Smith's Criminal Case Compendium
Table of Contents
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
State v. Edgerton, 266 N.C.App. 521, 832 S.E.2d 249 (Aug. 6, 2019)
In this habitual larceny case where the defendant was sentenced as a habitual felon, the use of an ACIS printout to prove one of the defendant’s prior convictions during the habitual felon phase of trial was competent evidence that did not violate the best evidence rule. Citing State v. Waycaster, ___ N.C. App. ___, 818 S.E.2d 189 (2018), the court explained that G.S. 14-7.4 permits an original or certified copy of the court record of a prior conviction to be admitted into evidence to prove the prior conviction but does not mandate that manner of proof. The same case held that a certified copy of an ACIS printout is sufficient evidence of a prior conviction under the habitual felon statute.