State v. Combs, 226 N.C. App. 87 (Mar. 19, 2013)

The court rejected the defendant’s argument that the trial court erred by failing to give additional jury instructions in open court and make them a part of the record as required by G.S. 15A-1234. Where, as here, the trial judge simply repeats or clarifies instructions previously given and does not add substantively to those instructions, the court’s instructions are not “additional instructions” within the meaning of the statute.