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Episode 35: Gibbon, Toomer, and Julius

SOG Applications Team April 14, 2026 3


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Turning State's
Turning State's
Episode 35: Gibbon, Toomer, and Julius
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In this episode, Hyde and Holbrook discuss three cases decided by the North Caroline Court of Appeals on February 4, 2026. In State v. Gibbon, No. COA25-415 (N.C. Ct. App. Feb 4, 2026), the Court of Appeals found the prosecutor conducted the necessary investigation between presentment and indictment by reviewing the case file. In State v. Toomer, No. COA24-1102 (N.C. Ct. App. Feb 4, 2026), the Court of Appeals held the trial court erred by admitting evidence of the defendant’s prior convictions that were more than ten years old.  And in State v. Julius, No. COA25-277 (N.C. Ct. App. Feb. 4, 2026), the Court of Appeals upheld the trial court’s application of the good faith exception to the exclusionary rule under the Fourth Amendment.

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