Smith's Criminal Case Compendium
Smith's Criminal Case Compendium
Table of Contents
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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In this Rowan County case, the Supreme Court majority affirmed the Court of Appeals decision upholding the exclusion of evidence offered by defendants to show other individuals committed the crimes for which defendants were convicted. Defendants were jointly tried and convicted of first-degree murder, attempted robbery with a dangerous weapon, and assault with a deadly weapon.
In May of 2016, defendants came to an apartment with the eventual murder victim, apparently searching for money owed by the woman to the defendants. The murder victim's mother and three-year-old son were also in the apartment. Defendants searched the bedroom, and after not finding the money, shot the woman in the head, killing her. The woman’s mother witnessed the events, and was at one point struck in the face by one of the defendants. The mother was able to identify defendants to the police and also testified identifying them at trial. During the trial, the State filed a motion in limine to exclude mention of the possible guilt of two other individuals that defendants argued were responsible for the crimes. Defendants’ evidence involved the identification of another woman who looked similar to one of the defendants, possessed a gun of the same caliber as the murder weapon, and drove a vehicle that matched a description from a confidential informant of a vehicle present at the scene. The trial court granted the motion in limine, ruling that the proffered evidence was not inconsistent with the guilt of the defendants. The trial court relied on the applicable test under State v. Cotton, 318 N.C. 663 (1987), where evidence implicating the guilt of others “‘must tend both to implicate another and be inconsistent with the guilt of the defendant.’” Slip Op. at 7.
The Supreme Court reviewed defendants’ appeal de novo, and noted that the parties agreed that the evidence in question was relevant, meaning the only consideration in front of the Court was whether the evidence was inconsistent with defendants’ guilt. The Court looked to State v. McNeill, 326 N.C. 712 (1990), for explanation of the relevant standard, emphasizing that the evidence must show another person actually committed the crimes instead of defendants, not just that another person had the opportunity to commit the crimes. Walking through the evidence, the Court concluded that “while defendants’ proffered evidence implicates other suspects which were suggested by defendants, such evidence does not exculpate defendants.” Slip Op. at 23. The Court explained that because the evidence did not tend to show the innocence of either defendant, it did not satisfy the applicable test and was inadmissible.
Justice Earls dissented by separate opinion and would have allowed the admission of the excluded evidence. Id. at 25.
The trial court did not err by joining for trial offenses that occurred on different dates. The first set of offenses occurred on May 15, 2015 and involved assaults and sexual assaults on B.A. The second set of charges arose from a breaking or entering that occurred approximately eight months later, when the defendant entered a neighbor’s home looking for B.A. The defendant argued that certain testimony offered by the neighbor was inadmissible character evidence as to the first set of charges but was essential testimony as to the second set of charges, to establish guilt of another. The court however found that the evidence would not have been admissible for that purpose; to be admissible, guilt of another evidence must do more than create mere conjecture of another’s guilt. Here, the evidence was mere speculation that another person committed the crime. Furthermore the testimony was not inconsistent with the defendant’s guilt.
Trial court did not err by excluding defense evidence of guilt of another where the evidence was “sheer conjecture” and was not inconsistent with the defendant’s guilt.
In a murder case, the trial court did not err by excluding evidence suggesting that the victim’s wife committed the crime. Distinguishing cases where alternate perpetrators were positively identified and both direct and circumstantial evidence demonstrated the third parties’ opportunity and means to murder, the defendant offered “merely conjecture” as to the wife’s possible actions. Additionally, the State contradicted these “speculations” with testimony by the couple’s daughters that they were with their mother on the night in question.