Smith's Criminal Case Compendium
Table of Contents
Criminal Procedure
Indictment & Pleading Issues
Evidence
Arrest, Search, and Investigation
State v. Barnett, 368 N.C. 710 (Mar. 18, 2016)
On discretionary review of a unanimous decision of the Court of Appeals, 239 N.C. App. 101 (2015), the court reversed, holding that the evidence was sufficient to sustain the defendant’s conviction to failing to register as a sex offender. Following Crockett (summarized immediately above), the court noted that G.S. 14-208.7(a) applies solely to a sex offender’s initial registration whereas G.S. 14-208.9(a) applies to instances in which an individual previously required to register changes his address from the address. Here, the evidence showed that the defendant failed to notify the Sheriff of a change in address after his release from incarceration imposed after his initial registration.