What's the Statute of Limitations for a Felony in NC?

An experienced attorney from another state recently remarked on her surprise at learning that there was no statute of limitations barring the prosecution of felony offenses in North Carolina after the passage of a specified period of time. This attorney’s comment reminded me that while the no-statute-of-limitations-state-of-affairs may be well-known among experienced practitioners of criminal law in NC, it isn’t necessarily known by others.  The rule is simple. While G.S. 15-1 requires that misdemeanors (other than malicious misdemeanors, whatever those are) be charged within two years of their commission, there is no corresponding statute of limitations for felonies. See State v. Johnson, 275 N.C. 264, 271 (1969) (“In this State no statute of limitations bars the prosecution of a felony. . . . The constitutional guarantee of a speedy trial, therefore, imposes the only limitation upon purposeful and oppressive delays between the date of a felonious offense and the commencement of the prosecution.). That means there is no statutory time bar to charging any felony, whether it be a charge for writing a worthless check of more than $2,000 or first degree murder. Prosecutions do occur decades after felonious acts. Just last month, the court of appeals upheld a defendant’s convictions for taking indecent liberties with a child and felony child abuse based on sexual conduct he inflicted on his daughter between 1990 and 1993, more than 25 years before he was charged with those crimes. See State v. Alonzo, ___ N.C. App. ___ (Aug. 21, 2018). Upon reaching the age of [...]