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  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

Smith's Criminal Case Compendium

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State v. Grainger, 367 N.C. 696 (Dec. 19, 2014)

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Criminal Procedure > Jury Instructions > Specific Instructions > Homicide > Accessory Before the Fact to Murder

In this murder case, the trial court did not err by denying the defendant’s request for a jury instruction on accessory before the fact. Because the defendant was convicted of first-degree murder under theories of both premeditation and deliberation and the felony murder rule and the defendant’s conviction for first-degree murder under the theory of felony murder is supported by the evidence (including the defendant’s own statements to the police and thus not solely based on the uncorroborated testimony of the principal), the court of appeals erred by concluding that a new trial was required.