State v. Phillips, 365 N.C. 103 (Jun. 16, 2011)

In a multiple homicide case in which the defendant also was charged with kidnapping a victim who was a minor, there was sufficient circumstantial evidence that the minor’s parents did not consent to her kidnapping. Because the victim’s parents did not testify, there was no direct evidence of lack of parental consent. However, the State presented evidence that, having shot and repeatedly stabbed the victim while she was at the murder scene, the defendant and his accomplices found her after she crawled outside and removed her from the yard for the stated purpose of killing her while she was incapable of escaping. They loaded her into the bed of the defendant’s truck and drove to a trash pile, only to abandon her there when they heard sirens.