Justia North Carolina Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing the order of the superior court (MAR court) granting Defendant's motion for appropriate relief (MAR) and awarding him a new trial, holding that the MAR court neither abused its discretion nor committed legal error in granting Defendant a new trial.Defendant was fourteen years old when he was indicted for and assaulting a cab driver who later died. Based largely on the basis of a confession Defendant made while being interrogated by a police detective outside the presence of a parent or guardian Defendant was convicted of first-degree murder. Years later, Defendant filed a MAR alleging that he was entitled to relief based on the newly discovered evidence of the testimony of a man who claimed that, on the night of the crime, another person confessed to him to assaulting the cab driver. The MAR court allowed the MAR and vacated Defendant's conviction. The court of appeals reversed. The Supreme Court reversed and remanded the case for a new trial, holding that the MAR court did not abuse its discretion in concluding that Defendant proved by a preponderance of the evidence all elements necessary to demonstrate his entitlement to a new trial on the basis of newly discovered evidence. View "State v. Reid" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the order of the trial court denying Defendant's motion for appropriate relief (MAR) and supplemental motion for appropriate relief (supplemental MAR) asserting that the indictment charging him with the offense of attempted robbery with a dangerous a dangerous weapon was fatally flawed, holding that the indictment was sufficient.Defendant pleaded guilty to second-degree murder and two robbery charges. The trial court denied both Defendant's MAR and supplemental MAR. The court of appeals reversed, concluding that the indictment's description of the victims of Defendant's attempted robbery was insufficient because it did not name the person against whom the offense was directed with certitude. The Supreme Court reversed, holding (1) the indictment comported with the requirements of N.C. Gen. Stat. 15A-924(a)(5) and the current status of the law; and (2) therefore, the trial court had the necessary jurisdiction to enter judgment against Defendant pursuant to his guilty plea. View "State v. Oldroyd" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that Defendant had failed to make the showing of materiality necessary to support an award of postconviction DNA testing, holding that there was no error.Defendant pleaded guilty to second-degree murder. After a sentencing hearing, Defendant was sentenced to a term of life imprisonment. The trial court denied Defendant's later request for postconviction DNA testing on the grounds that Defendant had failed to show that the requested testing would be material to his defense. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) Defendant's guilty plea did not preclude him from seeking postconviction DNA testing under N.C. Gen. Stat. 15A-269; and (2) the lower courts correctly concluded that Defendant failed to make the necessary showing of materiality. View "State v. Alexander" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree murder and possession of a firearm by a felon and his sentence of life imprisonment without parole, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not err or deprive Defendant of the right to a "complete self-defense instruction" by failing to instruct the jury using the exact language in which N.C.P.I. – Crim. 308.10 is couched; and (2) the court of appeals correctly held that Defendant failed properly to preserve his challenge to the trial court's second alleged instructional error for purposes of appellate review. View "State v. Benner" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing in part and vacating in part Defendant's convictions for insufficient evidence, holding that the court of appeals erred.After a jury trial, Defendant was found guilty of violating a civil domestic violence protective order while in possession of a deadly weapon, felonious breaking or entering, assault with a deadly weapon, and assault on a female. The court of appeals reversed Defendant's convictions for violation of a protective order and felonious breaking or entering for insufficient evidence. The Supreme Court reversed, holding that the court of appeals erred. View "State v. Tucker" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals affirming Defendant's convictions for first-degree murder, felonious speeding to elude arrest, and robbery with a dangerous weapon, holding that Defendant was disqualified from claiming the justification of self-defense.At issue on appeal was whether the trial court erred in instructing the jury that Defendant could not claim self-defense to justify his use of deadly force because he was also convicted of being a felon in possession of a firearm. The Supreme Court held (1) N.C. Gen. Stat. 14-51.4, the stand your ground law, requires the State to prove an immediate causal nexus between a defendant's attempt to commit, commission of, or escape after the commission of the felony and the circumstances giving rise to the defendant's perceived need to use force; (2) because the trial court failed to instruct the jury on this causal nexus requirement, the jury instructions were erroneous, but the error was not prejudicial; and (3) under section 14-51.4(1), Defendant was disqualified from claiming the justification of self-defense. View "State v. McLymore" on Justia Law

The Supreme Court affirmed the decision of the trial court concluding that Defendant had committed the revocable probation violation of absconding, holding that the trial court did not abuse its discretion in revoking Defendant's probation upon concluding that Defendant had absconded his probation.Specifically, the Supreme Court held (1) the probation violation reports sufficiently alleged that Defendant absconded supervision; and (2) the trial court did not abuse its discretion in deciding to revoke Defendant's probation and to activate his suspended sentences upon Defendant admitting that he committed the revocable violation of absconding probation. View "State v. Crompton" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals upholding Defendant's conviction for taking indecent liberties with a child, holding that the case must be remanded for a new trial.On appeal, Defendant argued that the trial court erred in allowing the State's expert to testify that the minor child in this case was sexually abused in the absence of physical evidence confirming her opinion, that the State's expert identifying Defendant as the perpetrator of the charged offense constituted plain error, and that he received ineffective assistance of counsel (IAC). The court of appeals affirmed. The Supreme Court remanded the case for a new trial, holding (1) permitting testimony that the minor child was sexually assaulted in the absence of definitive physical evidence constituted plain error; (2) the trial court committed plain error in permitting testimony as to the medical recommendations identifying Defendant as the perpetrator; and (3) the court of appeals did not err in dismissing Defendant's IAC claim without prejudice. View "State v. Clark" on Justia Law

The Supreme Court vacated Defendant's conviction for robbery with a dangerous weapon, holding that the prosecutor's exclusion of an African-American potential juror constituted a substantive violation of Defendant's constitutional right to equal protection under Batson v. Kentucky, 476 U.S. 79 (1986).After the court of appeals affirmed Defendant's conviction, Defendant filed a notice of appeal with the Supreme Court, asserting that the case presented a substantial constitutional question under the Equal Protection Clause of the United States Constitution and N.C. Const. art. I, 19. The Supreme Court remanded the case to the trial court for reconsideration of Defendant's Batson challenge in light of the United States Supreme Court decision in Foster v. Chatman, 578 U.S. 488 (2016). On remand, the Supreme Court again ordered that Defendant's Batson objections be overruled. The Supreme Court reversed, holding that the State committed a substantive violation of Defendant's constitutional right to equal protection under the Fourteenth Amendment of the United States Constitution. View "State v. Clegg" on Justia Law

The Supreme Court modified and affirmed the ruling of the court of appeals finding no prejudicial error in the criminal proceedings resulting in Defendant's conviction for second-degree forcible rape and first-degree kidnapping, holding that there was no prejudicial error in the proceedings below. On appeal, Defendant alleged several trial court errors, including the two errors at issue on appeal. The court of appeals affirmed, thus rejecting each of Defendant's arguments. The Supreme Court modified and affirmed the court of appeals, holding that, assuming without deciding that the trial court's admission of certain testimony violated Defendant's rights under the Confrontation Clause and that other testimony violated N.C. R. Evid. 404(b), the assumed errors were not prejudicial. View "State v. Pabon" on Justia Law