State v. Anderson

CourtCourt of Appeals of North Carolina
DecidedFebruary 4, 2026
Docket25-215
StatusUnpublished
AuthorJudge John Tyson

This text of State v. Anderson (State v. Anderson) 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
State v. Anderson, (N.C. Ct. App. 2026).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-215

Filed 4 February 2026

Hoke County, Nos. 21CR050055-460, 21CR050056-460, 21CR050057-460, 23CR000052-460

STATE OF NORTH CAROLINA

v.

RONNIE WADE ANDERSON

Appeal by defendant from judgment entered 5 February 2024 by Judge

Michael A. Stone in Hoke County Superior Court. Heard in the Court of Appeals 14

January 2026.

Attorney General Jeff Jackson, by Assistant Attorney General Scott K. Beaver, for the State.

Shawn R. Evans, for the defendant-appellant.

TYSON, Judge.

Ronnie Wade Anderson (“Defendant”) appeals from judgments entered upon a

jury’s convictions for illegal drug offenses. He argues the trial court committed plain

error in denying his motion to suppress due to lack of probable cause to issue a STATE V. ANDERSON

Opinion of the Court

warrant to search a residence. Defendant also argues the State presented insufficient

evidence tending to show he possessed a firearm as a felon. We discern no plain error.

I. Background

On 13 January 2021, and based upon prior surveillance activity, Hoke County

Sheriff’s detectives applied for, secured, and executed a warrant for a residence

located at 1629 Strother Road in Aberdeen, North Carolina. Defendant was arrested

and indicted for trafficking cocaine, trafficking methamphetamine, possession of a

firearm by a convicted felon, manufacturing marijuana, possession with intent to

distribute marijuana, and possession of drug paraphernalia.

Defendant filed a motion on 22 September 2023 to suppress evidence seized

pursuant to the search warrant based on lack of probable cause. The motion was

called for hearing on 6 February 2024.

Hoke County Sheriff’s Detective David Hayworth, who had submitted the

search warrant application, testified at the suppression hearing, regarding the events

and details written in the application:

Detective Hayworth recalled starting an investigation after receiving citizen

complaints and information from confidential informants asserting someone was

selling drugs from the property located at 1629 Strother Road. He and other Sheriff’s

deputies began surveilling the residence and observed vehicles arriving, staying for

short periods of time, and then leaving. In August of 2020, a Moore County Sheriff’s

-2- STATE V. ANDERSON

detective reached out to the Hoke County Sheriff in reference to a drug overdose, and

reported the drugs had come from 1629 Strother Road.

Upon receiving the report, Sheriff’s deputies began working with a confidential

informant. The informant told Sheriff’s deputies illegal narcotics, Suboxone and

methamphetamine, were being sold from 1629 Strother Road by an older white male

with long gray hair, approximately 60 years of age. The informant reported having

driven a friend to that residence. The name “Ronnie” was provided as the name of a

potential suspect. Using a North Carolina internal database, Detective Hayworth

searched for individuals associated with 1629 Strother Road and the results provided

the name James Ernest Luther as a potential match for that address. The Sheriff’s

deputies obtained a photograph believed to be an image of James Ernest Luther from

Moore County.

On 13 January 2021, Detective Hayworth and two other officers were

conducting physical surveillance at 1629 Strother Road. They stopped a vehicle

coming from the residence and spoke with the driver. The driver stated he had left

the house of a friend by the name of “Ronnie.” When asked if he had anything illegal

in the car, the driver stated he had meth and Suboxone underneath the driver’s seat.

The Officers seized those items. The driver provided a description of what “Ronnie”

looked like: “a white male with long, gray hair, approximately 6’1”, maybe in his 60’s.”

The driver also reported having previously bought the drugs from “Ronnie.”

Immediately after this interaction, Detective Hayworth applied for a search

-3- STATE V. ANDERSON

warrant for the residence located at 1629 Strother Road. The search warrant was

issued, and the Sheriff’s deputies executed it on 13 January 2021.

The trial court denied Defendant’s motion to suppress. During trial, counsel

for Defendant failed to renew objections to the introduction of evidence obtained as a

result of the execution of the search warrant. At the close of evidence, Defendant

moved to dismiss the charge of possession of a firearm by a felon.

