Justia North Carolina Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of conspiracy to traffic in more than four, but less than fourteen, grams of opium in violation of N.C. Gen. Stat. 90-95(h)(4)(a). The court of appeals vacated the trial court’s judgment, concluding that the State presented insufficient evidence that Defendant conspired or formed an agreement with another individual to traffic in Oxycodone, an opium derivative. The Supreme Court reversed, holding that the State presented sufficient evidence to support the jury’s determination that Defendant agreed with another individual to traffic in at least four, but not more than fourteen, grams of Oxycodone. Remanded. View "State v. Winkler" on Justia Law

After a jury trial, Defendant was found guilty of possession of a stolen motor vehicle. The trial court sentenced Defendant to an active term of eighty-four to 113 months’ imprisonment. Defendant appealed, arguing that the trial court erred in denying his request for a jury instruction on unauthorized use of a motor vehicle as a lesser-included offense of possession of a stolen vehicle. The Court of Appeals affirmed, concluding that it was bound by its decision in State v. Oliver, which held that unauthorized use of a motor vehicle is not a lesser-included offense of possession of a stolen vehicle. Defendant appealed, claiming that Oliver was wrongly decided because that decision incorrectly interpreted the Supreme Court’s decision in State v. Nickerson. The Supreme Court affirmed as modified, holding (1) the Oliver court misapprehended the Supreme Court’s decision in Nickerson, and therefore, Oliver is overruled to the extent that it is inconsistent with this opinion; but (2) nevertheless, the offense of unauthorized use of a motor vehicle is not a lesser-included offense of possession of a stolen vehicle, and therefore, the trial court did not err in denying Defendant’s request to instruct the jury on unauthorized use of a motor vehicle. View "State v. Robinson" on Justia Law

After a jury trial, Defendant was convicted for accessing a commercial social networking Web site as a registered sex offender in violation of N.C. Gen. Stat. 14-202.5. Defendant appealed, arguing that section 14-202.5 is unconstitutional on its face or as applied to him. The Court of Appeals vacated Defendant’s conviction, concluding that the statute violates the First Amendment and thus is unconstitutional on its face and as applied. The Supreme Court reversed, holding that section 14-202.5 is constitutional on its face, is constitutional as applied to Defendant, and is not unconstitutionally overbroad or vague. View "State v. Packingham" on Justia Law

Defendant was charged with impaired driving. Defendant filed a pretrial motion to suppress evidence obtained after his arrest. At the suppression hearing held before Judge Abraham Jones, a material conflict in the evidence arose from a disagreement between two expert witnesses. Judge Jones orally granted Defendant’s motion but was not able to sign a proposed written order reflecting his decision before his term of office expired. Defendant subsequently presented the proposed order to Judge Orlando Hudson. Judge Hudson granted Defendant’s motion to suppress without hearing any evidence himself, finding that Defendant’s expert was credible and that no probable cause existed to support Defendant’s arrest. The Court of Appeals affirmed the oral ruling rendered by Judge Jones without reaching the State’s contention that Judge Hudson was without authority to sign the order. The Supreme Court reversed, holding (1) N.C. Gen. Stat. 15A-977 requires the judge who presides at the suppression hearing to make the findings of fact necessary to decide the motion; and (2) in this case, although a second judge made the findings of fact necessary to resolve the material conflict in the evidence presented at the suppression hearing, he did so without hearing any evidence himself, and therefore, a new suppression hearing was required. View "State v. Bartlett" on Justia Law

After a jury trial, Defendant was convicted of felonious larceny, misdemeanor injury to personal property, first degree trespass, and misdemeanor possession of stolen property. The convictions stemmed from an incident in which police officers stopped Defendant’s vehicle while he was driving on the campus of the North Carolina State University (NCSU) and discovered copper wire taken from an electrical substation on campus. Defendant appealed, arguing that the trial court lacked subject matter jurisdiction over the injury to personal property charge because the information filed failed to allege that NCSU and “NCSU High Voltage Distribution” were legal entities capable of owning property. The Court of Appeals vacated Defendant’s conviction for the injury to personal property charge, concluding that the trial court lacked jurisdiction over the charge because the information failed to allege that NCSU High Voltage Distribution was capable of owning property. The Supreme Court reversed, holding that where a criminal pleading alleges that injury to personal property was committed against multiple entities, at least one of which is capable of owning property, that pleading is not facially invalid. View "State v. Ellis" on Justia Law

