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., 12/13/2024
E.g., 12/13/2024

In this federal death penalty case, the court relied on Williams v. New York, 337 U.S. 241 (1949), to hold that the confrontation clause does not apply in the sentence selection phase (where the jury exercises discretion in selecting a life sentence or the death penalty) of a federal capital trial. The court noted that under the Federal Death Penalty Act, the jury finds the facts necessary to support the imposition of the death penalty in the guilt and eligibility phases of trial and that “[i]t is only during th[o]se phases that the jury makes ‘constitutionally significant’ factual findings.” The court’s holding pertained only to the sentence selection phase.

In a substitute analyst case, the court per curiam and for the reasons stated in Ortiz-Zape (above, under substitute analysts), reversed the Court of Appeals’ decision in State v. Hurt, 208 N.C. App. 1 (2010) (applying Crawford to a non-capital Blakely sentencing hearing in a murder case and holding that Melendez-Diaz prohibited the introduction of reports by non-testifying forensic analysts pertaining to DNA analysis). Reversing on other grounds, the court did not indicate that Crawford was inapplicable to a non-capital sentencing proceeding.

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