Smith's Criminal Case Compendium

Smith's Criminal Case Compendium

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This compendium includes significant criminal cases by the U.S. Supreme Court & N.C. appellate courts, Nov. 2008 – Present. Selected 4th Circuit cases also are included.

Jessica Smith prepared case summaries Nov. 2008-June 4, 2019; later summaries are prepared by other School staff.

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E.g., 10/18/2021
E.g., 10/18/2021

Although statements made by a law enforcement officer during a videotaped interrogation of the defendant were not relevant, the defendant failed to show prejudice warranting a new trial. The court distinguished cases holding that statements by a law enforcement officer during a videotaped interrogation of the defendant are relevant to provide context for the defendant’s answers, noting, among other things, that in this case the defendant never made any concessions or admissions during the interrogation; instead, he repeatedly denied involvement in the crime. For the same reason, the officer’s statements were not relevant to show his interrogation techniques. Finally, because the defendant never wavered from his denials, the officer’s statements were not relevant to show that the defendant conceded the truth or changed his story.

The trial court did not commit plain error by failing to redact portions of a transcript of the defendant’s interrogation where the challenged statements were relevant. The court rejected the defendant’s argument that the trial court should have redacted statements made by the detective, finding that they provided context for the defendant’s responses. The court also rejected the defendant’s argument that the detective’s statements during the interrogation that the defendant was lying constituted improper opinion testimony on the defendant’s credibility and that of the State’s witnesses. 

Evidence of events leading up to the assault in question was relevant to complete the story of the crime.

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