Smith's Criminal Case Compendium
Table of Contents
Criminal Procedure
Indictment & Pleading Issues
Evidence
Arrest, Search, and Investigation
State v. Dove, ___ N.C. App. ___, 788 S.E.2d 198 (Jun. 21, 2016)
The evidence was insufficient to support a conviction for altering, stealing, or destroying criminal evidence under G.S. 14-221.1. The charges were based on the defendant’s alleged theft of money obtained from the controlled sale of illegal drugs. The money in question was not evidence as defined by the statute: “any article or document in the possession of a law-enforcement officer or officer of the General Court of Justice.”