Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing a superior court order, holding that Defendant failed to meet the required condition of N.C. Gen. Stat. 15A-269(a) that postconviction DNA testing of certain biological evidence was material to his defense, and Defendant further failed to satisfy his lesser burden to show under section 15A-269(c) that DNA testing may be material to his claim of wrongful conviction.Defendant was convicted of first-degree murder and first-degree burglary. Defendant later filed a pro se motion for postconviction DNA testing pursuant to section 15A-269. The superior court denied the motion on the grounds that the evidence of his guilt was overwhelming and that Defendant failed to show how conducting additional DNA testing was material to his defense. The court of appeals reversed and remanded for entry of an order appointing counsel to assist Defendant in which Defendant would attempt to establish the level of materiality required to obtain DNA testing. The Supreme Court reversed, holding that Defendant did not satisfy the necessary conditions to obtain the appointment of counsel under section 15A-269(c). View "State v. Byers" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that Defendant received ineffective assistance of appellate counsel, holding that Defendant failed to prove that his appellate counsel's representation fell below an objective standard of reasonableness.After a jury trial, Defendant was found guilty of possession of a firearm by a felon and being a habitual felon. The court of appeals affirmed. Defendant subsequently filed a motion for appropriate relief alleging ineffective assistance of appellate counsel. Specifically, Defendant asserted that appellate counsel's failure to cite State v. Pakulski, 356 S.E.2d 319 (N.C. 1987), amounted to ineffective assistance. After a successful appeal and remand, the trial court granted the motion. The court of appeals affirmed, holding that Defendant's appellate counsel was constitutionally ineffective for failing to make arguments under Pakulski. The Supreme Court reversed, holding the precedent established in Pakulski did not govern the instant case and that appellate counsel's failure to rely on Pakulski was objectively reasonable. View "State v. Collington" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals remanding this case for a new trial on an assault charge and vacating the judgment convicting Defendant of first-degree murder and remanding for entry of judgment convicting Defendant of second-degree murder, holding that Defendant was prejudiced by the trial court's failure to give his proffered jury instructions and that the proper remedy for this prejudicial error was to remand the case for a new trial on all charges.Defendant was found guilty of first-degree murder based on the felony murder rule with an assault charge as the underlying felony. The court of appeals determined that the trial court committed prejudicial error by not instructing the jury on self-defense with regard to the assault charge and granted a new trial on the assault charge. The Supreme Court affirmed in part and reversed in part, holding that the failure to give the proposed instructions prejudiced Defendant and that Defendant should receive a new trial on all charges. View "State v. Greenfield" on Justia Law

