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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The rules of evidence do not apply at sentencing. G.S. 8C-1101(b)(3).

The court may take judicial notice of adjudicative facts that are not subject to any reasonable dispute if the facts are common knowledge in the jurisdiction or can be easily determined by reference to reliable sources.

If the defendant does not introduce evidence, the defendant has the right to the first and last closing argument. 

A judge may accept an Alford plea, in which a defendant pleads guilty but does not admit committing the offense and protests his or her innocence, if the record strongly supports the defendant’s guilt and the defendant intelligently concludes that it is in his or her interest to enter such a plea. The consent of the prosecutor is not required. 

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