State v. Miles, ___ N.C. App. ___, 833 S.E.2d 27 (Aug. 20, 2019)

An officer testified at trial, without objection by the defendant, that the modus operandi of the crime was to use a female in a car by herself to gain access to the home for the purpose of committing an armed robbery. He further testified that there had been similar incidents in the area around the same time. Rejecting the defendant’s argument that the testimony was an inadmissible lay witness opinion as to the defendant’s guilt, the court explained that a lay witness may testify about “details ‘helpful to the fact-finder in presenting a clear understanding of [the] investigative process’ as long as such details are rational to the lay witness’s perception and experience.” Moreover, given that the State presented substantial evidence supporting the charge of criminal conspiracy, the court of appeals concluded that the trial court did not commit plain error in admitting the testimony.