Louis B. Meyer

The case concerned Darryl Eugene Hunt's retrial and conviction for first-degree felony murder in the 1984 death of Deborah Sykes, following reversal of his initial conviction. After a venue change due to publicity, the jury again found Hunt guilty based on evidence including the victim's body and clothing found near the crime scene, signs of struggle, stab wounds, and the state's theory that the murder occurred during the commission of robbery, rape, sexual offense, and kidnapping. The North Carolina Supreme Court reviewed numerous assignments of error from the trial record and concluded that Hunt received a fair trial free of prejudicial error. The court therefore affirmed the conviction and mandatory life sentence under N.C.G.S. § 14-17. A dissent argued that newly discovered DNA evidence excluding Hunt as the source of semen warranted a new trial under the standard for newly discovered evidence.

criminal lawprocedure

In State v. Ramseur, the defendant faced charges including assault with a deadly weapon with intent to kill inflicting serious injury stemming from a violent confrontation at a salvage yard in which he shot two men and struck a third, Junior Casstevens, with a gun butt and an air conditioning compressor. The court addressed the defendant's challenge to the sufficiency of the evidence supporting the assault charge against Casstevens, particularly the element of serious injury. The North Carolina Supreme Court concluded that the trial court committed no error in denying the motion to dismiss, as the evidence viewed in the light most favorable to the State established substantial proof of all elements of the offense. The core reasoning relied on testimony showing Casstevens sustained a badly bruised shoulder, pain, temporary loss of arm function, stitches for head wounds, and several hours of hospitalization.

criminal law

The case involved Ralph Edwin Hamilton, who was tried and convicted of first-degree murder for shooting and killing his wife, Marva Hamilton, multiple times in a hospital parking lot in 1991. The defendant appealed his conviction and life sentence, arguing that the trial court erred in its jury instructions regarding sanity and soundness of mind, the inference of intent from diminished mental capacity or intoxication, and the burden of proof on the elements of the crime. The North Carolina Supreme Court affirmed the conviction, holding that the trial was free of prejudicial error. The court reasoned that specific intent to kill is intertwined with the elements of premeditation and deliberation, so it was not error to instruct on them together in the context of voluntary intoxication or diminished capacity claims, and that the jury was properly and repeatedly instructed on the presumption of innocence and the state's burden of proof beyond a reasonable doubt.

criminal law

In State v. Moseley, the defendant was tried in Stokes County for the first-degree murder, first-degree rape, and first-degree sexual offense of Dorothy Louise Woods Johnson, whose body was found after she was last seen at a local dance club; the evidence showed she had been beaten, sexually assaulted, raped, and strangled. The jury convicted the defendant on all counts and recommended the death penalty for the murder, which the trial court imposed along with consecutive life sentences for the other offenses. On appeal, the North Carolina Supreme Court addressed the defendant's motion for change of venue based on pretrial publicity from this case and a prior similar conviction in a neighboring county, finding that the trial court did not abuse its discretion in denying the motion because the defendant failed to demonstrate a reasonable likelihood of prejudice preventing a fair trial. The court further reviewed the capital sentencing proceeding and concluded that the death sentence was not disproportionate, given the aggravating circumstances such as the especially heinous nature of the crime and the defendant's prior violent felony conviction, as compared to similar cases. The court ultimately held that the defendant received a fair trial and sentencing free of prejudicial error.

criminal lawprocedure

The case involved defendant Wilson, who was charged and convicted of first-degree murder, conspiracy to commit murder, and first-degree burglary in connection with the shooting death of Calvin Hargrove during a drug-related dispute. The trial court imposed two consecutive life sentences plus thirty years, and on appeal Wilson raised multiple assignments of error including evidentiary rulings, prosecutorial arguments, and whether the conspiracy conviction merged with the murder conviction. The court held there was no error in the murder conviction, which was supported by evidence that Wilson acted as an accessory before the fact by supplying weapons and directing others to kill Hargrove, but it remanded for resentencing on the conspiracy and burglary convictions because those sentences were improperly imposed. The court rejected the merger argument, citing precedent that conspiracy and accessory before the fact each contain distinct elements.

criminal lawprocedure

In State v. Sidberry, the defendant was convicted of first-degree murder and sentenced to life imprisonment based on evidence that he encouraged an associate to shoot the victim during an argument over stolen money and provided the gun used in the shooting. On appeal, the defendant argued that the trial court erred by allowing cross-examination about his prior guilty pleas to unrelated drug charges, by excluding certain testimony from his aunt as an excited utterance under Rule 803(2), and by admitting a witness's prior statement as corroboration despite material discrepancies with the witness's trial testimony. The court held that a guilty plea is equivalent to a conviction for impeachment purposes under Rule 609(a), that any error in admitting the discrepant corroborative statement was harmless in light of other evidence, and that the trial court's rulings did not constitute prejudicial error. The court therefore affirmed the conviction and sentence.

