State v. Campbell, 368 N.C. 83 (Jun. 11, 2015)

Reversing the decision below, State v. Campbell, 234 N.C. App. 551 (2014), the court held that a larceny indictment was not fatally flawed even though it failed to specifically allege that a church, the co-owner of the property at issue, was an entity capable of owning property. The indictment named the victim as Manna Baptist Church. The court held: “[A]lleging ownership of property in an entity identified as a church or other place of religious worship, like identifying an entity as a ‘company’ or ‘incorporated,’ signifies an entity capable of owning property, and the line of cases from the Court of Appeals that has held otherwise is overruled.”