State v. Spinks, ___ N.C. App. ___, 808 S.E.2d 350 (Nov. 21, 2017)

Following precedent, the court rejected the defendant’s assertion that counsel rendered ineffective assistance by failing to assert a fourth amendment claim at the hearing where he was ordered to submit to satellite-based monitoring for life. SBM proceedings are civil and ineffective assistance of counsel claims only can be asserted in criminal matters.