Case Summaries: N.C. Supreme Court (March 22, 2024)

This post summarizes the published criminal opinions from the Supreme Court of North Carolina released on March 22, 2024. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present. Supreme Court reversed holding in State v. Allen that review of MAR must be in the light most favorable to defendant; defendant could not demonstrate ineffective assistance of trial or appellate counsel. State v. Walker, 202PA22, ___ N.C. ___ (March 22, 2024). In this Wake County case, the Supreme Court affirmed an unpublished Court of Appeals opinion denying defendant’s motion for appropriate relief (MAR) based upon ineffective assistance of his trial and appellate counsel. The Court’s opinion reversed the holding in State v. Allen, 378 N.C. 286 (2021), that the factual allegations in a MAR must be reviewed in the light most favorable to the defendant. Defendant was convicted of first-degree murder in 1999 and sentenced to life without parole. Defendant appealed his conviction, but the Court of Appeals found no error. In April of 2020, defendant filed the MAR giving rise to the current case, arguing ineffective assistance of counsel from both trial counsel and appellate counsel. The Court of Appeals affirmed the trial court’s denial of the MAR but did not state that the standard of review was in the light most favorable to defendant as called for by Allen. After noting that Allen had created confusion for the Court of Appeals, the Supreme Court first clarified [...]