The Supreme Court vacated the order of the trial court dismissing Defendant's motion for appropriate relief (MAR) in which Defendant asserted claims under the Racial Justice Act (RJA), holding that the retroactive application of the 2012 amended RJA and the 2013 repeal of the RJA violates the constitutional prohibitions against ex post facto laws.The trial court dismissed Defendant's MAR, concluding that it was voided by the repeal of the RJA. The Supreme Court vacated the trial court's order and remanded the case for the reinstatement of Defendant's sentence of life imprisonment without parole, holding (1) the retroactivity provision of the RJA repeal violated the double jeopardy protections of the North Carolina Constitution; (2) the judgment sentencing Defendant to life imprisonment without the possibility of parole was a final judgment, and therefore, double jeopardy barred further review; and (3) the retroactive application of the RJA repeal violates the prohibitions against ex post facto laws contained in the state and federal constitutions. View "State v. Augustine" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that the General Assembly did not intend for the means of proof mentioned in the Habitual Felons Act, N.C. Gen. Stat. 14-7.4, to be exclusive, holding that the methods of proof listed in section 14-7.4 are not exclusive.Defendant was indicted on charges of interfering with an electronic monitoring device and attaining the status of habitual felon. Defendant was found guilty of interfering with an electronic monitoring device. During the habitual felon phase of the trial, the court introduced into evidence a computer printout from the Automated Criminal / Infraction System (ACIS) showing that Defendant had been convicted of felonious breaking and entering. The jury found that Defendant had attained the status of a habitual felon. On appeal, Defendant argued that the trial court erred by allowing into evidence the ACIS printout as proof of his prior conviction for the purpose of establishing that he was a habitual felon. The court of appeals affirmed. The Supreme Court affirmed, holding that section 14-7.4 is permissive, rather than mandatory, with respect to the issue of how a defendant's prior convictions may be established and that such convictions may be proven by means of any admissible evidence. View "State v. Waycaster" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's convictions, holding that the State presented sufficient evidence at trial to show that Defendant possessed the felonious intent necessary to support his convictions.Defendant was convicted of conspiracy to commit robbery with a dangerous weapon, felonious breaking or entering, and discharging a weapon into an occupied property. During trial, Defendant had moved to dismiss the charges against him for insufficiency of the evidence, but the trial court denied the motion. The court of appeals reversed Defendant's conviction for conspiracy to commit robbery with a dangerous weapon and for felonious breaking or entering on the basis of insufficiency of the evidence. The Supreme Court reversed, holding that, due to the existence of sufficient evidence regarding felonious intent, the trial court properly denied Defendant's motions to dismiss the charges against him. View "State v. Cox" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing Defendant's convictions and granting Defendant a new trial, holding that the trial court erred by declining to give Defendant's requested jury instruction on self defense and the defense of habitation.After a jury trial, Defendant was found guilty of assault with a deadly weapon inflicting serious injury and possession of a firearm by a felon. The court of appeals reversed, holding that the trial court erred by failing to give Defendant's requested jury instructions on the law of self-defense with the stand-your-ground provision and the law of the defense of habitation. The Supreme Court affirmed, holding (1) there was sufficient evidence presented at trial to support the submission of Defendant's requested instructions to the jury on self-defense and the defense of habitation; and (2) there was a reasonable possibility that had the trial court not committed prejudicial error in its presentation of instructions to the jury a different result would have been reached at the trial. View "State v. Coley" on Justia Law

The Supreme Court held that the retroactivity provision of the Racial Justice Act (RJA) Repeal violated the double jeopardy protections of the North Carolina Constitution.Defendant was convicted of first-degree murder and sentenced to death. After the North Carolina General Assembly enacted the RJA, Defendant filed a motion for appropriate relief pursuant to the RJA. After a hearing, the trial court concluded that race was a significant factor in the decisions of prosecutors to exercise peremptory challenges to strike African-American jurors and resentenced Defendant to life imprisonment without the possibility of parole. After three more defendants showed that their death sentences were sought or imposed on the basis of race the General Assembly repealed the RJA. The trial court concluded that the RJA Repeal retroactively voided the defendants' claims and dismissed each of the defendants' motions for appropriate relief. The Supreme Court vacated the trial court's order, holding that the retroactivity provision of the RJA Repeal violates double jeopardy protections and that, in any event, the State lacked the statutory authority to appeal that judgment. View "State v. Robinson" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals upholding Defendant's convictions for two counts of engaging in sexual activity with a student, holding that Defendant sufficiently preserved for appellate review whether the State presented sufficient evidence of each element of the crime for which he was convicted, but, nonetheless, the trial court properly denied Defendant's motion to dismiss.On appeal, Defendant argued that the trial court erred in denying his motion to dismiss based on insufficient evidence, arguing that the evidence at trial did not establish that he was a "teacher" within the meaning of N.C. Gen. Stat. 14-27.7(b). The court of appeals concluded that Defendant had failed to preserve his arguments for appellate review. The Supreme Court affirmed as modified, holding (1) Defendant sufficient preserved for appellate review all sufficiency of the evidence issues through his motion to dismiss at trial; and (2) Defendant fell within the "teacher" category under the statute. View "State v. Smith" on Justia Law

The Supreme Court held that Defendant could not be separately convicted and punished for the offenses of both habitual misdemeanor assault and felony assault inflicting serious bodily injury stemming from the same act.After a jury trial, Defendant was found guilty of habitual misdemeanor assault and felony assault. The court of appeals vacated the trial court's judgment on the offense of habitual misdemeanor assault, holding that the trial court erred in entering judgment and sentencing Defendant for both habitual misdemeanor assault and felony assault given that both offenses arose from the same act. The Supreme Court affirmed as modified, holding that (1) Defendant could not be separately convicted and punished for both misdemeanor assault and felony assault based on the same conduct; but (2) Defendant's conviction for habitual misdemeanor assault should have been arrested rather than vacated. View "State v. Fields" on Justia Law