Smith's Criminal Case Compendium
Table of Contents
Evidence
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
State v. Dale, 245 N.C. App. 497 (Feb. 16, 2016)
A statement of charges, alleging that the defendant engaged in disorderly conduct in or near a public building or facility sufficiently charged the offense. Although the statute uses the term “rude or riotous noise,” the charging instrument alleged that the defendant did “curse and shout” at police officers in a jail lobby. The court found that the charging document was sufficient, concluding that “[t]here is no practical difference between ‘curse and shout’ and ‘rude or riotous noise.’”