Editor's note: Jessie has prepared a series of posts about the law of relevancy. They'll run as an intermittent series over the next several weeks. In this and upcoming posts, I will explore several relevancy issues that arise with some frequency. Perhaps the most litigated relevancy issue in North Carolina criminal cases is the admissibility of evidence regarding guilt of another. The law is clear that to be relevant, evidence of the guilt of another must: (1) point directly to the guilt of another party and (2) be inconsistent with the defendant’s guilt. By contrast, evidence that creates only an inference or conjecture as to another's guilt is irrelevant. There are a fair number of cases on this issue, and they come out both ways. Cases holding that guilt of another evidence is inadmissible under the standard set out above include: State v. Williams, 355 N.C. 501 (2002) (evidence attempting to implicate others in murders); State v. May, 354 N.C. 172 (2001) (evidence showing that another person had an argument with the victim days before the murder, was committed because he was hearing voices telling him to kill, told his doctor that he had hallucinations telling him to kill, and had a history of violent conduct; even if the evidence showed that the other person committed the crime, it was not inconsistent with the defendant’s guilt where the evidence put both the defendant and that person at the scene); State v. Hamilton, 351 N.C. 14 (1999) (evidence of a prior knife [...]
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