NC Criminal Law
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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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.
Venue to try an accessory after the fact is proper in any county where the principal could be prosecuted or in the county where the defendant committed acts that form the basis of the charge of accessory after the fact.
Improper venue is waivable, while improper jurisdiction ordinarily is not.
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.
When a conviction or sentence imposed in superior court has been set aside on direct review or collateral attack, a judge may not impose a new sentence for the same offense, or for a different offense based on the same conduct, that is more severe. G.S. 15A-1335.