NC Criminal Law

Jamie Markham on Monday, February 23rd, 2026

This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on February 18, 2026.

Competent evidence supported the factual findings in the trial court’s denial of a motion to suppress; a defendant who pleads guilty has no right to appeal the denial of a motion in limine.

State v. Alston, No. COA25-291 (N.C. Ct....

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A judge must accept a plea arrangement that involves only charges and no sentence recommendation, as long as the judge determines the plea is the product of an informed choice of the defendant and there is a factual basis for the plea. See G.S. 15A-1023(c).

An indigent defendant who has been formally charged has a right to counsel at a pretrial lineup or other identification procedure at which defendant’s presence is required.

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.

A prosecutor’s failure to sign an indictment does not invalidate the indictment. G.S. 15A-644(a)(4).

G.S. 15A-134 provides that if a charged offense occurred partly in North Carolina and partly in another state, a person charged with that offense may be tried in North Carolina only if he or she has not already been placed in jeopardy for the same offense by the other state.