This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on June 18, 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
Case Summaries: N.C. Court of Appeals (June 4, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on June 4, 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.
State v. Chambers and the Substitution and Discharging of Alternate Jurors Pursuant to G.S. 15A-1215(a)
Criminal law practitioners may recall that in 2021 the General Assembly amended G.S. 15A-1215(a) to permit the substitution of an alternate juror after deliberations have begun in a criminal trial. S.L. 2021-94. When those changes became effective for jurors selected on or after October 1, 2021, North Carolina joined the federal courts and several other states that permit this practice.
The practice was, however, challenged within a few years of enactment. And the North Carolina Court of Appeals in State v. Chambers, 292 N.C. App. 459 (2024), held that notwithstanding G.S. 15A-1215(a), the state constitutional requirement for unanimous verdict of twelve jurors in a criminal case prohibited the substitution of an alternate juror after deliberations begin. Two weeks ago, the North Carolina Supreme Court reversed the Court of Appeals, upholding the statute as constitutional. This post will review the Supreme Court’s decision in State v. Chambers, No. 56PA24, ___ N.C. ___ (2025), and consider how trial courts must handle alternate jurors in future trials.
Case Summaries: N.C. Supreme Court (May 23, 2025)
This post summarizes the published criminal opinions from the North Carolina Supreme Court released on May 23, 2025.
Case Summaries: N.C. Court of Appeals (May 21, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on May 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 (May 7, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on May 7, 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 (April 16, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on April 16, 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.