Smith's Criminal Case Compendium
Smith's Criminal Case Compendium
Table of Contents
Smith's Criminal Case Compendium
About
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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(1) In this sexual assault case, the trial court did not err by excluding the defendant’s evidence that the victim had previously been sexually active that her parents punished her for this activity. The defendant did not argue that the victim’s past sexual activity was admissible under one of the four exceptions to the Rape Shield statute. Rather, he argued that her past sexual activity and parental punishment for it was relevant to show that she had a motive to fabricate accusations against him. Here, the evidence showed that the victim had not engaged in sexual activity for several months prior to the incident at issue. The victim’s parents knew that she had been sexually active for several years prior to the incident and the victim testified that she was not worried about being punished for engaging in sexual conduct. No evidence tied her past sexual activity or parental punishment to the incident in question. Additionally, unlike other cases where evidence of sexual activity was deemed admissible, this case did not turn primarily on the victim’s testimony. Here, there was other “compelling physical evidence submitted by the State” including, among other things, DNA evidence and GPS records. (2) The trial court did not violate the defendant’s constitutional right to present a defense by excluding irrelevant evidence.
The trial court committed plain error during the habitual felon phase of a trial by admitting into evidence plea transcripts for the defendant’s prior felony convictions without redacting irrelevant information pertaining to the defendant's prior drug use, mental health counseling, and lenient sentencing. However, no prejudicial error occurred. The court expressly declined to determine whether admission of the transcripts violated G.S. 15A-1025.
Admission of the defendant’s statements did not violate Evidence Rule 410 where it did not appear that the defendant thought that he was negotiating a plea with the prosecuting attorney or with the prosecutor’s express authority when he made the statements at a court hearing. Instead, the statements were made in the course of the defendant’s various requests to the trial court.
G.S. 15A-1025 (the fact that the defendant or counsel and the prosecutor engaged in plea discussions or made a plea arrangement may not be received in evidence) was violated when the prosecutor asked the defendant whether he was charged with misdemeanor larceny as a result of a plea bargain.