Case Summaries: N.C. Supreme Court (Dec. 13, 2024)

This post summarizes the published criminal opinions from the Supreme Court of North Carolina released on December 13, 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. Defendant’s actions waived statutory right to court-ordered competency evaluation under G.S. 15A-1002. State v. Wilkins, 44A23, ___ N.C. ___ (Dec. 13, 2024). In this Caswell County case, the Supreme Court majority affirmed the Court of Appeals decision that defendant’s convictions were valid even though he never received the competency evaluation ordered by the trial court under G.S. 15A-1002. The Court concluded that defendant waived his statutory right to the competency hearing. Defendant was arrested in 2018 for a scheme that involved cutting open footballs and filling them with drugs, then throwing the footballs over the wall to a prison yard. While defendant was in the Caswell County Jail awaiting trial, he was involved in assaulting a detention officer and was charged with assaulting a government employee and communicating threats. Defense counsel filed a motion questioning defendant’s competency for trial, and the trial court granted the request to have a competency evaluation. However, after the order was entered, defendant posted bond and was released. Throughout the trial proceedings, the competency evaluation was not raised again. After defendant was convicted, he raised the competency evaluation issue at the Court of Appeals, where the majority held that under State v. Young, 291 N.C. 562 (1977), defendant waived his statutory right to the [...]