This post summarizes the published criminal opinions from the Court of Appeals of North Carolina released on October 1, 2025.
Case Summaries
Case Summaries: N.C. Court of Appeals (Sept. 17, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on September 17, 2025.
Devalle and the Good Moral Character Requirement for Law Enforcement Officers
Law enforcement officers in North Carolina must have good moral character to be certified, and may lose their certification if they lose their good moral character. The requirement of good moral character is neither unique to North Carolina nor exclusive to law enforcement officers. At the same time, it is a difficult standard to apply, as illustrated by a recent decision issued by the Supreme Court of North Carolina. This post provides context for that decision and explores its reasoning.
Case Summaries: N.C. Court of Appeals (Sept. 3, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on September 3, 2025. In defendant’s trial for felonious possession of stolen goods, admission of police chief’s testimony about defendant’s record of charges for breaking and entering was not plain error. State v. Clark, No. COA25-13 (N.C. Ct. App. Sept. … Read more
Case Summaries: N.C. Supreme Court (August 22, 2025)
This post summarizes the published criminal opinions from the North Carolina Supreme Court released on August 22, 2025. Previously, summaries were added to Smith’s Criminal Case Compendium, but due to personnel changes and resource limitations, that resource is no longer available. We will continue to post and archive new summaries here on the blog.
Case Summaries: N.C. Court of Appeals (Aug. 20, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on August 20, 2025.
An indictment for injuring property to obtain non-ferrous metals was sufficient despite the lack of any allegation concerning the value of the property damage.
State v. Council, No. COA25-78 (N.C. Ct. App. Aug. 20, 2025) (Hampson). In this Durham County case, the defendant was suspected of stealing a catalytic converter from a truck. He was indicted for, and convicted of, felony larceny and felony injury to property to obtain non-ferrous metals. He appealed, asserting that the indictment for the injury to property charge was defective for failing to specify the value of the property damage.
Case Summaries: N.C. Court of Appeals (August 6, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on August 6, 2025.
The State presented sufficient evidence to establish that a hammer was used as a dangerous weapon to support conviction for robbery with a dangerous weapon.
State v. Blackburn, No. COA24-1016 (N.C. Ct. App. Aug. 6, 2025). The victim was sleeping in his Mazda as he did every night when he was awakened by banging on the outside of his car. Two men pulled the victim from the car and held a gun to his head. Three men threatened to shoot him if he didn’t hand over his money, and when the victim stated he didn’t have any money, the men pushed him against the car facing the vehicle, and one of the men hit the victim with a hammer. The defendant stated he hit the victim with a hammer on the back of the victim’s shoulder, while the victim testified that he was hit on the back of the head and neck, fell to the ground, and lost consciousness for a short period. When he came to, he saw the men driving away in the Mazda. The defendant was apprehended near the stolen vehicle later that night. The defendant was convicted of robbery with a dangerous weapon and conspiracy to commit robbery with a dangerous weapon after a jury trial.
Case Summaries: N.C. Court of Appeals (July 16, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on July 16, 2025.