Justia North Carolina Supreme Court Opinion Summaries

Daniel Raymond Jonas was indicted for possession of a controlled substance after officers found methamphetamine in his car during a traffic stop. Jonas filed a pre-trial motion to suppress the evidence, arguing that the officer lacked reasonable suspicion for the stop and subsequent search of his vehicle. The trial court denied the motion. Jonas then pleaded guilty without a plea agreement, also known as an "open plea." He did not give notice of his intent to appeal before entering his guilty plea, but minutes after sentencing, his counsel gave oral notice of appeal on the record.The Court of Appeals unanimously held that Jonas was not required to give notice of intent to appeal the denial of the motion to suppress prior to entering his guilty plea because he did not plead guilty pursuant to a plea agreement. The Court of Appeals also held that the stop of Jonas's vehicle was unconstitutional, and that the trial court erred when it denied Jonas's motion to suppress.The Supreme Court of North Carolina was asked to extend the rule from State v. Reynolds, which requires a defendant to give notice of intent to appeal before finalizing plea negotiations, to cases where a defendant pleads guilty without a plea agreement. The court declined to do so, holding that when a defendant enters a guilty plea without a plea agreement, the defendant does not waive his or her right of appeal by pleading guilty without prior notice of intent to appeal. The court affirmed the decision of the Court of Appeals. View "State v. Jonas" on Justia Law

In August 2016, Chad Cameron Copley shot and killed Kourey Thomas as he crossed Copley's front yard. Copley was charged with first-degree murder and claimed self-defense and defense of habitation. The jury rejected these defenses and convicted him. Copley appealed, arguing that the prosecutor improperly mentioned race during closing arguments. The Supreme Court of North Carolina found no prejudicial error in the prosecutor’s remarks and remanded the case to the Court of Appeals to consider Copley’s remaining claims.On remand, the Court of Appeals examined Copley’s three outstanding arguments. It rejected each, finding no gross impropriety in the prosecutor’s closing statements on the defense of habitation, no reviewable error in the trial court’s jury instruction on the aggressor doctrine and habitation defense, and no error in the jury instruction on first-degree murder by lying in wait. Copley challenged each of these rulings.The Supreme Court of North Carolina found no gross impropriety in the prosecutor’s closing arguments and only invited error in the trial court’s instruction on the habitation defense. The court also found no prejudicial error in the instruction on first-degree murder by lying in wait. Therefore, the court modified and affirmed the Court of Appeals decision and upheld Copley’s conviction. View "State v. Copley" on Justia Law

The Supreme Court of North Carolina reversed a decision by the Court of Appeals that had vacated a conviction for second-degree rape due to a perceived deficiency in the indictment. The defendant, Charles Singleton, had been convicted of second-degree forcible rape, first-degree kidnapping, and felonious restraint. On appeal, Singleton argued that the indictment failed to allege that he knew or should have known that the victim was physically helpless, an essential element of the crime. The Court of Appeals agreed and vacated the rape conviction.The Supreme Court disagreed, holding that an indictment is sufficient to invoke a court's jurisdiction as long as it charges a defendant with violating the laws of the state. The court found that the indictment in this case clearly alleged a crime and was not required to allege actual or constructive knowledge of the victim's physical helplessness. The court also noted that the legislature has consistently acted to eliminate technicalities in criminal pleadings that impede justice. The court concluded that a mere pleading deficiency in an indictment does not deprive the courts of jurisdiction. The court therefore reversed the decision of the Court of Appeals and reinstated Singleton's conviction. View "State v. Singleton" on Justia Law

