State v. Howard, 215 N.C. App. 318 (Sept. 6, 2011)

In an armed robbery prosecution, evidence of a break-in occurring hours after the incident in question was properly admitted under the “‘course of conduct’” or ‘complete story’ exception.” The evidence was necessary for the jury to understand how the defendant was identified as the perpetrator and how items stolen from the robbery victim and purchased with her credit card were recovered. The break-in evidence “was necessary for the jury to understand the complete story and timeline of the events that took place on the night in question, and therefore was properly admitted under the ‘course of conduct’ exception.” A footnote to the court’s opinion suggests that this basis for admission was separate from and independent of admissibility under Rule 404(b).