Episode 11: Lester, Boyd, and Spry

School of Government Podcasts

Episode 11: Lester, Boyd, and Spry

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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 State v. Boyd, COA24-36, the Court of Appeals remanded for the trial court to make additional findings and conclusions on the defendant’s speedy trial challenge. And in State v. Spry, COA24-129, the Court of Appeals held the trial court erred by summarily denying the defendant’s motion for appropriate relief, concluding that extended post-release supervision was a direct consequence of a guilty plea, and the defendant was entitled to be advised of it before pleading guilty.