Smith's Criminal Case Compendium
Table of Contents
Criminal Procedure
Indictment & Pleading Issues
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
State v. Wilson-Angeles, ___ N.C. App. ___, 795 S.E.2d 657 (Feb. 7, 2017)
In this arson case, the trial court properly admitted 404(b) evidence to show the defendant’s intent. The evidence in question pertained to another arson which was sufficiently similar to the incident in question. Both arsons occurred in the same town during nighttime hours and involved the same building location. In both instances the defendant was intoxicated, knew the buildings were occupied, and was angry about a perceived harm perpetrated against her by an occupant of the residence. Although the other incident occurred approximately four years earlier, there was a sufficient temporal proximity to the conduct at issue.