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

In a first-degree murder case, the court rejected the defendant’s argument that the trial court made an improper judicial comment on his dangerousness in violation G.S. 15A-1222 and -1232. The defendant had argued that the trial court’s decision to order additional security after his mid-trial escape attempt, including physical restraints and an escort for the jury, was akin to a statement that defendant was highly dangerous and probably guilty. The court rejected this argument, concluding that the trial court did not abuse its discretion or violate the defendant’s constitutional rights by ordering additional security measures after the defendant attempted to escape, causing a lockdown of the courthouse. The court also rejected the defendant’s argument that the trial court should have instructed the jury that they should not consider the fact that they had been escorted to their cars or the additional security personnel in the courtroom.