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  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

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State v. Collins, 234 N.C. App. 398 (Jun. 17, 2014)

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Post-Conviction Proceedings > DNA Testing & Related Matters > New or More Accurate Tests

The trial court properly denied the defendant’s pro se motion for post-conviction DNA testing where the defendant failed to adequately establish that newer and more accurate tests would identify the perpetrator or contradict prior test results. It reasoned:

Defendant’s mere allegations that “newer and more accurate testing” methods exist, “which would provide results that are significantly more accurate and probative of the identity of the perpetrator [o]r accomplice, or have a reasonable probability of . . . contradicting prior test results” are incomplete and conclusory. Even though he named a new method of DNA testing, he provided no information about how this method is different from and more accurate than the type of DNA testing used in this case. Without more specific detail from Defendant or some other evidence, the trial court could not adequately determine whether additional testing would be significantly more accurate and probative or have a reasonable probability of contradicting past test results.