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., 09/22/2021
E.g., 09/22/2021
State v. Young, 368 N.C. 188 (Aug. 21, 2015)

In this murder case the court held that the court of appeals erred by concluding that the trial court committed reversible error in allowing into evidence certain materials from civil actions. The relevant materials included a default judgment and complaint in a wrongful death suit stating that the defendant killed the victim and a child custody complaint that included statements that the defendant had killed his wife. The court of appeals had held that admission of this evidence violated G.S. 1-149 (“[n]o pleading can be used in a criminal prosecution against the party as proof of a fact admitted or alleged in it”) and Rule 403. The court held that the defendant did not preserve his challenge to the admission of the child custody complaint on any grounds. It further held that the defendant failed to preserve his G.S. 1-149 objection as to the wrongful death evidence and that his Rule 403 objection as to this evidence lacked merit. On the 403 issue as to the wrongful death evidence, the court rejected the court of appeals’ reasoning that substantial prejudice resulting from this evidence “irreparably diminished” defendant’s presumption of innocence and “vastly outweighed [its] probative value.” Instead, the court found that evidence concerning the defendant’s response to the wrongful death and declaratory judgment action had material probative value. Although the evidence posed a significant risk of unfair prejudice, the trial court “explicitly instructed the jury concerning the manner in which civil cases are heard and decided, the effect that a failure to respond has on the civil plaintiff’s ability to obtain the requested relief, and the fact that ‘[t]he entry of a civil judgment is not a determination of guilt by any court that the named defendant has committed any criminal offense.’”

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