During an investigation of a stolen car, law enforcement officers followed a suspect into a nearby home where they discovered an illegal drug operation. One of the participants in the operation, the defendant, did not live at the residence and denied any ownership or control over the premises or the objects within, including a safe containing illegal items. The homeowner, who was also the defendant's uncle, consented to the search of the home. After the defendant was convicted of several drug-related offenses, he appealed, arguing that the evidence should have been suppressed because the police entered the home without a warrant.The Supreme Court of North Carolina was tasked with deciding if the defendant had standing to challenge the warrantless entry into the home, given that he had declared he did not live there. The Court of Appeals had previously reversed the trial court's denial of the motion to suppress, stating that the trial record did not support any finding that the defendant lacked a reasonable expectation of privacy in the home.The Supreme Court of North Carolina reversed the decision of the Court of Appeals, holding that the evidence presented at the suppression hearing could support findings that the defendant lacked standing to challenge the search. The court, however, noted that the trial court failed to make these findings despite the presence of materially conflicting evidence in the trial record. The case was remanded to the trial court for findings of fact based on the trial record. Depending on those findings, the trial court could again deny the motion to suppress, or it may grant the motion to suppress in whole or in part and order a new trial. View "State v. Jordan" on Justia Law

The Supreme Court of North Carolina was tasked with reviewing the decision of the Court of Appeals related to a defendant's claim of ineffective assistance of counsel. The defendant was convicted of first-degree murder in 1999 and sentenced to life imprisonment without parole. Over two decades later, the defendant filed a motion for appropriate relief (MAR), arguing that his trial counsel did not inform him of his right to testify and prevented him from testifying. He also claimed that his appellate counsel was ineffective because they filed an Anders brief.The Supreme Court concluded that the Court of Appeals correctly disposed of the defendant's claims. The record demonstrated that the defendant was aware of his right to testify, and there was no evidence to support his claim that his trial counsel prevented him from testifying. Furthermore, the defendant's claim that his appellate counsel was ineffective for failing to challenge limitations on an expert witness’s testimony was without merit because the trial court had appropriately restricted the expert from using legal terminology. Therefore, the defendant's claims of ineffective assistance of both trial and appellate counsel were deemed baseless.The Supreme Court also held that the standard of review set forth in a previous case, State v. Allen, which involved reviewing MARs in the light most favorable to defendants, was a departure from the court's longstanding standard of review. Thus, the court returned to the previous standard of review, which involves a statutory review pursuant to N.C.G.S. § 15A-1420(c). View "State v. Walker" on Justia Law

In the case of the State of North Carolina v. Russell William Tucker, the defendant argued that his conviction for first-degree murder and sentence of death should be overturned due to alleged discrimination in jury selection. He asserted that newly discovered evidence, a continuing legal education handout and a statistical study, supported his claim of purposeful discrimination. However, the defendant had failed to raise a Batson claim (a claim of discrimination in jury selection) during his original trial or in previous post-conviction proceedings. The Supreme Court of North Carolina found that the defendant’s claim was procedurally barred and affirmed the judgment of the Superior Court.The defendant killed a security guard and shot two police officers in 1994. He was convicted of first-degree murder and sentenced to death. During jury selection, the defendant raised objections to the State’s peremptory strikes against black prospective jurors. The trial court found that the defendant failed to establish a prima facie case of purposeful discrimination, and the defendant did not raise a Batson claim on direct appeal or in previous post-conviction proceedings.In this appeal, the defendant argued that the handout and study constituted newly discovered evidence that would support a Batson claim. The defense argued that these materials showed a pattern of racial discrimination in jury selection in North Carolina. However, the Court held that the defendant's claim was procedurally barred because he could have raised a Batson claim during his original trial or in previous post-conviction proceedings but failed to do so. The Court also found that the handout and study did not constitute newly discovered evidence and did not show that the defendant was prejudiced by the alleged discrimination. Therefore, the Court concluded that the defendant’s Batson claim was procedurally barred and affirmed the judgment of the Superior Court. View "State v. Tucker" on Justia Law

