NC Criminal Law

Jeff Welty on Monday, March 23rd, 2026

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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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).

A prosecutor’s failure to sign an indictment does not invalidate the indictment. G.S. 15A-644(a)(4).

In felony cases, a defendant is entitled to inspect the complete files of all law enforcement agencies, investigatory agencies, and prosecutors' offices involved in the investigation of the crimes committed or the prosecution of the defendant. See G.S. 15A-903(a).

A defendant who is in custody has a Fifth Amendment right to counsel during an interrogation.

Whichever county is the first to bring charges against the defendant has exclusive venue. See G.S. 15A-132. But if the county with exclusive venue dismisses the charges, another county with concurrent venue may initiate its own charges and obtain venue.