State v. Anthony, ___ N.C. App. ___, 831 S.E.2d 905 (Aug. 20, 2019)

review granted, ___ N.C. ___, 835 S.E.2d 448 (Aug. 30, 2019)

The court reversed the trial court’s order requiring the defendant to submit to lifetime satellite-based monitoring (SBM) on the basis that it ordered an unreasonable search. Though the State mentioned statistics and studies related to the risk of recidivism posed by sex offenders in its argument, it did not present those studies to the trial court, and they were not subject to judicial notice under Rule 201. In addition, the State presented no evidence on the efficacy of SBM to reduce recidivism.