Episode 42: Dobson, Myers, and Holt

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina appellate courts in May 2026. In State v. Dobson, 190PA24 (N.C. May 22, 2026), the Supreme Court held that the odor of marijuana is a factor to be considered under the totality of the circumstances for probable cause. In State v. Myers, No. COA25-631 (N.C. Ct. App. May 20, 2026), the Court of Appeals concluded the superior court lacked jurisdiction to adjudicate two infractions. And in State v. Holt, No. COA25-560 (N.C. Ct. App. May 20, 2026), the Court of Appeals found a confrontation clause violation in a substitute analyst’s testimony on the defendant’s blood alcohol concentration.