The case was submitted to the jury, who returned a verdict of guilty in all

counts and convicted Defendant of all charges. He was sentenced to an active term

of 70-93 months for the conviction of trafficking and manufacturing marijuana, and

35-51 months active term to run consecutively to the first sentence for the remaining

charges. Defendant timely entered oral notice of appeal.

II. Jurisdiction

Jurisdiction lies in this Court pursuant to N. C. Gen. Stat. §§ 7A-27(b)(1) and

15A-1444(a) (2023).

III. Issues

Defendant argues the trial court prejudicially erred in denying his motion to

suppress and asserts the warrant was not properly based upon probable cause.

Defendant also argues the State presented insufficient evidence tending to show

Defendant constructively possessed the firearm found inside the residence. We

address each argument in turn.

IV. Analysis

-4- STATE V. ANDERSON

A. Motion to Suppress

1. Standard of Review

When reviewing a trial court’s ruling “on appeal from denial of a motion to

suppress, the trial court’s findings of fact are binding when supported by competent

evidence, while conclusions of law are fully reviewable by the appellate court.” State

v. Icard, 363 N.C. 303, 308, 677 S.E.2d 822, 826 (2009); State v. Biber, 365 N.C. 162,

167-68, 712 S.E.2d 874, 878 (2011); State v. Reed, 373 N.C. 498, 507, 838 S.E.2d 414,

420 (2020). The trial court’s conclusions of law are reviewed de novo, wherein this

Court “considers the matter anew and substitutes its own judgment for that of the

trial court.” In re C.V.D.C., 374 N.C. 525, 530, 843 S.E.2d 202, 205 (2020); State v.

Woolard, 385 N.C. 560, 570, 894 S.E.2d 717, 725 (2023).

When trial counsel fails to renew objections to the introduction of evidence at

the time it is offered at trial, we review the appeal of a motion in limine for plain

error. State v. Golphin, 352 N.C. 364, 405, 533 S.E.2d 168, 198 (2000), cert. denied,

532 U.S. 931, 149 L. Ed. 2d 305 (2001); see, e.g., State v. Patterson, 194 N.C. App. 608,

615-16, 671 S.E.2d 357, 361-62, disc. rev. denied, 363 N.C. 587, 683 S.E.2d 383 (2009).

To show plain error, the error in the admissibility of evidence must be so fundamental

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

Related

United States v. Ventresca
380 U.S. 102 (Supreme Court, 1965)
Illinois v. Gates
462 U.S. 213 (Supreme Court, 1983)
State v. Patterson
671 S.E.2d 357 (Court of Appeals of North Carolina, 2009)
State v. Fritsch
526 S.E.2d 451 (Supreme Court of North Carolina, 2000)
State v. Benson
372 S.E.2d 517 (Supreme Court of North Carolina, 1988)
State v. Campbell
191 S.E.2d 752 (Supreme Court of North Carolina, 1972)
State v. McCoy
397 S.E.2d 355 (Court of Appeals of North Carolina, 1990)
State v. Jones
261 S.E.2d 860 (Supreme Court of North Carolina, 1980)
State v. Golphin
533 S.E.2d 168 (Supreme Court of North Carolina, 2000)
State v. Witherspoon
429 S.E.2d 783 (Court of Appeals of North Carolina, 1993)
State v. Odom
300 S.E.2d 375 (Supreme Court of North Carolina, 1983)
State v. Williams
333 S.E.2d 708 (Supreme Court of North Carolina, 1985)
State v. Icard
677 S.E.2d 822 (Supreme Court of North Carolina, 2009)
State v. Rose
451 S.E.2d 211 (Supreme Court of North Carolina, 1994)
State v. Smith
650 S.E.2d 29 (Court of Appeals of North Carolina, 2007)
State v. Arrington
319 S.E.2d 254 (Supreme Court of North Carolina, 1984)
State v. Ledbetter
461 S.E.2d 341 (Court of Appeals of North Carolina, 1995)
State v. Louchheim
250 S.E.2d 630 (Supreme Court of North Carolina, 1979)
State v. Smarr
551 S.E.2d 881 (Court of Appeals of North Carolina, 2001)
State v. Biber
712 S.E.2d 874 (Supreme Court of North Carolina, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Anderson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-anderson-ncctapp-2026.