Case Summaries: N.C. Court of Appeals (Feb. 19, 2025)

This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on February 19, 2025. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present. Court rejected defendant’s argument that “serious injury” requires medical attention beyond an examination. State v. Reaves, COA24-663, ___ N.C. App. ___ (Feb. 19, 2025). In this Durham County case, defendant appealed his convictions for assault with a deadly weapon inflicting serious injury, arguing error in denying his motion to dismiss because the victim’s injuries were not “serious” under G.S. 14-32(b). The Court of Appeals found no error. In 2022, defendant and the victim, defendant’s on-and-off girlfriend, rekindled their relationship and the victim moved into defendant’s apartment. Their relationship soured and defendant became abusive towards the victim, culminating in September 2022 when defendant punched and kicked the victim and hit her with a curtain rod and the butt of his handgun. The victim eventually escaped by jumping from the balcony and running to a nearby mail carrier for help. At the hospital, an examination documented bruising, swelling, and tenderness on the victim’s body. At trial, the State called law enforcement, EMS, and a nurse from the hospital to testify to the victim’s injuries, and admitted photographs of her injuries and hospital reports. On appeal, defendant argued that the State provided insufficient evidence of the severity of the victim’s injuries, pointing to State v. Brunson, 180 N.C. App. 188 (2006), and [...]