NC Criminal Law
This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on December 3, 2025.
Trial court did not err by admitting expert testimony on historical cell-site handoff analysis; Defendants failed to preserve an objection to an alleged discovery violation; and Defendants failed to show ineffective assistance of counsel in not objecting to the expert testimony.
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A misdemeanor statement of charges is a criminal pleading prepared by the prosecutor, charging a misdemeanor. A statement of charges is a type of pleading, but is not a form of process, and cannot be used to initiate a prosecution and compel the defendant to appear. See G.S. 15A-922(b)(1).
A prosecution in superior court must be by indictment, although a noncapital defendant may waive the right to an indictment and be tried on an information. See G.S. 15A-642; -943.
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).
Even if he does not testify, the defendant may offer evidence of a “pertinent trait” of his character. G.S. 8C-404(a)(1).
If the defendant (or any defendant in a multi-defendant case) puts on evidence, then state has the right to the first and last closing argument.