Turning State's

Episode 26: Chafen, Thomas, and Creed

SOG Applications Team December 15, 2025 1


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School of Government Podcasts
School of Government Podcasts
Episode 26: Chafen, Thomas, and Creed
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In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on September 17, 2025. In State v. Chafen, No. COA24-1030 (N.C. Ct. App. Sept. 17, 2025), the Court of Appeals found no error when there was insufficient evidence to raise a bona fide doubt as to the defendant’s capacity. In State v. Thomas, No. COA24-770 (N.C. Ct. App. Sept. 17, 2025), the Court of Appeals concluded the trial court reversibly erred in its jury instructions on defense of habitation. And in State v. Creed, No. COA25-184 (N.C. Ct. App. Sept. 17, 2025), the Court of Appeals held the trial court erred by revoking probation when the evidence was insufficient to show that the defendant committed a new offense by communicating a true threat.

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