NC Criminal Law
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on March 18, 2026.
(1) Insufficient evidence of serious bodily injury where the assault victim was beaten unconscious and suffered multiple facial fractures but only spent one night in the hospital and only experienced pain for a day or two. (2) Ring doorbell video clips were sufficiently authenticated by the testimony of the camera’s owner.
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Two or more offenses may be joined for trial when the offenses are based on the same act or transaction or on a series of acts or transactions connected together or constituting parts of a single scheme or plan. See G.S. 15A-926(a).
An information is an accusation drafted by the prosecutor and filed in superior court, charging one or more criminal offenses. An information may be filed only if the defendant waives indictment.
A statement of charges, criminal summons, arrest warrant, citation or magistrate’s order may be amended at any time before or after final judgment as long as the amendment does not change the nature of the offense charged. G.S. 15A-922(f).
If evidence is excluded by the trial court, the proponent of the evidence generally must provide an adequate offer of proof regarding the nature of the excluded evidence in order to argue on appeal that the evidence should have been allowed. See G.S. 8C-103(a)(2).
In district court, jeopardy attaches once the court begins to hear evidence, which occurs when the first witness is sworn. In superior court, jeopardy attaches once the jury is sworn and impaneled.