NC Criminal Law
This post summarizes criminal law and related cases released by the Fourth Circuit Court of Appeals during April of 2026. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit are available here.
Search of juvenile’s phone by school officials was reasonable; juvenile’s confession was voluntary
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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).
Misdemeanors may be charged in an indictment only if the charge is initiated by presentment or if the offense is joined with a charged felony. See G.S. 15A-923; G.S. 7A-271.
If the defendant does not introduce evidence, the defendant has the right to the first and last closing argument.
The state must give the defendant, at the beginning of jury selection, a written list of the names of all witnesses whom the state reasonably expects to call during the trial.
A defendant who is in custody has a Fifth Amendment right to counsel during an interrogation.