Case Summaries: N.C. Court of Appeals (Dec. 31, 2024)

Published for NC Criminal Law on January 07, 2025.

This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on December 31, 2024. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present. [The following juvenile delinquency case touches on criminal matters, and a summary by Prof. Jacquelyn Greene is included below. This case and others related to juvenile justice are included in the Juvenile Justice Case Compendium.] In the matter of C.S., COA24-46, ___ N.C. App. ___ (Dec. 31, 2024). Held: Reversed Facts: The juvenile posted a screenshot of his school’s announcement of a three-day spirit week on Snapchat. The juvenile superimposed the following over the screenshot: “THIS IS SOME FUCKING BULLSHIT, IMMA SHOOT UP AL BROWN (for reason that I do not wish to have the police come to my house, it is a joke I do not nor have I ever owned a gun.) Thank you pls don’t report me[.]” Snapchat flagged the post as containing a threat of mass violence and the SBI connected the post to the juvenile. The juvenile explained that the post was a joke during his interview with the investigating officer. The juvenile was charged with communicating a threat to commit an act of mass violence on educational property (G.S. 14-277.6) and making a false report concerning mass violence on educational property (G.S. 14-277.5). The trial court denied a motion to dismiss both petitions for insufficient evidence and the youth was adjudicated delinquent on [...]