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.
North Carolina Court of Appeals
State v. Watlington: Court Clarifies Unit of Prosecution for Hit and Run
Author’s Note: The Court of Appeals withdrew the decision on which this post is based on April 7, 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 leaving the scene of a crash, not the number of people injured. Read on for further details.
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 Summaries: N.C. Court of Appeals (Jan. 15, 2025)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on January 15, 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 (Dec. 31, 2024)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on December 31, 2024. 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 (Dec. 17, 2024)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on December 17, 2024. 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 (Dec. 3, 2024)
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on December 3, 2024. These summaries will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present.