Case Summaries: N.C. Court of Appeals (July 16, 2025)

This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on July 16, 2025. The law of the other state governs whether a juvenile adjudication from that state is a final conviction that requires registration in North Carolina. State v. Jackson, No. COA24-731 (N.C. Ct. App. July 16, 2025). [This summary was updated August 4, 2025, after the opinion was reissued.] The defendant was placed on Delaware’s sex offender registry in 2008, when he was 15 years old, based on a juvenile adjudication of delinquency for first-degree rape. When he moved to North Carolina in 2022, he was notified that he was required to register as a sex offender. He filed a Petition for Judicial Determination of Sex Offender Registration under G.S. 14-208.12B. He argued that the Delaware adjudication did not qualify as a reportable conviction, because he would not be required to register on the adult registry for a comparable North Carolina juvenile adjudication. The trial court disagreed. It found that the Delaware juvenile adjudication was substantially similar to first-degree statutory sexual offense in North Carolina and ordered registration on North Carolina's adult registry. The Court of Appeals affirmed the trial court’s order, holding that the defendant was required to register pursuant to G.S. 14-208.6(4)(b), which states that a person must register in North Carolina for a “final conviction in another state of an offense that requires registration under the sex offender registration statutes of that state.” The court read that statute to require application [...]