Smith's Criminal Case Compendium
Table of Contents
State v. Mangum, 242 N.C. App. 202 (Jul. 7, 2015)
In this case where the defendant was convicted of second-degree murder for killing her boyfriend, the trial court did not err by introducing 404(b) evidence pertaining to an incident between the defendant and another boyfriend, Walker, which occurred 14 months before the events in question. The court found strong similarities between the incidents, noting that both involved the defendant and her current boyfriend; the escalation of an argument that led to the use of force; the defendant’s further escalation of the argument; and the defendant’s deliberate decision to obtain a knife from the kitchen. Given these similarities, the court found that the Walker evidence was probative of the defendant’s motive, intent, and plan. Next, the court found that the prior incident was not too remote.