School of Government
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Episode 47: Williams, Farook, and Lofton

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina appellate courts in August 2026. In State v. Williams, No. 21PA25 (N.C. Aug. 14, 2026), the North Carolina Supreme Court held that the occupant of a motor vehicle does not lose his protected status under the castle doctrine statute when he is forced out of the vehicle by the attack of an unlawful intruder. In State v. Farook, No. 457PA20-2 (N.C. Aug. 14, 2026), the North Carolina Supreme Court limited State v. Harbison to cases in which the defendant is wholly surprised by defense counsel's concession of guilt. And in State v. Lofton, COA25-58 (N.C. Ct. App. Aug. 5, 2026), the Court of Appeals concluded that a prosecutor has no authority to dismiss a charge after the jury returned a verdict of guilty and the charge resulted in a conviction.

Episode 46: Wilder, Sandi, and Simpson

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals in July 2026. In State v. Wilder, No. COA25-1153 (N.C. Ct. App. July 1, 2026), the Court of Appeals concluded the trial court did not err by denying the defendant’s request to proceed pro se. In State v. Sandi, No. COA25-430 (N.C. Ct. App. July 1, 2026), the Court of Appeals found sufficient evidence of restraint beyond that inherent in another felony to support a conviction for kidnapping). And in State v. Simpson, No. COA 24-1092 (N.C. Ct. App. July 15, 2026), the Court of Appeals held that simultaneous possession of multiple firearms constitutes one instance of carrying a concealed weapon.

Episode 45: Broadway, Fair, and Thompson

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on July 1, 2026. In State v. Broadway, No. COA25-1159 (N.C. Ct. App. July 1, 2026), the Court of Appeals held the defendant could not be sentenced for both assault inflicting serious bodily injury (ASBI) and assault with a deadly weapon with intent to kill inflicting serious injury (ADWIKISI) based on the same conduct. In State v. Fair, No. COA25-880 (N.C. Ct. App. July 1, 2026), the Court of Appeals found no plain error in the trial court’s guilty knowledge instruction. And in State v. Thompson, No. COA25-1017 (N.C. Ct. App. July 1, 2026), the Court of Appeals upheld the defendant’s convictions for obtaining property by false pretenses even absent evidence that the victim was a person within the state.

Episode 44: Wise, Havens, and Moore

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals in June 2026. In State v. Wise, No. COA25-683 (N.C. Ct. App. June 3, 2026), the Court of Appeals found no violation of the confrontation clause when the testifying expert reviewed and approved a toxicology report. In State v. Havens, No. COA25-592 (N.C. Ct. App. June 17, 2026), the Court of Appeals upheld the defendant’s convictions for secret peeping and sexual exploitation of a minor. And in State v. Moore, No. COA25-1049 (N.C. Ct. App. June 17, 2026), the Court of Appeals concluded the trial court did not err by admitting evidence of a separate instance of the defendant’s fleeing to elude arrest.

Episode 43: Phelps, Metcalf, and Tyson

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on June 3, 2026. In State v. Phelps, No. COA25-934 (N.C. Ct. App. June 3, 2026), the Court of Appeals ruled that simultaneous possession of multiple weapons constitutes a single instance of possession of a weapon of mass death and destruction. In State v. Metcalf, No. COA25-624 (N.C. Ct. App. June 3, 2026), the Court of Appeals found that repeated unanswered phone calls in violation of a DVPO constitutes felony stalking. And in State v. Tyson, No. COA25-604 (N.C. Ct. App. June 3, 2026), the Court of Appeals held that sexual exploitation of a minor by solicitation does not require that the material solicited actually exist.