State v. Adams

11 Citing cases

  1. State v. Sterling

    771 S.E.2d 633 (N.C. Ct. App. 2015)

    “In evaluating the admissibility of Rule 404(b) evidence, we start by determining whether there was substantial evidence presented by the State tending to support a reasonable finding by the jury that the defendant committed the other crimes, wrongs, or acts.” State v. Adams,220 N.C.App. 319, 322, 727 S.E.2d 577, 580 (2012). “Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”

  2. State v. Corbett

    863 S.E.2d 329 (N.C. Ct. App. 2021)

    The prosecution can present either direct or circumstantial evidence so long as it tends to support a reasonable inference that the same person committed both the earlier and later acts." State v. Adams , 220 N.C. App. 319, 323, 727 S.E.2d 577, 580 (2012). ¶ 21 Here, the trial transcript indicates that, during the trial court's hearing on the admissibility of the State's proffered Rule 404(b) evidence, Corbett's counsel argued that there was insufficient evidence to support the alleged prior assaults.

  3. State v. Young-Kirkpatrick

    846 S.E.2d 525 (N.C. Ct. App. 2020)   Cited 1 times

    In reviewing the admission of evidence of other crimes, wrongs, or acts of a criminal defendant, we engage in a "three-pronged analysis." State v. Adams , 220 N.C. App. 319, 323, 727 S.E.2d 577, 580-81 (2012). "[W]e first determine whether the evidence was offered for a proper purpose under Rule 404(b), then determine whether the evidence is relevant under Rule 401, and finally determine whether the trial court abused its discretion in balancing the probative value of the evidence under Rule 403."

  4. State v. Gary A.

    791 S.E.2d 392 (W. Va. 2016)

    See 1 Louis J. Palmer, Jr., Robin Jean Davis, & Franklin D. Cleckley, Handbook on Evidence for West Virginia Lawyers§ 404.04[2][c] (“Timing of the Rule 404(b) bad conduct evidence should be a question of relevancy and prejudice under Rules 401–403.”). See also Hart v. State , 2002 WY 163, 57 P.3d 348, 356 (2002) (“Remoteness in time renders the evidence inadmissible only if the remoteness is so great that the evidence has no value.”); State v. Adams , 220 N.C.App. 319, 328, 727 S.E.2d 577, 584 (2012) (“[T]he prior crime must not be so remote [in time] as to have lost its probative value.”) (internal quotations and citations omitted).

  5. State v. Gary A.

    791 S.E.2d 392 (W. Va. 2016)

    See 1 Louis J. Palmer, Jr., Robin Jean Davis, & Franklin D. Cleckley, Handbook on Evidence for West Virginia Lawyers§ 404.04[2][c] (“Timing of the Rule 404(b) bad conduct evidence should be a question of relevancy and prejudice under Rules 401–403.”). See also Hart v. State , 2002 WY 163, 57 P.3d 348, 356 (2002) (“Remoteness in time renders the evidence inadmissible only if the remoteness is so great that the evidence has no value.”); State v. Adams , 220 N.C.App. 319, 328, 727 S.E.2d 577, 584 (2012) (“[T]he prior crime must not be so remote [in time] as to have lost its probative value.”) (internal quotations and citations omitted).

  6. State v. Wiles

    270 N.C. App. 592 (N.C. Ct. App. 2020)   Cited 8 times

    Admissions under Rule 403 are reviewed by this Court for an abuse of discretion. State v. Adams , 220 N.C. App. 319, 328, 727 S.E.2d 577, 584 (2012). "Abuse of discretion results where the court's ruling is manifestly unsupported by reason or is so arbitrary that it could not have been the result of a reasoned decision."

  7. State v. Engle

    837 S.E.2d 727 (N.C. Ct. App. 2020)

    In reviewing the admission of evidence of other crimes, wrongs, or acts of a criminal defendant, we engage in a three-prong analysis. State v. Adams , 220 N.C. App. 319, 323, 727 S.E.2d 577, 580-81 (2012). First, we review de novo "whether the evidence was offered for a proper purpose under Rule 404(b), then determine whether the evidence is relevant under Rule 401, and finally determine whether the trial court abused its discretion in balancing the probative value of the evidence under Rule 403."

  8. State v. Thomas

    268 N.C. App. 121 (N.C. Ct. App. 2019)   Cited 9 times
    Holding a three-day period was not a "substantial amount of time"

    This Court reviews de novo the trial court's legal conclusions that evidence was offered for a proper purpose under Rule 404(b) and is relevant under Rule 401. State v. Adams , 220 N.C. App. 319, 323, 727 S.E.2d 577, 581 (2012). We then "determine whether the trial court abused its discretion in balancing the probative value of the evidence under Rule 403."

  9. State v. Bennett

    812 S.E.2d 911 (N.C. Ct. App. 2018)

    Later one of the witnesses identified that man as Defendant. Though Defendant did not attempt to rob the individuals, nor was he charged with robbery, the trial court could properly conclude the items inside the trunk could be relevant circumstantial evidence of motive. See State v. Adams , 220 N.C. App. 319, 327, 727 S.E.2d 577, 583 (2012) ("It is not required that evidence bear directly on the question in issue.") (quoting State v. Riddick , 316 N.C. 127, 137, 340 S.E.2d 422, 428 (1986) ).The evidence in the trunk was properly admitted to present a motive for the events that occurred earlier in the evening.

  10. State v. Young

    No. COA17-712 (N.C. Ct. App. Jan. 2, 2018)

    On the first point, whether the evidence was offered for a proper purpose, we first note that Rule 404(b) "is a clear rule of inclusion of relevant evidence of other crimes, wrongs or acts by a defendant, subject to but one exception requiring its exclusion if its only probative value is to show that the defendant had the propensity or disposition to commit an offense of the nature of the crime charged." State v. Adams, 220 N.C. App. 319, 322, 727 S.E.2d 577, 580 (2012) (quoting State v. Kennedy, 130 N.C. App. 399, 403, 503 S.E.2d 133, 135 (1998)). In other words, evidence of other crimes or wrongs committed by a defendant is admissible, even if it may show a propensity to act in conformity therewith, "so long as it also 'is relevant for some purpose other than to show that defendant has the propensity for the type of conduct for which he is being tried.