State v. Vann, ___ N.C. App. ___, 821 S.E.2d 282 (Oct. 2, 2018)

In this assault case, the trial court did not abuse its discretion by allowing portions of the defendant’s telephone call, made from jail, to his grandmother into evidence but refusing to allow the defendant to offer other portions from the same call into evidence. The defendant argued that the trial court’s ruling violated the rule of completeness. The admitted portions of the telephone conversation show that the defendant had certain knowledge of the crime that only the perpetrator would know. The defendant sought to introduce an additional portion of the conversation in which the defendant’s grandmother said, “you didn’t do it,” and the defendant responded, “I know.” The court concluded that the defendant’s exculpatory statement to his grandmother was neither explanatory of nor relevant to the admitted statements.

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