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.

Instructions

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E.g., 11/27/2021
E.g., 11/27/2021

In 1992, the defendant pled guilty to second-degree murder for the killing of a gas station attendant during a robbery. In 2016, after learning that an informant implicated another person in the crime, the defendant filed a motion to test the DNA and fingerprints on evidence found at the scene. The trial court denied the motion and the defendant appealed. The Court of Appeals affirmed. As a threshold matter the court said that the defendant was not barred from seeking testing under G.S. 15A-269 because he pled guilty. It rejected the State’s argument that the statute’s reference to the defendant’s “defense” and the requirement for a “verdict” meant that the law only applied to defendants found guilty after a trial. On the merits, though, the court concluded that the defendant failed to meet his burden of showing that the results of the requested testing would be material to his defense. With the “high bar” required to establish materiality after a guilty plea, even the presence of another’s DNA on the evidence would not necessarily exclude the defendant’s involvement in the crime in light of the substantial evidence of his guilt. A judge concurring in the result would have concluded that the Supreme Court’s decision in State v. Sayre, 255 N.C. App. 215 (2017), aff’d per curiam, 371 N.C. 468 (2018), bars a defendant who pled guilty from post-conviction DNA testing under G.S. 15A-269.

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