Smith's Criminal Case Compendium
Table of Contents
State v. Williams, 252 N.C. App. 267 (Mar. 7, 2017)
The trial court properly applied the doctrine of collateral estoppel when it denied the defendant’s second motion to suppress. The defendant was in possession of a bag containing two separate Schedule I substances, Methylone and 4-Methylethcathinone. He was charged with possession with intent to manufacture, sell or deliver Methylone (Charge 1) and with possession with intent to manufacture, sell or deliver Methylethcathinone (Charge 2). Before trial he filed a motion to suppress, which was denied. He was convicted on both counts. On appeal, the court affirmed his conviction on the first charge but vacated the second because of a defective indictment. The State then re-indicted on the second charge. The then defendant filed a motion to suppress that was functionally identical to the motion to suppress filed before his first trial. The trial court denied the second motion based on the doctrine of collateral estoppel. The defendant was tried and found guilty. The trial court properly applied the doctrine of collateral estoppel when it denied the defendant’s second motion where the parties and the issues raised by the motions were the same; the issues were raised and fully litigated during the hearing on the first motion; the issue was material and relevant to the disposition of the prior action; and the trial court’s determination was necessary and essential to the final judgment.