In re: S.C.

CourtCourt of Appeals of North Carolina
DecidedSeptember 5, 2023
Docket22-965
StatusPublished

This text of In re: S.C. (In re: S.C.) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: S.C., (N.C. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA22-965

Filed 05 September 2023

Onslow County, No. 21-JB-201

IN THE MATTER OF: S.C.

Appeal by Juvenile-appellant from order entered 23 June 2022 by Judge James

L. Moore Jr. in Onslow County District Court. Heard in the Court of Appeals 9

August 2023.

Attorney General Joshua H. Stein, by Assistant Attorney General, Janelle E. Varley, for the State.

Appellate Defender Glenn Gerding, by Assistant Appellate Defender Heidi Reiner, for juvenile-appellant.

MURPHY, Judge.

Juvenile-appellant, Karen,1 appeals the trial court’s adjudication and

disposition orders sentencing her to eight months’ probation. Under N.C.G.S. § 7B-

2405(4), a trial court must advise a juvenile of her right to remain silent against

prejudicial self-incrimination during an adjudicatory hearing. We hold, as the State

concedes, that Karen’s statutory right under N.C.G.S. § 7B-2405(4) were violated

when she testified without the trial court first conducting a colloquy regarding her

1 We use pseudonyms to protect the identity of all juveniles and for ease of reading. IN RE: S.C.

Opinion of the Court

right to avoid self-incrimination. Accordingly, we vacate the adjudication and

disposition orders and remand for a new hearing.

BACKGROUND

On 10 November 2021, the State filed a juvenile petition alleging that Karen

committed misdemeanor assault against Iris in violation of N.C.G.S. § 14-33(c)(1).

At the 24 March 2022 adjudicatory hearing, Karen denied the allegation. Karen’s

attorney made a motion to dismiss after the close of the State’s evidence, which the

trial court denied. Karen’s attorney then called her to the witness stand to testify.

The trial court did not ask Karen any questions or engage in a colloquy with her

before she testified about the assault allegation. Nor did the trial court inform Karen

of her right to remain silent; that her testimony could be used against her; or that

she was entitled to invoke her constitutional privilege against self-incrimination.

The contested adjudicatory hearing concluded in the trial court finding Karen

responsible for the lesser included offense of simple assault. Karen’s attorney gave

notice of appeal from the trial court’s adjudication, and no formal disposition order

was entered until 23 June 2022. Karen was sentenced to probation for the simple

assault and appealed. On 1 June 2023, we allowed Karen’s Motion for Peremptory

Setting and Motion to Expedite Consideration.

ANALYSIS

Karen argues that the trial court violated N.C.G.S. § 7B-2405(4) by allowing

her to testify without first advising her regarding her privilege against self-

-2- IN RE: S.C.

incrimination. Additionally, Karen contends that the error was prejudicial because

her testimony was self-incriminating.2 We agree.

“Our courts have consistently recognized that the State has a greater duty to

protect the rights of a respondent in a juvenile proceeding than in a criminal

prosecution.” In re J.R.V., 212 N.C. App. 205, 207 (2011), disc. rev. improvidentially

allowed, 365 N.C. 416 (2012) (quoting In re T.E.F., 359 N.C. 570, 575 (2005)).

N.C.G.S. § 7B-2405 provides, in pertinent part, that “the court shall protect the

following rights of the juvenile and the juvenile’s parent, guardian, or custodian to

assure due process of law,” including “[t]he privilege against self-incrimination.”

N.C.G.S. § 7B-2405(4) (2022) (emphasis added). “[B]y stating that the trial court

shall protect a juvenile’s delineated rights, [the General Assembly] places an

affirmative duty on the trial court to protect . . . a juvenile’s right against self-

incrimination.” In re J.R.V., 212 N.C. App. at 208 (emphasis added). “The plain

language of N.C.G.S. § 7B-2405 places an affirmative duty on the trial court to protect

the rights delineated therein during a juvenile delinquency adjudication.” In re J.B.,

261 N.C. App. 371, 373 (2018), disc. rev. denied, 372 N.C. 104 (2019).

While N.C.G.S. § 7B-2405 “does not provide the explicit steps a trial court must

follow when advising a juvenile of [her] rights, the statute requires, at the very least,

2 The State agrees with Karen that the trial court did not comply with N.C.S.G. 7B-2405(4) and thus did not properly adjudicate Karen. Further, the State does not dispute Karen’s argument that the testimony was self-incriminatory and therefore prejudicial.

-3- IN RE: S.C.

some colloquy between the trial court and the juvenile to ensure that the juvenile

understands [her] right against self-incrimination before choosing to testify at [her]

adjudication hearing.” In re J.R.V., 212 N.C. App. at 208-209. Here, the trial court

did not, at any time, discuss with, or inquire from, Karen whether she understood the

implications of testifying. Karen incriminated herself when she testified to

assaulting Iris both on direct and cross examination. On direct examination, Karen

incriminated herself by giving the following testimony:

[COUNSEL]: Based on her demeanor at the time did you believe that there was a chance she may strike you?

[KAREN]: Yeah. That she might try to beat me?

...

[COUNSEL]: Did you ever hit her in the back of the head?

[KAREN]: No. I just punched her face.

After the initial questioning by her attorney, Karen again incriminated herself

by admitting on cross-examination that she “pushed” Iris:

[STATE]: Yes, [Karen], just one—one question. You said before that “after she called me daddy long legs I”— something her. Did you say punched her or pushed?

[KAREN]: Pushed.

[STATE]: Pushed. Thank you.

The State also benefited from re-eliciting Karen’s admission on cross-

examination to secure a simple assault adjudication instead of an assault inflicting

-4- IN RE: S.C.

serious injury. The State’s closing argument relied on Karen’s incriminatory

testimony:

Your Honor, as to the facts that aren’t in dispute that there was some kind of verbal negative interactions like an argument, cursing, shouting match, insults being thrown around, but by [Karen’s] own admission “after she called me daddy long legs, I pushed her,” so there’s—there’s no dispute per the testimony that the—that [Karen] put hands on [Iris] first. So because of that I would ask you to find her guilty.

After the State’s closing argument, the trial court adjudicated Karen

responsible for the simple assault, which Karen admitted to during her responses to

the State’s inquiries.

We held in J.B. that “failure to follow the statutory mandate when conducting

an adjudication hearing constitutes reversible error unless proven to be harmless

beyond a reasonable doubt.” In re J.B., 261 N.C. App. at 373–374 (citing In re J.R.V.,

212 N.C. App. at 209). Likewise, in J.R.V., where “there was absolutely no colloquy

between the juvenile and the trial court,” it was determined that “the trial court’s

failure to follow its statutory mandate” was error. In re J.R.V., 212 N.C. App. at 209.

Nevertheless, we found harmless error beyond a reasonable doubt in J.R.V. because

“the juvenile’s eventual testimony was not incriminating[] [as] it was either

consistent with the evidence presented by the State or favorable to the juvenile[.]”

Id. at 210. The State has the burden of proving that a violation of a constitutional

right is harmless beyond a reasonable doubt. State v. McKoy, 327 N.C.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. McKoy
394 S.E.2d 426 (Supreme Court of North Carolina, 1990)
In re: J.B.
820 S.E.2d 369 (Court of Appeals of North Carolina, 2018)
In re T.E.F.
614 S.E.2d 296 (Supreme Court of North Carolina, 2005)
In re J.R.V.
720 S.E.2d 387 (Supreme Court of North Carolina, 2012)
In re J.R.V.
212 N.C. App. 205 (Court of Appeals of North Carolina, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
In re: S.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-sc-ncctapp-2023.