State v. Ellison, 213 N.C. App. 300 (Jul. 19, 2011)

aff'd on other grounds, 366 N.C. 439

In a drug trafficking case, the trial court did not abuse its discretion by allowing the State’s witness to identify the substance as an opium derivative on rebuttal. Under G.S. 15A-1226, a trial judge may, in his or her discretion, permit a party to introduce additional evidence prior to the verdict and offer new evidence which could have been offered in the party’s case in chief or during a previous rebuttal as long as the opposing party is permitted further rebuttal.