Turning State's

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.

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.

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina appellate courts in March and April 2026. In State v. Perry, No. 64PA24 (N.C. March 20, 2026), the Supreme Court found sufficient evidence to withstand a defendant’s motion to dismiss the charge of armed robbery. In State v. Friend, No. COA25-908 (N.C. Ct. App. April 15, 2026), the Court of Appeals found sufficient evidence to withstand a defendant’s motion to dismiss the charges of accessing a government computer to defraud and obtaining property by false pretenses. And in State v. Whitt, No. COA25-516 (N.C. Ct. App. April 1, 2026), the Court of Appeals found sufficient evidence that the defendant absconded to warrant revocation of his probation.

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 [...]