State v. Calderon Refines Analysis of When Acts Support Multiple Counts of Indecent Liberties
Author's Note: The opinion discussed below was reversed by the North Carolina Supreme Court in State v. Calderon, No. 238A23 (N.C. Dec. 12, 2025) (discussed here). A recent court of appeals case, State v. Calderon, ___ N.C. App. ___ (2023), sets forth a new test for determining whether multiple acts of touching a child during a single encounter can support multiple counts of indecent liberties.