for the day and was thereafter involuntarily committed. The trial court concluded that Defendant had voluntarily waived her constitutional right to be present at her trial because of her suicide attempt and therefore proceeded with the trial without Defendant. On appeal, Defendant argued that the trial court was required to conduct a competency hearing before proceeding with the trial in her absence. The court of appeals affirmed. The Supreme Court reversed and remanded the case for a new trial, holding that the trial court was presented with substantial information that cast doubt on Defendant's competency, and the trial court erred by failing to hold a competency hearing. View "State v. Sides" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing Defendant's conviction, holding that the court of appeals correctly held that the trial court committed plain error when it admitted improper testimony by an investigator with the Department of Social Services (DSS) Child Protective Services who improperly vouched for the victim's testimony.Defendant was convicted of sexual offense with a child by an adult, child abuse by a sexual act, and indecent liberties with a child. On appeal, Defendant argued that the trial court erred in allowing the DSS investigator's testimony. The court of appeals concluded that the trial court committed plain error requiring a new trial because the DSS investigator's testimony improperly bolstered or vouched for the victim's credibility. The Supreme Court affirmed, holding that the trial court commits a fundamental error when it allows testimony which vouches for the complainant's credibility in a case where the verdict entirely depends upon the jurors' comparative assessment of the complainant's and the defendant's credibility. View "State v. Warden" on Justia Law

The Supreme Court reversed the trial court's denial of Defendant's motion for appropriately relief filed after he was convicted of two counts of first-degree murder, holding that certain undisclosed evidence was material and that it was reasonably probable that, had it been disclosed to Defendant prior to trial, the outcome would have been different.Defendant was convicted of first-degree burglary, first-degree rape, robbery with a dangerous weapon, and two counts of first-degree murder and sentenced to death. The convictions were affirmed on direct appeal. In postconviction proceedings, it became clear that the State failed to produce certain pieces of evidence to Defendant prior to his trial. Later that year, postconviction counsel uncovered additional evidence. Defendant then filed a motion for appropriate relief, arguing that the State failed to disclose exculpatory evidence in violation of his due process right pursuant to Brady v. Maryland, 373 U.S. 83 (1963). The trial court denied the motion. The Supreme Court reversed and remanded this case with instruction to grant the motion and order a new trial, holding that the failure to disclose the exculpatory evidence prejudiced Defendant's ability to present a defense. View "State v. Best" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's convictions, holding that the trial court abused its discretion when it "flatly prohibited questioning as to issues of race and implicit bias during voir dire" and that the trial court's improper restrictions on Defendant's questioning during voir dire prejudiced Defendant.Defendant was convicted of several crimes, including robbery with a dangerous weapon and second-degree kidnapping. On appeal, Defendant challenged the trial court's refusal to allow him to pursue during voir dire certain lines of inquiry relating to racial bias and police-officer shootings of black civilians. The court of appeals rejected Defendant's claims and found no error in the trial court's judgment. The Supreme Court reversed, holding that the trial court abused its discretion and prejudiced Defendant by restricting all inquiry into prospective jurors' racial biases and opinions regarding police officer shootings of black men. View "State v. Crump" on Justia Law

The Supreme Court vacated Defendant's convictions and the resulting judgments against him, holding that the trial court committed prejudicial error in its jury instruction on the theory of acting in concert as a basis upon which to find Defendant guilty.After a jury trial, Defendant was convicted of simple possession of methamphetamine, heroin, and cocaine. During trial, the trial court gave instructions to the jury on both constructive possession and acting in concert as legal theories underlying the drug possession charges. The court of appeals affirmed. The Supreme Court reversed the decision of the court of appeals and vacated Defendant's convictions, holding that the trial court erred in instructing the jury on Defendant's criminal culpability on the theory of acting in concert, and the error was not harmless. View "State v. Glover" on Justia Law

The Supreme Court affirmed the decision of the court of appeals holding that substantial evidence existed to create a bona fide doubt as to Defendant's competency and that, therefore, the trial court's failure to make an inquiry into Defendant's competency at trial violated his due process rights, holding that the trial court committed prejudicial error by failing to conduct a competency hearing for Defendant.After a jury trial, Defendant was convicted of three counts each of second-degree sexual offense and taking indecent liberties with a child. On appeal, Defendant argued that events that occurred during trial combined with his lengthy history of mental illness, which included periods of incompetence to stand trial, created a duty upon the trial court sua sponte to inquire into his competency to stand trial. The court of appeals remanded the case to the trial court for a termination of whether a meaningful retrospective hearing could be conducted on the issue of Defendant's competency at the time of his trial. The Supreme Court affirmed, holding that, in light of substantial evidence that was sufficient to raise a bona fide doubt regarding Defendant's competency to stand trial, the trial court committed prejudicial error by failing to conduct a competency hearing for Defendant. View "State v. Hollars" on Justia Law

The Supreme Court held that the scheduling and procedural circumstances existent in this case did not constitute an infringement upon Defendant's constitutional right to a speedy trial.After a jury trial, Defendant was convicted of first-degree sex offense with a child and indecent liberties with a child. On appeal, Defendant argued that the trial court erred by denying his motion to dismiss the charges against him because the State violated his constitutional right to a speedy trial by failing to calendar his trial date for approximately five years following the issuance of the indictments against him. The court of appeals affirmed, holding that here was no speedy trial violation. The Supreme Court affirmed after weighing the factors set forth in Barker v. Wingo, 407 U.S. 514 (1972), as they applied to the circumstances of this case, holding that Defendant's constitutional right to a speedy trial was not violated. View "State v. Farmer" on Justia Law

The Supreme Court remanded this case for a new trial with respect to the issue of Defendant's guilt of the murder of his grandfather, holding that the court of appeals erred in holding that the trial court's instruction that the jury was entitled to find that Defendant attempted to murder his mother using a garden hoe as a deadly weapon did not constitute prejudicial error.After a jury trial, Defendant was convicted of robbery with a dangerous weapon, the attempted first-degree murder of his mother, and the first degree murder of his grandfather on the basis of the felony-murder rule using attempted first-degree murder as the predicate felony. On appeal, Defendant argued that the trial court erred in its jury instructions. The court of appeals affirmed. The Supreme Court reversed and remanded the case for a new trial, holding (1) the court of appeals did not err in holding that the trial court did not err by instructing that the jury could find that Defendant's hands and arms constituted a deadly weapon for purposes of the felony-murder provisions of N.C. Gen. Stat. 14-17(a); but (2) the trial court's instruction concerning the use of the garden hoe as a deadly weapon during Defendant's alleged attempt to murder his mother constituted prejudicial error necessitating a new trial in the case in which Defendant was convicted of murdering his grandfather. View "State v. Steen" on Justia Law