Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction, holding that the trial court clearly erred in ruling that Defendant failed to prove purposeful discrimination with respect to the State's use of peremptory challenges to strike three jurors without considering all of the evidence presented by Defendant.Defendant was found guilty of one count of first-degree murder and other crimes. On appeal, Defendant argued that the trial court erred by failing to grant three objections that he made under Batson v. Kentucky, 476 U.S. 79 (1986). The court of appeals affirmed Defendant's convictions. The Supreme Court reversed, holding (1) the court of appeals erred in its analysis of Defendant's Batson claims with respect to the three jurors; and (2) as to all three jurors, remand was required for reconsideration of whether Defendant proved purposeful discrimination in each case. View "State v. Hobbs" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's judgment convicting Defendant for conspiracy to commit harassment of a juror, holding that the trial court erred in denying Defendant's motion to dismiss the conspiracy charge for insufficient evidence.Defendant was convicted of conspiracy to commit harassment of a juror because of his actions at a courthouse following his twin brother's conviction for assault on a government official. On appeal, the court of appeals concluded that the trial court did not err in denying Defendant's motion to dismiss the conspiracy charge for insufficient evidence. The Supreme Court reversed, holding that the evidence in Defendant's trial was insufficient to raise anything more than mere conjecture that he had made an agreement with another person to threaten or intimidate a juror. View "State v. Mylett" on Justia Law

The Supreme Court reversed the decision of the Court of Appeals affirming the trial court's denial of Defendant's motion to suppress evidence, holding that there was no reasonable suspicion to justify the law enforcement officer's stop when Defendant signaled with his middle finger from the passenger side window of a moving vehicle.While assisting a stranded motorist, the officer turned his attention to another car traveling on the roadway, a white SUV. Defendant had his arm outside the passenger window and gestured with his middle finger, making an up-and-down motion. Believing that Defendant was committing the crime of disorderly conduct, the officer pursued and then stopped the SUV. At trial, Defendant moved to suppress the officer's testimony, arguing that there was no reasonable suspicion to justify the stop. The trial court denied the motion. Defendant pleaded guilty to resisting, delaying, or obstructing a public officer. The court of appeals affirmed the trial court's denial of Defendant's motion to suppress. The Supreme Court reversed, holding that the specific, articulable facts did not establish reasonable suspicion of the crime of disorderly conduct. View "State v. Ellis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing judgments entered by the superior court convicting and sentencing Defendant on five separate counts for violation of N.C. Gen. Stat. 14-269.2(b) based on an incident in which he was discovered on the grounds of a school in possession of five guns, holding that, under the rule of lenity, Defendant could only lawfully be convicted on one firearm count.Defendant's convictions arose from an incident in which he was discovered on the grounds of a school in possession of five guns. At issue was whether section 14-259.2(b) was ambiguous as to whether multiple convictions are permitted for the simultaneous possession of more than one firearm on a single occasion. The Supreme Court invoked the rule of lenity and held that Defendant could be convicted of only a single violation of the statute. View "State v. Conley" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals affirming Defendant's convictions, holding that Defendant preserved his challenges to the sufficiency of the evidence for appeal but that the State presented sufficient evidence to support the convictions.A jury found Defendant guilty of obtaining property worth less than $100,000 by false pretenses, accessing a government computer, altering court records, and unlicensed bail bonding. On appeal, Defendant argued that the State presented insufficient evidence that he aided and abetted another and that he obtained a thing of value. The court of appeals concluded that Defendant waived his challenge to the sufficiency of the State's evidence of aiding and abetting and that Defendant waived his right to appellate review to the sufficiency of the State's evidence that he obtained a thing of value. The Supreme Court affirmed as modified, holding (1) Defendant preserved each of his challenges to the sufficiency of the evidence; and (2) the State presented sufficient evidence that Defendant aided and abetted another and that he obtained a thing of value. View "State v. Golder" on Justia Law

