Turning State's

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 [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on March 19, 2025. In State v. Windseth, COA24-718, the Court of Appeals found that still images from an ATM surveillance video were properly authenticated as a business record. In State v. Fuller, [...]

In this episode, Hyde and Holbrook discuss two cases decided by the North Carolina Court of Appeals on March 5, 2025. In State v. Fearns, COA23-650, the Court of Appeals held that, when the defendant’s pretrial motion to dismiss was heard by one judge, who rendered a ruling from the bench [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on February 19, 2025. In State v. Nanes, COA24-487, the Court of Appeals upheld the constitutionality of G.S. 14-415.1, criminalizing possession of a firearm by a felon. In State v. Greenfield, COA23-597, the [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina appellate courts in January and February 2025. In State v. Lester, 293PA23-2, the North Carolina Supreme Court held the Confrontation Clause is not violated by the introduction of machine generated raw data, particularly call detail records. [...]

In this episode, Hyde and Holbrook discuss three cases about digital evidence decided by the North Carolina Court of Appeals on December 31, 2024, and January 15, 2025. In State v. Hicks, COA20-665-2, the Court of Appeals held the defendant was entitled to a new trial based on the erroneous [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on December 31, 2024. In State v. Wilson, COA23-1031, the Court of Appeals awarded the defendant a new trial where the trial court instructed the jury on the theory of kidnapping that was not alleged [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on December 17, 2024. In State v. Reel, COA23-711, the Court of Appeals rejected the defendant’s challenge to a warrantless search of his home based on exigent circumstances. In State v. Carwile, COA23-885, [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on December 3, 2024. In State v. Clark, COA23-1133, the Court of Appeals applied Smith v. Arizona, 602 U.S. 779 (2024), and concluded the trial court erred by admitting the testimony of a [...]

***Language Warning*** In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on November 19, 2024. In State v. Lancaster, COA24-152, the Court of Appeals found no error in the trial court’s holding the defendant in criminal contempt twice for swearing at the judge (the [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina appellate courts in October and November 2024. In State v. Burris, 198A23, the North Carolina Supreme Court affirmed an opinion of the North Carolina Court of Appeals that found no error in the denial of the [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on October 15, 2024. In State v. Ellison, COA24-30, the Court of Appeals upheld a search warrant despite the inclusion of photographs depicting the wrong address. In State v. Hunt, COA23-890, the Court [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on October 1, 2024, all of them involving issues of search and seizure. In State v. Jackson, COA23-637, the Court of Appeals concluded the defendant’s consent to search his car was not involuntary [...]

In this episode, Hyde and Holbrook discuss two cases decided by the North Carolina Court of Appeals on September 17, 2024. In State v. Evans, COA23-1160, the Court of Appeals addressed the defendant’s challenge to the State’s evidence of larceny by an employee, concluding there was sufficient evidence of an intent [...]

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on September 3, 2024. In State v. Little, COA23-410, the Court of Appeals held the odor and smell of marijuana alone provide probable cause for a search. In State v. Pierce, No COA23-348, the Court of Appeals [...]