NC Criminal Law

Joseph L. Hyde on Monday, September 21st, 2026

This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on September 16, 2026.

Trial court did not err by finding a violation of conditions of probation based on Defendant’s admission to failure to pay; insufficient evidence supported the findings that Defendant committed new criminal offenses and failed to report as directed; trial court did not err by imposing a five-month...

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If the elements of the offense were committed in more than one county, each county in which an element of the crime was committed has concurrent venue. See G.S. 15A-132(a).

If a defendant pleads guilty to an H or I felony in district court, is placed on probation, and is subsequently charged with violating that probation, the superior court has jurisdiction to hear the violation. But with the consent of the state and the defendant, the district court may hear the violation. G.S. 7A-271(e).

The state must give notice to the defendant of any expert witnesses that the state reasonably expects to call as a witness at trial.

All criminal pleadings must name or otherwise identify the defendant. See G.S. 15A-924(a)(1).

Evidence of the victim’s character may be introduced in two circumstances: First, the defendant may introduce evidence of a “pertinent trait” of the victim’s character. G.S. 8C-404(a)(2). The most common example is evidence of the victim’s violent character, offered when the defendant is claiming self-defense. Second, in homicide cases, the state may offer evidence of the victim’s character trait for “peacefulness” to rebut a claim by the defense that the victim was the first aggressor.