Turning State's

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Appellate Courts in March and April 2026. In State v. Cole, No. COA24-563 (N.C. Ct. App. April 1, 2026), the Court of Appeals found no error in the trial court’s instructing the jury on the felony [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on March 18, 2026. In State v. Butler, No. COA25-9 (N.C. Ct. App. March 18, 2026), the Court of Appeals found insufficient evidence of serious bodily injury to support a conviction for assault [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on March 4, 2026. In State v. Barbour, COA24-664 (N.C. Ct. App. Mar. 4, 2026), the Court of Appeals held the State presented sufficient evidence contradicting the defendant’s castle doctrine defense to warrant [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on February 18, 2026. In State v. Cooke, No. COA25-527 (N.C. Ct. App. Feb. 18, 2026), the Court of Appeals vacated the judgment where the trial court proceeded without first determining that the [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Caroline Court of Appeals on February 4, 2026. In State v. Gibbon, No. COA25-415 (N.C. Ct. App. Feb 4, 2026), the Court of Appeals found the prosecutor conducted the necessary investigation between presentment and indictment by reviewing [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on January 7 and January 21 of 2026. In State v. Oakes, No. COA25-247 (N.C. Ct. App. Jan. 7, 2026), the Court of Appeals concluded that a voicemail was sufficiently authenticated by voice [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on January 7, 2026. In State v. White, No. COA25-470 (N.C. Ct. App. Jan. 7, 2026), the Court of Appeals found no error in the denial of the defendant’s motion to suppress when [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Supreme Court on December 12, 2025. In State v. Calderon, No. 238A23 (N.C. Dec. 12, 2025), the Supreme Court applied the distinct-interruption test and found sufficient evidence to support three separate convictions for indecent liberties with [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on December 3, 2025. In State v. Kleist, No. COA24-677 (N.C. Ct. App. Dec. 3, 2025), the Court of Appeals found insufficient evidence of aiding and abetting child sex crimes and felony child [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on November 5 and 19, 2025. In State v. Johnson, No. COA24-1126 (N.C. Ct. App. Nov. 5, 2025), the Court of Appeals found no error in the denial of the defendant’s request for [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on November 5, 2025. In State v. Barthel, No. COA25-159 (N.C. Ct. App. Nov. 5, 2025), the Court of Appeals vacated the defendant’s convictions arising from the display of a vulgar banner at [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Supreme Court on Oct. 17, 2025. In State v. Chemuti, No. 282PA24 (N.C. Oct. 17, 2025), the Supreme Court ruled that defendants cannot compel the production of body camera footage and other recordings in the custody [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on Oct. 1, 2025. In State v. Lamm, No. COA24-982 (N.C. Ct. App. Oct. 1, 2025), the Court of Appeals held that a prior acquittal did not collaterally estop the State from presenting [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on September 17, 2025. In State v. Chafen, No. COA24-1030 (N.C. Ct. App. Sept. 17, 2025), the Court of Appeals found no error when there was insufficient evidence to raise a bona fide [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on September 3, 2025. In State v. Powell, No. COA24-556 (N.C. Ct. App. Sept. 3, 2025), the Court of Appeals awarded the defendant a new trial when the trial court erred by failing [...]

In this episode, Hyde and Holbrook discuss three cases decided by North Carolina appellate courts on August 20 and 22, 2025. In State v. McCall, COA24-779 (N.C. Ct. App. Aug. 20, 2025), the Court of Appeals held that the State may use evidence of the defendant’s pre-arrest silence as substantive evidence [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on August 6, 2025. In State v. Jenkins, No. COA24-889 (N.C. Ct. App. Aug. 6, 2025), the Court of Appeals construed the some-other-provision-of-law clause of G.S. 14-34.10 to preclude sentencing a defendant on [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on July 2 and July 16, 2025. In State v. Upchurch, No. COA24-460 (N.C. Ct. App. July 2, 2025), the Court of Appeals found no error in the denial of the defendant’s motion [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on July 2, 2025. In State v. Gilbert, No. COA25-32 (N.C. Ct. App. July 2, 2025), the Court of Appeals held that it was improper for the prosecutor during closing argument to refer [...]

In this episode, Hyde and Holbrook discuss two cases decided by the North Carolina Court of Appeals on June 18, 2025. In State v. Tate, COA24-450 (N.C. Ct. App. June 18, 2025), the Court of Appeals rejected the defendant’s Confrontation Clause challenge to the trial court’s admission of DNA results absent an opportunity [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on June 4, 2025. In State v. Arrington, COA24-688 (N.C. Ct. App. June 4, 2025), the Court of Appeals found no impropriety when the prosecutor told the jury that a State’s witness was [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Appellate Courts in May 2025. In State v. Chambers, No. 56PA24 (N.C. May 23, 2025), the Supreme Court held that substitution of a juror after deliberations have begun (per G.S. 15A-1215(a)) does not violate a defendant’s [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals in May 2025. In State v. Meadows, COA24-149 (N.C. Ct. App. May 7, 2025), the Court of Appeals awarded a new trial where defense counsel impliedly admitted the defendant’s guilt to the jury [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on April 16, 2025. In State v. Peters, COA24-475, the Court of Appeals concluded that the trial court’s findings on the defendant’s motion to suppress did not resolve the question of whether the defendant [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Appellate Courts in March and April 2025. In State v. Fenner, 289PA23 (N.C. Mar. 21, 2025), the North Carolina Supreme Court held that the trial court complied with the colloquy required by G.S. 15A-1242 despite a [...]