State v. Jackson, 235 N.C. App. 384 (Aug. 5, 2014)

In a first-degree murder trial, the trial court did not err by admitting a jail letter that the defendant wrote to an accomplice in “Crip” gang code. In the letter, the defendant asked the accomplice to kill a third accomplice because he was talking to police. Rejecting the defendant’s argument that the evidence should have been excluded under Rule 403, the court determined that the fact that the defendant solicited the murder of a State’s witness was highly relevant and that the defendant’s gang membership was necessary to understand the context and relevance of the letter, which had to be translated by an accomplice. Additionally, the trial court repeatedly instructed the jury that they were only to consider the gang evidence as an explanation for the note.