State v. Holmes, ___ N.C. App. ___, 822 S.E.2d 708 (Dec. 18, 2018)

In this first-degree murder case, the trial court did not err by admitting letters detailing the defendant’s outstanding debts. The defendant argued that the letters were not relevant. At the time of the victim’s death, she was considering calling off her engagement to the defendant because of his financial problems, and the day before her death she sent him a text message telling him to move out of their home and that, notwithstanding his financial problems, she would continue to seek child support from him. Whether the defendant had a motive to murder the victim was a strongly contested issue in this case. The State alleged that the defendant was facing financial difficulties and that those difficulties created a motive to kill the victim. The letters indicated that the defendant faced financial hardships, both with consumer and child-support debt. This, coupled with evidence that the victim had threatened to remove the defendant from the home and expressed that she would continue to request child-support, made the existence of a financial motive to murder the victim more probable. The letters thus were relevant. The court continued, finding that the trial court did not abuse its discretion by finding that the probative value of the letters was not outweighed by danger of unfair prejudice under Rule 403.