State v. McNeill, 243 N.C. App. 762 (Nov. 3, 2015)

The trial court did not err by failing to intervene sua sponte during the prosecutor’s closing argument. Here, the prosecutor argued facts in evidence regarding a prior assault by the defendant and the trial court gave an appropriate limiting instruction regarding the defendant’s prior conviction. Thus, the prosecutor’s reference to this incident and his comment suggesting that the defendant was a “cold person” were not so grossly improper that the trial court was required to intervene on its own motion.