Case Summaries: N.C. Court of Appeals (Sept. 17, 2025) (September 22, 2025)
Joseph L. Hyde
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on September 17, 2025.
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September 22, 2025
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on September 17, 2025.
READ POST "Case Summaries: N.C. Court of Appeals (Sept. 17, 2025) (September 22, 2025)"September 16, 2025
This post summarizes published criminal law and related cases released by the Fourth Circuit Court of Appeals during August 2025. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here.
READ POST "Case Summaries: Fourth Circuit Court of Appeals (Aug. 2025) (September 16, 2025)"September 15, 2025
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.
READ POST "Devalle and the Good Moral Character Requirement for Law Enforcement Officers (September 15, 2025)"September 8, 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 […]
READ POST "Case Summaries: N.C. Court of Appeals (Sept. 3, 2025) (September 8, 2025)"August 27, 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.
READ POST "Case Summaries: N.C. Supreme Court (August 22, 2025) (August 27, 2025)"August 25, 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.
READ POST "Case Summaries: N.C. Court of Appeals (Aug. 20, 2025) (August 25, 2025)"August 19, 2025
This post summarizes published criminal law and related cases released by the Fourth Circuit Court of Appeals during July of 2025. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here.
READ POST "Case Summaries: Fourth Circuit Court of Appeals (July 2025) (August 19, 2025)"August 11, 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.
READ POST "Case Summaries: N.C. Court of Appeals (August 6, 2025) (August 11, 2025)"July 21, 2025
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on July 16, 2025.
READ POST "Case Summaries: N.C. Court of Appeals (July 16, 2025) (July 21, 2025)"July 15, 2025
This post summarizes published criminal law and related cases released by the Fourth Circuit Court of Appeals during June of 2025. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here.
READ POST "Case Summaries: Fourth Circuit Court of Appeals (June 2025) (July 15, 2025)"