The Supreme Court of North Carolina heard a case regarding a traffic checkpoint where the defendant, Alvarez, was stopped, searched, and found in possession of illegal drugs. He moved to suppress the evidence, arguing that it was collected at an unconstitutional checkpoint. The trial court agreed with the defendant, ruling that the checkpoint violated the Fourth Amendment as the State failed to provide a valid primary programmatic purpose for it. The Court of Appeals affirmed this decision.However, the Supreme Court of North Carolina disagreed, holding that the officers at the checkpoint had an independent reasonable suspicion to stop Alvarez's vehicle, thus no violation of his Fourth Amendment rights occurred. This suspicion was based on Alvarez's behavior and driving, including his failure to maintain lane control. The court emphasized that reasonable suspicion is an issue separate from the constitutionality of the checkpoint.The court concluded that the trial court erred in granting the motion to suppress and that the Court of Appeals erred in affirming the trial court's order. As a result, the court reversed the decision of the Court of Appeals and remanded the case for further proceedings. The court declined to comment on the constitutionality of the traffic checkpoint due to the presence of independent reasonable suspicion. View "State v. Alvarez" on Justia Law

In April 2017, Isaiah Scott Beck, Daniel Silva, and Javier Holloway planned to rob a drug dealer in Boone, North Carolina. They initially did not have a specific target in mind. However, through a series of text messages, the trio agreed to rob a particular dealer, Mackenzie Beshears. On the day of the robbery, Silva met Beshears in her apartment while Beck and Holloway, wearing all black clothing and face coverings, broke into the apartment. The North Carolina Supreme Court had to determine whether there was substantial evidence to support Beck's conviction for conspiracy to commit robbery with a dangerous weapon and conspiracy to commit felonious breaking or entering.The Court found that the evidence showed that the original plan was to rob Beshears in the parking lot, but that a new plan was formed in the time between Silva’s first and second appearances at the apartment complex. This new plan involved Silva entering Beshears’ apartment for the meeting, and Beck and Holloway breaking into the apartment. Therefore, a rational juror could find that Beck entered into two separate conspiracies: one to commit robbery with a dangerous weapon and another to commit felonious breaking or entering.As such, the Court concluded that the trial court did not err in denying Beck's motion to dismiss the charges against him, including the charge of conspiracy to commit robbery with a dangerous weapon. The Court therefore directed the Court of Appeals to reinstate Beck's conviction for conspiracy to commit robbery with a dangerous weapon. View "State v. Beck" on Justia Law

In this case, the Supreme Court of North Carolina was tasked with interpreting N.C.G.S. § 14-208.12A, which allows for the removal of a registered sex offender from the North Carolina Sex Offender Registry ten years after initial registration. The defendant, Larry Fritsche, had argued that since he had registered as a sex offender in Colorado more than ten years ago, he was eligible for removal from the North Carolina registry. However, the trial court, using precedent set by the case In re Borden, denied his petition, stating that the ten-year period must be completed in North Carolina. The Court of Appeals affirmed this decision.Upon review, the Supreme Court also affirmed the lower courts' decisions. The court determined that the term "county" in the relevant statutes refers to a county in North Carolina, not any state. The court also noted that the purpose of the Sex Offender Protection Registration Programs was to protect North Carolina communities, and this protection could not be ensured if sex offenders could avoid registering in North Carolina due to time spent on another state's registry. Therefore, the court held that the term "initial county registration" in section 14-208.12A requires ten years of registration in North Carolina, not simply ten years of registration in any state. View "State v. Fritsche" on Justia Law

In the case before the Supreme Court of North Carolina, the defendant, Jahzion Wilson, was charged with first-degree murder under the felony-murder theory, with the underlying felony being attempted robbery with a dangerous weapon. Wilson argued that he was entitled to a jury instruction on second-degree murder as a lesser-included offense of first-degree murder. However, the court held that in order for a defendant to be entitled to an instruction on a lesser-included offense, there must be a conflict in the evidence of the underlying felony and the evidence must support the lesser-included offense. The defendant's own statements denying his involvement in the crime are not sufficient to create a conflict in the evidence. In this case, the court found that there was no conflict in the evidence supporting the underlying felony of attempted robbery with a dangerous weapon, thus, Wilson was not entitled to an instruction on second-degree murder. The court modified and affirmed the decision of the Court of Appeals. View "State v. Wilson" on Justia Law