Variations on State v. Singleton: Surplus Theory in State v. Tate.

Published for NC Criminal Law on July 08, 2025.

After State v. Singleton, 386 N.C. 183 (2024), an indictment is not rendered facially invalid by failure to allege all the elements of a crime. One issue that remains unresolved is the consequence of failure to allege the State’s theory. Two post-Singleton cases decided last year found reversible error when the trial court instructed the ... Read more

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