Case Summaries: N.C. Supreme Court (Mar. 21, 2025)

This post summarizes the published criminal opinions from the Supreme Court of North Carolina released on March 21, 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 affirms case holding hydrocodone represented opiate for controlled substance conviction.  State v. Miller, 81A24, ___ N.C. ___ (Mar. 21, 2025). In this Henderson County case, the Supreme Court affirmed per curiam the Court of Appeals decision State v. Miller, 292 N.C. App. 519 (2024), where the majority held that hydrocodone, an opioid, qualified as an “opiate” for purposes of G.S. 90-95(h)(4) at the time of the offense, supporting defendant’s conviction. Defendant’s life without parole sentences complied with Miller v. Alabama. State v. Borlase, 33A24, ___ N.C. ___ (Mar. 21, 2025). In this Watauga County case, the Supreme Court majority affirmed the Court of Appeals decision finding no error with the imposition of two consecutive life sentences without parole for defendant’s first-degree murder convictions. In April of 2019, when defendant was a senior in high school and seventeen years old, he stabbed his mother and father to death with a large kitchen knife. Defendant then took steps to cover up the murder, washing away the blood inside their home and hiding the bodies under bags of mulch and leaves from the yard, and went to smoke marijuana with his friends. After defendant was convicted of two counts of first-degree murder, the sentencing court performed the analysis required by G.S. [...]