The Supreme Court reversed the judgment of the court of appeals awarding Defendant a new trial after he was convicted of first-degree murder, holding that the trial court did not commit prejudicial error when it overruled Defendant's objections to the State's closing argument.A jury found Defendant guilty of first-degree murder by premeditation and deliberation and/or by lying in wait. On appeal, Defendant argued that the trial court abused its discretion when it failed to sustain his objections to comments made by the prosecutor during closing argument about race. The court of appeals agreed, holding that the trial court committed prejudicial error by overruling Defendant's objections to the prosecutor's comments and by failing to instruct the jury to disregard the comments or to declare a mistrial. The Supreme Court reversed, holding that, assuming without deciding that the prosecutor's comments were improper, Defendant was not prejudiced by the error. View "State v. Copley" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions and rejecting Defendant's argument that the trial court erred in denying his motion to dismiss on jurisdictional grounds, holding that Defendant failed to demonstrate that he was an Indian for purposes of the federal Indian Major Crimes Act (IMCA) such that he was not subject to the jurisdiction of North Carolina's courts.Defendant was charged in Jackson County with first-degree murder, robbery with a dangerous weapon, and possession of a firearm by a felon. Defendant moved to dismiss the charges for lack of subject matter jurisdiction, arguing that he was an Indian, and therefore, he could only be tried in federal court pursuant to the IMCA. After a hearing, the trial court denied Defendant's motion to dismiss, determining that Defendant was not an Indian within the meaning of the IMCA. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to dismiss; and (2) the trial court did not err by denying Defendant's request for a special jury verdict. View "State v. Nobles" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that the trial court failed to satisfy the requirements of N.C. Gen. Stat. 15A-1242 before allowing Defendant to proceed pro se, holding that the court of appeals correctly concluded that Defendant did not forfeit his right to counsel and that the trial court was therefore required to ensure that his waiver of counsel was knowing, intelligent, and voluntary.Defendant was charged with offenses related to his failure to maintain a valid driver's license. Defendant was first tried in the district court, where he was convicted. Defendant appealed to the superior court, where he was tried without counsel and convicted by a jury. On appeal, a majority of the court of appeals determined that Defendant did not engage in such serious misconduct as to warrant forfeiture of the right to counsel. The Supreme Court affirmed, holding that Defendant was entitled to a new trial because the trial court violated his right to counsel under the federal and state Constitutions. View "State v. Simpkins" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the superior court's judgment following Defendant's plea of guilty to trafficking in cocaine, holding that the court of appeals correctly determined that the trial court erred in denying Defendant's motion to suppress evidence discovered pursuant to an unlawful traffic stop.In his appeal, Defendant argued that his initial investigatory detention was not properly tailored to address a speeding violation and contended that the officer seized him without consent or reasonable suspicion of criminal activity. Therefore, Defendant argued, the officer unlawfully seized items from the vehicle during the ensuing search of the car and that those objects were the fruit of the poisonous tree. The court of appeals reversed the denial of the motion to suppress, concluding that the officer lacked reasonable suspicion to search the vehicle after the traffic stop had been completed. The Supreme Court affirmed, holding that the evidence was obtained as a result of the officer's unlawful detainment of Defendant without reasonable suspicion of criminal activity after the lawful duration of the traffic stop had concluded. View "State v. Reed" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing in part the trial court's judgments and holding that the trial court had erred by denying Defendant's motion to dismiss the possession of a weapon of mass death and destruction charge for insufficiency of the evidence, holding that a "flash bang" grenade is a weapon of mass death and destruction as defined in N.C. Gen. Stat. 14-288.8(a).Defendant was convicted of, among other things, possession of a weapon of mass death and destruction, which stemmed from his possession of "flash bang" grenades. The court of appeals reversed in part, holding that the flash bang grenades found in Defendant's car were not devices or weapons or grenades capable of causing mass death and destruction when constructing section 14-288.8(c)(1). The Supreme Court reversed, holding that the State presented substantial evidence tending to show that Defendant possessed an "explosive or incendiary" grenade in violation of N.C. Gen. Stat. 14-288.8(a). View "State v. Carey" on Justia Law