criminal lawprocedure

In State v. Gray, the defendant was convicted of first-degree murder after shooting Reginald Anderson in the chest during an argument in a park on November 15, 1992, and received a mandatory life sentence. The defendant appealed, contending that the trial court erred by admitting cumulative autopsy photographs and that the evidence was insufficient to prove premeditation and deliberation or to disprove self-defense. The court reviewed witness accounts of the scuffle, the defendant's actions in pulling and firing the gun, and the size disparity between the parties, finding substantial evidence supporting the first-degree murder conviction when viewed in the light most favorable to the State. It further held that the evidence did not establish self-defense as a matter of law under the four required elements and that no trial errors occurred.

criminal lawprocedure

The case involved defendant John Dennis Daniels, who was convicted after a capital trial of first-degree murder of his aunt (on theories of both felony murder and premeditation and deliberation), common law robbery, multiple assaults with deadly weapons against family members and a neighbor, and attempting to burn a dwelling. The jury found three aggravating circumstances and eleven mitigating circumstances before recommending a death sentence, which the trial court imposed along with consecutive prison terms for the other convictions. The North Carolina Supreme Court reviewed the guilt-innocence and capital sentencing phases, considered evidence including the defendant's statements and psychiatric testimony, and affirmed the convictions and death sentence after finding no error.

criminal law

This case concerns a child custody dispute between Jake Phelps and Lisa Phelps over their son following their separation and divorce. The trial court awarded sole custody to the mother with extensive visitation rights to the father after making findings about both parents' fitness, lifestyles, inability to cooperate on joint custody, and the child's best interests. The Court of Appeals had addressed certain evidentiary and constitutional issues, but the North Carolina Supreme Court reversed that decision and reinstated the trial court's custody order. The Supreme Court held that the trial court's findings of fact were supported by competent evidence, that brief references to the father's age did not violate equal protection, and that the trial judge properly exercised discretion regarding hearsay statements from the child.

family law

This case involved five outdoor advertising companies challenging a 1983 Raleigh ordinance that limited the size, height, and placement of billboards, declared existing nonconforming signs as such, and imposed a five-and-a-half-year amortization period for their removal without compensation, alleging it amounted to an unconstitutional regulatory taking under 42 U.S.C. § 1983. The companies filed suit in April 1989 after receiving a removal demand, but the trial court dismissed the complaint as time-barred. The North Carolina Supreme Court determined that the trial judge had jurisdiction to enter the dismissal order and that the three-year statute of limitations applicable to the § 1983 claim had begun running upon the ordinance's adoption in 1983, making the filing untimely, and therefore reversed the Court of Appeals and reinstated the dismissal.

business & regulatorypropertycivil rightsprocedure

The case involved Sherman Skipper, who was convicted of two counts of first-degree murder after shooting and killing Ailene Pittman and her grandson Nelson Fipps in Pittman's driveway following an argument. Skipper received death sentences based on aggravating factors including prior violent felonies and a course of conduct involving violence to multiple victims, though the jury also found mitigating circumstances such as mental and emotional disturbance. On appeal, the North Carolina Supreme Court addressed challenges to the excusal of a prospective juror for cause due to her death-penalty scruples and to the jury's rejection of mental retardation as a nonstatutory mitigating factor despite evidence of the defendant's low IQ and organic brain syndrome. The court affirmed the convictions and sentences, holding that the trial judge properly excused the juror after determining her beliefs would substantially impair her ability to follow the law and that conflicting evidence on adaptive functioning supported the jury's findings.

criminal lawprocedurecivil rights

The case concerned the constitutionality of N.C.G.S. § 62-158, which permits the North Carolina Utilities Commission to require natural gas local distribution companies to establish expansion funds financed in part by supplier refunds, in order to extend service to unserved areas of the state. The Commission had ordered Public Service Company of North Carolina to create such a fund and to deposit certain supplier refunds into it. Carolina Utility Customers Association challenged the order, arguing that the Commission misinterpreted the statute's grant of discretion and that the statute itself was unconstitutional on multiple grounds. The court held that the statute is constitutional and that the Commission properly exercised its authority under the statute to establish and fund the expansion fund using the refunds.

business & regulatory

The case involved defendants Alexander and Cunningham, who were indicted and tried for the first-degree murder of Darrin Burch, the assault with a deadly weapon with intent to kill inflicting serious injury on Corey Hill, and discharging a firearm into an occupied vehicle. A jury convicted both of first-degree murder on a felony-murder theory, the assault charges, and the firearm discharge offense, resulting in life sentences for the murders plus additional prison terms for the assaults. The court held that the evidence was sufficient to support the convictions, including proof of intent to kill and serious injury, and found no prejudicial error at trial. It affirmed the convictions but remanded for amendment of the judgment sheets because the underlying felony of discharging a firearm into occupied property merges into the felony-murder conviction, requiring arrest of judgment on that count.

