State v. Williams, 220 N.C. App. 130 (2012)

In a first-degree murder case, the defendant was not entitled to a hearing regarding the admissibility of his juvenile records under G.S. 7B-3000(f) before the State could cross-examine a witness about whether she knew of the defendant’s prior juvenile adjudications. The testimony of defendant’s mother that defendant was not a violent person opened the door to cross-examination about his prior crimes under Rule 404(a)(1). Defendant argued that because his prior crimes were juvenile adjudications, the trial court was required to hold an in camera hearing to determine the admissibility of his juvenile records. The Court of Appeals held that G.S. 7B-3000(f) was inapplicable because it concerns the use of juvenile court “records,” and the State did not seek to introduce any portion of the defendant’s juvenile record. The State’s questions on cross-examination inquired only of defendant’s mother’s knowledge of his prior adjudications. Further, G.S. 7B-3000(f) mentions the use of juvenile records under Rule 404(b), and not Rule 404(a)(1).