State v. Leaks, 240 N.C. App. 573 (Apr. 21, 2015)

An indictment charging failing to notify the sheriff of a change in address was not defective. The indictment alleged, in relevant part, that the defendant “fail[ed] to register as a sex offender by failing to notify the Forsyth County Sheriff’s Office of his change of address.” The defendant argued that the indictment was defective because it failed to allege that he was required to provide “written notice” of a change of address. The court held: “we consider the manner of notice, in person or in writing, to be an evidentiary matter necessary to be proven at trial, but not required to be alleged in the indictment.”

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