Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing an order denying Defendant’s motion to suppress and vacating Defendant’s guilty plea.Defendant moved to suppress the evidence derived from a search of the car he was driving after he was pulled over for traffic violations, arguing that the search violated the Fourth Amendment. The trial court denied the motion to suppress. The court of appeals reversed, concluding that the traffic stop had been unlawfully prolonged under the standard that the United States Supreme Court set out in Rodriguez v. United States, 575 U.S. __ (2015). The Supreme Court reversed, holding that the stop was not unlawfully prolonged under the standard set forth in Rodriguez. View "State v. Bullock" on Justia Law

The indictment returned for the purpose of charging Defendant with the offense of robbery with a dangerous weapon was fatally defective because it did not sufficiently allege all of the essential elements of the offense.Defendant was convicted of robbery with a dangerous weapon. The Court of Appeals arrested judgment with respect to the charge of robbery with a dangerous weapon, concluding that the indictment intended to charge Defendant with robbery with a dangerous weapon was fatally defective because it failed to name any dangerous weapon that Defendant allegedly employed. The Supreme Court affirmed, holding that the indictment was fatally defective because it failed to allege sufficiently that Defendant possessed, used, or threatened to use a dangerous weapon. View "State v. Murrell" on Justia Law

Defendant was subjected to a custodial interrogation as defined in Miranda v. Arizona, 384 U.S. 436 (1966), when police questioned him while he was confined under a civil commitment order, and therefore, the failure of police to advise him of his Miranda rights rendered inadmissible the incriminating statements he made during the interrogation. The trial court concluded otherwise and denied Defendant’s motion to suppress. Defendant was subsequently convicted of robbery with a dangerous weapon. The Supreme Court reversed the trial court’s denial of Defendant’s motion to suppress and vacated his conviction, holding that the trial court’s order denying Defendant’s motion to suppress was an erroneous application of the law and that the error was prejudicial. View "State v. Hammonds" on Justia Law

In this criminal case, the prosecutor’s comments in his closing argument were improper but did not amount to prejudicial error in light of the evidence against Defendant, and therefore, the trial judge did not err by failing to intervene ex mero motu in the prosecutor’s closing arguments.The court of appeals vacated Defendant’s conviction and ordered a new trial, concluding that the prosecutor’s statements had the cumulative effect of resulting in unfair prejudice to Defendant, and therefore, the trial court erred by failing to intervene ex mero motu. The Supreme Court disagreed, holding (1) the prosecutor’s statements were improper; but (2) the statements were not so grossly improper as to prejudice Defendant’s due process rights. View "State v. Huey" on Justia Law

The superior court correctly denied Defendant’s motion to suppress.Defendant was pulled over for driving at an unsafe speed given the road conditions and cited for driving while impaired. Defendant filed a motion to suppress, which the superior court ultimately denied. Defendant eventually pleaded guilty to driving while impaired while preserving his right to appeal the denial of his motion to suppress. The court of appeals reversed, concluding that the traffic stop was unconstitutional because the police officer who pulled Defendant over did not have reasonable suspicion to do so. The Supreme Court reversed, holding that the traffic stop was constitutional because the officer had reasonable suspicion to initiate the traffic stop. View "State v. Johnson" on Justia Law

Defendant was convicted, after a jury trial, of attempted first-degree rape, first-degree sexual offense with a child, and kidnapping. Defendant appealed, arguing that his motion “for an instruction” was clearly a request for a limiting instruction regarding N.C. R. Evid. 404(b) evidence that had just been presented by the State’s witness. The court of appeals reversed Defendant’s convictions and remanded the matter to the trial court for a new trial. The Supreme Court modified in part the judgment of the court of appeals and affirmed, holding (1) defense counsel’s motion “for an instruction” was plain a request for a Rule 404(b) limiting instruction; and (2) Defendant was prejudiced by the trial court’s failure to give the requested limiting instruction, thus entitling him to a new trial. View "State v. Watts" on Justia Law

The court of appeals erred by determining the the trial court committed prejudicial error in instructing the jury concerning the right of self-defense.Defendant was charged with assault with a deadly weapon with the intent to kill and inflicting serious injury. Defendant requested that the trial court instruct the jury concerning the law of self-defense and defense of another. Instead of delivering the exact instruction that Defendant requested, the trial court instead instructed the jury with respect to the issue of self-defense using a modified version of the pattern jury instruction relating to felonious assaults. The jury found Defendant guilty. The court of appeals awarded Defendant a new trial on the grounds that the trial court’s deviations from the pattern self-defense instruction misstated the law. The Supreme Court reversed, holding that the trial court’s instructions concerning the law of self-defense were not erroneous. View "State v. Holloman" on Justia Law

The court of appeals erred by determining the the trial court committed prejudicial error in instructing the jury concerning the right of self-defense.Defendant was charged with assault with a deadly weapon with the intent to kill and inflicting serious injury. Defendant requested that the trial court instruct the jury concerning the law of self-defense and defense of another. Instead of delivering the exact instruction that Defendant requested, the trial court instead instructed the jury with respect to the issue of self-defense using a modified version of the pattern jury instruction relating to felonious assaults. The jury found Defendant guilty. The court of appeals awarded Defendant a new trial on the grounds that the trial court’s deviations from the pattern self-defense instruction misstated the law. The Supreme Court reversed, holding that the trial court’s instructions concerning the law of self-defense were not erroneous. View "State v. Holloman" on Justia Law

N.C. Gen. Stat. 20-16.2(b) alone does not create a per se exception to the warrant requirement.At issue before the Supreme Court was whether section 20-16.2(b), which authorizes law enforcement to obtain a blood sample from an unconscious defendant who is suspected of driving while impaired without first obtaining a search warrant, was unconstitutionally applied to Defendant. Defendant in this case filed a pretrial motion to suppress testing performed by law enforcement on his seized blood. The trial court granted the motion, concluding as a matter of law that the seizure of Defendant’s blood was a search subject to Fourth Amendment protection and, under a totality of the circumstances test, no exigency justified a warrantless search. The court of appeals affirmed. The Supreme Court affirmed as modified, holding that section 20-16.2(b) is unconstitutional under the Fourth Amendment as applied to Defendant in this case because (1) there was no dispute that there were no exigent circumstances justifying a warrantless blood draw; (2) section 20-16.2(b) does not create a per se exception to the warrant requirement; and (3) the State did not carry its burden of proving voluntary consent. View "State v. Romano" on Justia Law

Defendant was convicted of driving while impaired. The court of appeals awarded Defendant a new trial, concluding that N.C. R. Evid. 702(a1) requires that a witness explicitly be found to be an expert before testifying to the results of a horizontal gaze nystagmus (HGN) test and that the trial court erred in failing to recognize the law enforcement officer in this case as an expert pursuant to rule 702(a). The Supreme Court reversed the decision of the court of appeals awarding Defendant a new trial, holding (1) rule 702(a1) does not require a law enforcement officer to be recognized explicitly as an expert witness pursuant to rule 702(a) before he may testify to the results of an HGN test, and the trial court implicitly recognized the officer as an expert prior to allowing him to testify as to the issue of Defendant’s impairment; and (2) the trial court did not err in denying Defendant’s request for a special jury instruction to explain that results of a chemical breath test are not conclusive evidence of impairment. View "State v. Godwin" on Justia Law