This post summarizes published criminal law and related cases released by the Fourth Circuit Court of Appeals during March 2025. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here.
Case Summaries
Case Summaries: N.C. Court of Appeals (April 2, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on April 2, 2025. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present.
State v. Watlington: Court Clarifies Unit of Prosecution for Hit and Run
Author’s Note: This post has been modified from its original based on the reissuance of the opinion on April 16, 2025.
Earlier last month, the Court of Appeals decided State v. Watlington, COA23-1106, ___ N.C. App. ___ (2025). Among other issues, in its decision the Court addressed an open question: what is the unit of prosecution for a hit and run? May the defendant be charged once for leaving the scene of a crash that causes injury, or instead may a separate charge be issued for each person injured? (Shea Denning wrote about that issue and the framework for analysis in 2014, noting then that the question had not been directly addressed by our appellate courts). We now have an answer: the unit of prosecution is the number of crashes from which the defendant fled, not the number of people injured. Read on for further details.
Case Summaries: N.C. Supreme Court (Mar. 21, 2025)
This post summarizes the published criminal opinions from the Supreme Court of North Carolina released on March 21, 2025. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present.
Case Summaries: N.C. Court of Appeals (March 19, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on March 19, 2025. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present.
Case Summaries: N.C. Court of Appeals (March 5, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on March 5, 2025. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present.
Case Summaries: N.C. Court of Appeals (Feb. 19, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on February 19, 2025. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present.
Case Summaries: N.C. Court of Appeals (Feb. 5, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on February 5, 2025. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present.
Case Summary: U.S. Supreme Court (Jan. 21, 2025)
This post summarizes a criminal law decision published by the U.S. Supreme Court on Jan. 21, 2025.