An investigation that began with an anonymous complaint to police led to a search of Defendant’s home. The police applied for and received a warrant to search the apartment. When the warrant was executed, the officers discovered controlled substances, drug paraphernalia, and a firearm and ammunition. Defendant was arrested and indicted for drug trafficking, drug possession, and firearm charges. Defendant moved to suppress the evidence seized from his residence, arguing that the warrant was not supported by probable cause. The trial court denied the motion, and Defendant later pleaded guilty to several charges. The court of appeals reversed, holding that the search warrant was unsupported by probable cause. The Supreme Court reversed, holding that, under the the totality of circumstances, the evidence described in the affidavit was sufficient to support the magistrate’s finding of probable cause to search Defendant’s apartment. View "State v. McKinney" on Justia Law

Plaintiffs, two private corporations, sought a copy of the Automated Criminal/Infraction System database via the state’s Public Records Act (Act). The North Carolina Administrative Office of the Courts (AOC) declined to produce an index of the ACIS database and declined to provide a copy of the ACIS. Plaintiffs filed suit seeking an order requiring production of the requested materials and seeking a declaration that the ACIS database is a public document or public information as defined in the Act. The trial court granted judgment for Defendants on their responsive pleadings and dismissed the case. The court of appeals reversed as to the AOC, concluding that ACIS is a public record subject to disclosure under the Act and that the AOC was the custodian of the ACIS. The Supreme Court reversed, holding (1) N.C. Gen. Stat. 7A-109(d), addressing “remote electronic access” to court records, is a more specific statute that overrides applicability of the Act in this case; and (2) the legislature intended that remote electronic access to the ACIS be available solely through nonexclusive contracts, as provided in section 7A-109(d). Remanded. View "LexisNexis Risk Data Mgmt., Inc. v. N.C. Admin. Office of Courts" on Justia Law

After a second jury trial, Defendant was convicted of the first-degree murder of his wife, Michelle Young. The court of appeals vacated the conviction and ordered a new trial, concluding that the trial court had committed prejudicial error by admitting evidence concerning a complaint that had been filed and default judgments that had been entered in two actions - a wrongful death and declaratory judgment action that had been brought against Defendant by the executrix of Ms. Young’s estate and a complaint that had been filed in an action in which members of Ms. Young’s family sought to obtain custody of Emily, the daughter of Defendant and the victim, from Defendant. The Supreme Court reversed, holding that the court of appeals erred by awarding Defendant a new trial based upon the admission of the challenged evidence. Remanded for consideration of Defendant’s remaining challenges to the trial court’s judgment. View "State v. Young" on Justia Law

After a jury trial, Defendant was convicted of robbery with a dangerous weapon, second-degree burglary, and first-degree murder under the felony murder rule. Defendant was sentenced to life imprisonment without parole. The Court of Appeals vacated the judgment and ordered that Defendant receive a new trial, holding that the trial court abused its discretion by excluding evidence of a threatening voice mail message left by one of Defendant’s sisters for a different sister and that the error was prejudicial. The Supreme Court reversed, holding that the trial court’s ruling that the probative value of the voice mail message was outweighed by other concerns under N.C. R. Evid. 403 was not “manifestly unsupported by reason.” View "State v. Triplett" on Justia Law

Defendant was indicted for felony breaking or entering a place of worship and felony larceny after breaking or entering. After a trial, the jury found Defendant guilty of felony larceny and felony breaking or entering a place of religious worship. The court of appeals vacated Defendant’s larceny conviction and reversed his conviction for breaking or entering, concluding (1) the larceny indictment was “fatally flawed” because it it did not specifically state that a church, the alleged co-owner of the stolen property, was a legal entity capable of owning property; and (2) there was insufficient evidence of Defendant’s intent to commit larceny. The Supreme Court reversed, holding (1) the indictment was sufficient on its face because the name of a church necessarily imports an entity capable of owning property; and (2) there was sufficient evidence of Defendant’s criminal intent to sustain a conviction for felony breaking or entering a place of religious worship. Remanded. View "State v. Campbell" on Justia Law