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  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

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State v. Arrington, 226 N.C. App. 311 (Apr. 2, 2013)

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Criminal Procedure > Sex Offenders > Reportable Convictions > Child Abduction

The trial court properly required the defendant to enroll in lifetime SBM. When deciding whether a conviction counts as a reportable conviction as an “offense against a minor”, the trial court is not restricted to considering the elements of the offense; the trial court may make a determination as to whether or not the defendant was a parent of the abducted child. The defendant had a 2009 conviction for abduction of a child. Although the State did not present any independent evidence at the SBM hearing that the defendant was not the child’s parent, the trial court previously made this determination at the 2009 sentencing hearing when it found the conviction to be a reportable offense. This prior finding supported the trial court’s determination at the SBM hearing that the defendant’s conviction for abduction of a child was a reportable conviction as an offense against a minor.