Sentencing Whiteboard: Active Sentences for Aggravated Level One DWI

Today’s post is a return to the Sentencing Whiteboard, this time to explain active sentences for aggravated level one DWI. As Shea and I have discussed in earlier posts (here, here, and here, among others), they are different from other DWI sentences. No parole. No good time. Not cut in half. The video explains why, and describes how typical aggravated level one sentences are administered by the county jails through the Statewide Misdemeanant Confinement Program. As you’ll see, sentences for this most serious level of misdemeanor impaired driving are in many cases longer than a felony habitual DWI. I hope you’ll take a look. 

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A Trip to DART Cherry

Last week, through a North Carolina Judicial College program, a group of judges, lawyers, and clerks visited DART Cherry, the state’s lone residential chemical dependency treatment facility for male probationers and parolees. It was an informative visit that, frankly, busted some myths about DART Cherry. Today’s post passes along some of what we learned.

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Special Sentencing Rules

Aside from a few notable exceptions (impaired driving, drug trafficking, and first-degree murder), most North Carolina crimes are sentenced under Structured Sentencing. Some crimes have additional sentencing wrinkles—a kind of Structured Sentencing plus—that kick in by statute. Today’s post is a noncomprehensive list of some of the most common offense-specific sentencing provisions.

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The “Evidence Necessary to Prove an Element” Limitation on Aggravating Factors

Under G.S. 15A-1340.16(d), “[e]vidence necessary to prove an element of the offense shall not be used to prove any factor in aggravation.” The general idea behind that rule is to prevent the defendant from getting extra punishment via an aggravating factor for something that is inherent in the crime of conviction. A similar prohibition existed under Fair Sentencing, so we have a relatively large body of case law that helps us understand the rule.

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Barlow Strikes Back

After Justice Reinvestment, all North Carolina felonies are predicate felonies for certain federal purposes. That was the Fourth Circuit’s recent conclusion in United States v. Barlow. The decision significantly rolls back the court’s 2011 ruling in United States v. Simmons, 649 F.3d 237 (4th Cir. 2011), which held that many low-level North Carolina offenses were … Read more