Smith's Criminal Case Compendium
Table of Contents
Evidence
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
State v. Beckelheimer, 366 N.C. 127, 726 S.E.2d 156 (Jun. 14, 2012)
In this child sexual abuse case, the court clarified that when analyzing Rule 404(b) and 403 rulings, it “conduct[s] distinct inquiries with different standards of review.” It stated:
When the trial court has made findings of fact and conclusions of law to support its 404(b) ruling . . . we look to whether the evidence supports the findings and whether the findings support the conclusions. We review de novo the legal conclusion that the evidence is, or is not, within the coverage of Rule 404(b). We then review the trial court’s Rule 403 determination for abuse of discretion.