Turning State's

Episode 16: Peters, Watlington, and Bryant

SOG Applications Team June 12, 2025


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School of Government Podcasts
School of Government Podcasts
Episode 16: Peters, Watlington, and Bryant
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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 had consented to a search of her wallet, justifying remand for additional proceedings. In State v. Watlington, COA23-1106, the Court of Appeals held that the unit of prosecution for felony hit-and-run is the number of crashes and not the number of victims. And in State v. Bryant, COA24-436, the Court of Appeals ruled that the State’s evidence was sufficient to support the defendant’s conviction for possession of drug paraphernalia.

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