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Episode 38: Butler, Smathers, and Sloan

SOG Applications Team May 28, 2026 1


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Turning State's
Turning State's
Episode 38: Butler, Smathers, and Sloan
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In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on March 18, 2026. In State v. Butler, No. COA25-9 (N.C. Ct. App. March 18, 2026), the Court of Appeals found insufficient evidence of serious bodily injury to support a conviction for assault inflicting serious bodily injury. In State v. Smathers, No. COA25-357 (N.C. Ct. App. March 18, 2026), the Court of Appeals upheld the statutory requirement that convicted sex offenders report their online identifiers against a First Amendment challenge. And in State v. Sloan, No. COA25-128 (N.C. Ct. App. March 18, 2026), the Court of Appeals concluded the trial court did not err by excluding the defendant’s evidence of certain text messages offered to show a witness’s purported bias.

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