Smith's Criminal Case Compendium
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State v. Madures, 197 N.C. App. 682 (Jul. 7, 2009)
In a trial for assault on a law enforcement officer and resisting and obstructing, the trial court properly admitted evidence relating to the defendant’s earlier domestic disturbance arrest. The same officer involved in the present offenses handled the earlier arrest, and at the time had told the defendant’s mother to call him if there were additional problems. It was the defendant’s mother’s call that brought the officers to the residence on the date in question. Thus, the fact of the earlier arrest helped to provide a complete picture of the events for the jury. The court also held that the trial court did not abuse its discretion in admitting the defendant’s statement to the police after his arrest while he was being transported to the jail. The court found that the defendant’s argumentative statements showed both his intent to assault or resist officers as well as absence of mistake.