criminal lawguns

In State v. Carson, the defendant was indicted and tried for first-degree murder, assault with a deadly weapon with intent to kill inflicting serious injury, and discharging a firearm into an occupied vehicle after shooting into a truck during a drug-related altercation, resulting in one death and one injury. The jury convicted him of first-degree murder under the felony murder rule based on the shooting, along with the assault charge. On appeal, the defendant argued that the evidence was insufficient to show he personally inflicted the fatal wound and that the transferred intent jury instruction was improper. The court affirmed the convictions, holding that the evidence permitted a reasonable inference that the defendant's .38-caliber shots caused the death and finding no error in the jury instruction under prior precedent.

criminal lawguns

The case involved Phillip Lee Ingle, who was convicted in Cleveland County of two counts of first-degree murder for beating an elderly couple, William and Margaret Davis, to death with an axe handle in their Rutherford County home in 1991 after entering through an unlocked door and stealing items from the residence. The jury found the defendant guilty based on malice, premeditation, and deliberation, and recommended the death penalty, which the trial court imposed. On direct appeal, the North Carolina Supreme Court reviewed twenty-nine assignments of error and concluded that the defendant received a fair trial and sentencing proceeding free from prejudicial error. The court held that the convictions were supported by the evidence, including the defendant's confession and recovery of stolen items, and that the death sentences were not disproportionate when compared to similar cases, despite mitigating circumstances related to the defendant's troubled background.

criminal law

The case concerned charges of second-degree rape, second-degree sexual offense, and crime against nature against defendant Jonathan McNeil Horn, based on sexual acts with a nineteen-year-old mentally handicapped victim whose mental deficiency was an element of the offenses. Prior to trial, the superior court ordered the victim to submit to an independent psychological examination at the defendant's request. The North Carolina Supreme Court held that a trial judge has no authority, statutory or discretionary, to compel a victim to undergo such an examination even when the victim's mental status is an element of the charged crimes. The ruling relied on prior precedent establishing that ordering unwilling witnesses to submit to psychiatric evaluations constitutes an impermissible invasion of privacy that is not justified by potential benefits to the defense, and that any change in this rule should come from legislation rather than judicial order. The court vacated the examination order and remanded for further proceedings, noting alternatives available to safeguard the defendant's rights.

criminal lawprocedure

The case involved the 1993 first-degree murder conviction of Samuel Tyrone Mason for fatally shooting Fredrick Harris at a party in Durham, North Carolina, based primarily on eyewitness testimony from Terrell Royster, who later claimed the defendant threatened him before trial. Mason appealed, alleging ineffective assistance of counsel and trial errors including the admission of evidence about threats to the witness and alleged prosecutorial interference with witness interviews. The North Carolina Supreme Court reviewed these claims in detail, determined that no prejudicial errors occurred and that the defendant received a fair trial, and affirmed the conviction and life sentence.

criminal lawprocedure

This case involves defendant Dwight Lamont Robinson's appeal from a death sentence imposed after a resentencing hearing for his convictions of first-degree murder (based on premeditation and deliberation as well as felony murder), robbery with a dangerous weapon, and two counts of assault with a deadly weapon with intent to kill inflicting serious injury. The court addressed fifty-four assignments of error, primarily claims of racial discrimination in the prosecutor's use of peremptory jury strikes under Batson v. Kentucky, along with challenges to the proportionality of the death sentence. The court held that the prosecutor provided legitimate, race-neutral reasons for the strikes, that defendant failed to prove purposeful discrimination, and that the death sentence was not disproportionate when compared to similar cases, as the crimes involved multiple victims with no provocation or confession by the defendant. Accordingly, the court found the resentencing proceeding free of prejudicial error and affirmed the convictions and death sentence.

criminal lawcivil rights

In State v. Baker, the defendant was convicted of first-degree rape after breaking into a mobile home and assaulting the victim, with the first-degree element resting on proof that he inflicted serious personal injury. The Court of Appeals vacated the first-degree rape conviction for insufficient evidence of such injury and reduced it to second-degree rape. The North Carolina Supreme Court reversed that holding and reinstated the first-degree conviction, concluding that testimony about the victim's extended mental and emotional harm—depression, nightmares, insomnia, job loss, relocation, counseling, and inability to care for her child for nine months—provided sufficient evidence that the injuries persisted well beyond the immediate events of the crime. The court applied precedents requiring proof that the injury was not merely a res gestae result of any forcible rape and found the evidence met that standard when viewed in the light most favorable to the State.

criminal law

In this case, defendants Adams and Reid were jointly tried for first-degree murder and assault with a deadly weapon with intent to kill inflicting serious injury arising from a shooting at a nightclub following an argument. The jury convicted Adams of first-degree murder and Reid of the assault, and the trial court imposed corresponding sentences. On appeal, the defendants challenged the sufficiency of the evidence to support the convictions and certain jury instructions on self-defense and the first-aggressor theory. The North Carolina Supreme Court affirmed the convictions, holding that the evidence, viewed in the light most favorable to the State, was sufficient to support findings of guilt either directly or on an acting-in-concert theory, and that any errors in the self-defense instructions were harmless because the defendants were not entitled to such instructions and the first-degree murder verdict rendered related issues immaterial.

criminal law