State v. Medlin, ___ N.C. ___, 2022-NCSC-25 (Mar. 11, 2022)

In this Cabarrus County case involving a defendant convicted of obtaining property by false pretenses, the Supreme Court affirmed the decision of the Court of Appeals, 2021-NCCOA-313, which had concluded that the trial court did not abuse its discretion in imposing a special condition of probation under G.S. 15A-1343. Though not discussed in the Supreme Court’s opinion, the special condition at issue was that the defendant not have any contact with the victim—his mother-in-law, who also had legal custody of his three children. The defendant had argued that a probation condition forbidding all contact with his mother-in-law would conflict with the terms of his child custody order, which allowed limited visitation with his children each week. Highlighting the Court of Appeals’ observation that trial judges have substantial discretion in devising probation conditions, the Supreme Court affirmed the lower court’s conclusion that the condition was reasonably related to protection of the victim and the defendant’s rehabilitation.