Episode 41: Hague, Phillips, and Palmiter

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina appellate courts in May 2026. In State v. Hague, No. 225A24 (N.C. May 22, 2026), the Supreme Court concluded the trial court reversibly erred by excluding evidence of the victim’s prior convictions to show the defendant’s state of mind. In State v. Phillips, No. COA25-864 (N.C. Ct. App. May 6, 2026), the Court of Appeals found no confrontation clause violation in allowing a substitute analyst to testify to independent conclusions based on photographs. And in State v. Palmiter, No. COA25-338 (N.C. Ct. App. May 6, 2026), the Court of Appeals upheld the constitutionality of G.S. 14-318.5 making it a felony for a person providing care to or supervision of a child knowingly or wantonly to fail to report the disappearance of the child to law enforcement.