NC Criminal Law

Phil Dixon on Tuesday, September 15th, 2026

This post summarizes criminal law and related cases released by the Fourth Circuit Court of Appeals during August of 2026. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit are available here.

Where video footage contradicted material allegations of the...

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If evidence is excluded by the trial court, the proponent of the evidence generally must provide an adequate offer of proof regarding the nature of the excluded evidence in order to argue on appeal that the evidence should have been allowed. See G.S. 8C-103(a)(2).

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.

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 is proper in the entire district of the alleged offense, not just the particular county where the offense allegedly occurred. See G.S. 15A-131(b). Probable cause hearings are an exception and must be held in the county where the offense occurred. See G.S. 15a-131(c).

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).