Smith's Criminal Case Compendium
Table of Contents
Evidence
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
State v. Santillan, ___ N.C. App. ___, 815 S.E.2d 690 (May. 1, 2018)
In this case involving a defendant who was 15 years old at the time of his crimes, and as conceded by the State, the trial court failed to make sufficient findings to support two sentences of life without parole. On appeal the defendant argued that although the trial court listed each of the statutory mitigating factors under G.S. 15A-1340.19B(c), it failed to expressly state the evidence supporting or opposing those mitigating factors as required by relevant case law. The State conceded that this was error and the court remanded.