Case Summaries – N.C. Court of Appeals (March 7, 2023)

This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on March 7, 2023. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present. Trial court did not err when denying motion to dismiss due to sufficient evidence in the record, despite possibility that victim was also involved in the management of defendant’s prostitution ring. State v. Norman, COA22-812, ___ N.C. App. ___ (March 7, 2023). In this Alamance County case, defendant appealed his convictions for human trafficking and sexual servitude regarding his ex-wife, arguing error in the denial of his motion to dismiss for insufficient evidence. The Court of Appeals found no error. From 2015 to 2018, defendant operated a prostitution ring in the Alamance County area, operating at truck stops and using websites such as backpage.com to solicit customers. Eight to twelve women were involved in defendant’s prostitution ring, and paid him for drugs and hotel rooms that he provided, which were to be used for liaisons with paying customers. One of the women involved in the prostitution ring was defendant’s ex-wife, who assisted him in doing whatever was needed to operate the prostitution ring. After several incidents with law enforcement, defendant was arrested and charged with several counts of human trafficking, sexual servitude, and promoting prostitution. Another prostitute that worked with defendant was also charged and reached a plea agreement after agreeing to testify for the state. Reviewing defendant’s appeal, [...]