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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.
  • 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. Ingram, 283 N.C. App. 85 (Apr. 19, 2022)

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Criminal Offenses > Motor Vehicle Offenses > Impaired Driving

In this Rowan County case, the defendant appealed after being convicted of impaired driving after a jury trial. The conviction stemmed from a 2017 incident in which the defendant was found unresponsive on a fallen moped in the middle of the road.  Field sobriety tests and a toxicology test indicated that the defendant was impaired. The trial court denied the defendant’s motion to dismiss and the defendant was convicted. On appeal, the defendant contended that the trial court erred by denying his motion to dismiss because there was insufficient evidence that he drove the moped. Though no witness testified to seeing the defendant driving the moped, the Court of Appeals concluded that there was sufficient circumstantial evidence that he did. He was found alone, wearing a helmet, lying on the double yellow line in the middle of the road and mounted on the seat of the fallen moped. The Court thus found no error.