Articles Posted in North Carolina Supreme Court

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A police officer’s decision to briefly detain Defendant for questioning was supported by a reasonable suspicion of criminal activity. Defendant was indicted for robbery with a dangerous weapon. Defendant moved to suppress evidence obtained as a result of his seizure by the police officer, asserting that he had been unlawfully detained, in violation of his constitutional rights. The trial court denied the motion to suppress, and Defendant was subsequently convicted of common law robbery. The court of appeals ordered a new trial, concluding that the trial court committed prejudicial error by denying Defendant’s suppression motion and that the police officer lacked reasonable suspicion to detain Defendant for questioning. The Supreme Court reversed, holding that the undisputed facts established reasonable suspicion necessary to justify Defendant’s seizure. View "State v. Nicholson" on Justia Law

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The Supreme Court reversed the decision of the court of appeals in vacating the judgments entered by the trial court based upon Defendant’s convictions for first-degree murder and attempted first-degree murder on the grounds that certain evidence had been admitted in violation of the Confrontation Clause. The court of appeals concluded that the statements at issue were admitted in violation of Defendant’s constitutional right to confront the State’s witnesses against him. The Supreme Court reversed, holding that the trial court did not err by overruling Defendant’s confrontation-based objection and allowing the admission of the challenged evidence. View "State v. Miller" on Justia Law

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Defendant’s Fourth Amendment claims were not reviewable on direct appeal, even for plain error, because Defendant completely waived them. A police officer found cocaine in Defendant’s coat pocket during a traffic stop. Defendant did not move in liming to suppress evidence of the cocaine, nor did Defendant object to the State’s use of the cocaine evidence at any point during his trial. On appeal, Defendant argued that the trial court plainly erred by admitting evidence of the cocaine and that the seizure of the cocaine violated his rights under the Fourth Amendment. The court of appeals ordered a new trial, concluding that the trial court committed plain error by admitting evidence of the cocaine. The Supreme Court reversed, holding that Defendant waived his Fourth Amendment claims by not moving to suppress evidence of the cocaine before or after trial. The Court remanded the case for consideration of Defendant’s ineffective assistance of counsel claim because the court of appeals did not reach this claim. View "State v. Miller" on Justia Law

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The Supreme Court affirmed Defendant’s convictions for first-degree murder, sexual offense of a child by a adult offender, and other crimes and his sentence of death, holding that there was no error in Defendant’s trial or sentencing and that Defendant’s death sentence was not disproportionate to his crimes. Among other things, the Supreme Court held (1) Defendant failed to meet his burden under Strickland v. Washington, 466 U.S. 668 (1984), of establishing that he received ineffective assistance of counsel; (2) Defendant failed to identify any error in the trial court’s evidentiary rulings; (3) the trial judge did not abuse his discretion in denying Defendant’s motions for a mistrial based upon an improper remark by the prosecutor during closing arguments; (4) there was no error in the jury instructions; (5) Defendant received a capital sentencing proceeding free of prejudicial error; and (6) the death sentence was not excessive or disproportionate. View "State v. McNeill" on Justia Law

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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

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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

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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

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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

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Defendant was charged with violating N.C. Gen. Stat. 90-95(d1)(1)(c). Defendant filed a motion requesting the trial court to declare section 90-95(d1)(1)(c) unconstitutional on the grounds that punishing him for violating a newly enacted statutory provision contravened his federal due process rights. The trial court denied Defendant’s motion. Thereafter, a jury convicted Defendant as charged. Defendant appealed, arguing that the statute, as applied to him, violated his due process rights. Specifically, Defendant argued that when a state has rendered otherwise innocent and lawful behavior subject to significant criminal penalties, due process considerations require either that scienter or mens rea be shown in order to prove guilt or, alternatively, that the State establish that Defendant had fair warning that a previously lawful act was now subject to a criminal sanction. The Court of Appeals held that section 90-95(d1)(1)(c) was unconstitutional as applied to Defendant on notice-related grounds. The Supreme Court reversed, holding that Defendant’s conviction did not result in a violation of his federal constitutional right to due process of law because the conviction rested upon Defendant's own active conduct rather than a “wholly passive” failure to act. View "State v. Miller" on Justia Law

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In two separate jury trials, Defendant was convicted of assault on a female, second-degree rape, second-degree sexual offense, and first-degree kidnapping. Defendant appealed, arguing that the second trial judge erred when she denied Defendant’s motion to suppress his custodial statements. The Court of Appeals ruled that Defendant did not understand his Miranda rights and therefore did not knowingly and intelligently waive them but that the trial judge’s error in admitting the custodial statements was not prejudicial. The Supreme Court affirmed as modified, holding (1) the Court of Appeals erred in finding that the admission of Defendant’s interrogation violated his Miranda rights; but (2) the Court of Appeals correctly upheld Defendant’s convictions and the judgment entered on those convictions. View "State v. Knight" on Justia Law