Episode 7: Clark, Vaughn, and Garmon

School of Government Podcasts

Episode 7: Clark, Vaughn, and Garmon

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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 substitute analyst. In State v. Vaughn, COA23-297, the Court of Appeals held the State failed to lay a proper foundation for the admission of the defendant’s Intoxilyzer breath test result. And in State v. Garmon, COA23-544, the Court of Appeals remanded for resentencing where the trial court lacked jurisdiction over the habitual felon indictment