State v. Austin

CourtCourt of Appeals of North Carolina
DecidedSeptember 21, 2021
Docket20-198
StatusPublished

This text of State v. Austin (State v. Austin) 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. Austin, (N.C. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2021-NCCOA-494

No. COA20-198

Filed 21 September 2021

Caldwell County, No. 13 CRS 54340

STATE OF NORTH CAROLINA

v.

NANCY BENGE AUSTIN

Appeal by defendant from judgment entered 24 May 2019 by Judge Lisa C.

Bell in Caldwell County Superior Court. Heard in the Court of Appeals 14 April 2021.

Attorney General Joshua H. Stein, by Special Deputy Attorney General Mary Carla Babb, for the State.

Appellate Defender Glenn Gerding, by Assistant Appellate Defender Daniel K. Shatz, for defendant.

DIETZ, Judge.

¶1 Defendant Nancy Austin appeals her conviction for first degree murder after

she shot and killed Dylan Short in her driveway.

¶2 Just before the shooting, Short drove his car into Austin’s driveway knowing

that he was not welcome there and refused to leave. Short then shoved Austin’s adult

daughter, in view of Austin, and a fight broke out. After Austin pulled out a gun and

demanded that Short leave her property, Short reached for the gun and, at some

point, a gunshot went off. After further fighting, a bystander saw Austin standing STATE V. AUSTIN

Opinion of the Court

over Short, who lay on the ground in the driveway pleading “Please, please, just let

me go. Let me go.” Austin then stepped several feet back and shot Short in the head,

killing him.

¶3 The State charged Austin with murder, and Austin asserted the castle doctrine

defense, which is codified in North Carolina General Statute § 14-51.2. The trial court

declined to resolve the defense in a pre-trial hearing and also denied Austin’s motion

to dismiss at trial, concluding that there were fact issues to be resolved by a jury.

¶4 As explained below, the trial court properly declined to resolve the castle

doctrine defense before trial. Where, as here, there are fact disputes concerning the

castle doctrine’s applicability, those fact questions must be resolved by a jury. The

trial court also properly denied the motion to dismiss because the State presented

sufficient evidence to rebut the castle doctrine’s presumption in favor of the lawful

occupant of a home, thus creating a fact issue concerning the doctrine’s applicability.

Finally, the trial court’s jury instructions, viewed as a whole, properly instructed the

jury on the elements of the castle doctrine. We therefore reject Austin’s arguments

and find no error in the trial court’s judgment.

Facts and Procedural History

¶5 In 2013, Defendant Nancy Austin lived in a home with her daughter, Sarah,

and Sarah’s child. Dylan Short is the father of Sarah’s child. Short was once in a

relationship with Sarah, but the two later broke up. STATE V. AUSTIN

¶6 After a violent incident between Short and Sarah at Austin’s home in the

summer of 2012, Austin told Short he was not welcome on the property. Sarah

resumed a relationship with Short in November 2013. In December 2013, Austin and

Short exchanged Facebook messages in which Austin disapproved of Short’s

relationship with her daughter. Austin also accused Short of attempting to run her

off the road, which he acknowledged.

¶7 On 26 December 2013, Short spent the day with Sarah and then followed her

home without her permission. Short had not been to the house in over a year. Austin

was outside in the driveway, near a “no trespassing” sign, when Short arrived. Sarah,

who had already arrived, got out of her car and took her child inside.

¶8 Short yelled at Sarah to stop and to talk to him. Austin told Short to leave.

Sarah also told Short to leave, and Short then pushed her. Short was unarmed at the

time. At this point, Austin took out a gun, pointed it at Short, told her daughter to go

inside, and told Short to leave. Short refused to leave, telling Austin he did not have

to leave because his child was inside the home.

¶9 Austin testified that she looked to see if her daughter had gone inside and,

when she turned back, Short had “jumped” on her and reached for the gun. As Sarah

was walking inside, she heard a gunshot. When she turned back around, Short and

Austin were entangled, and Short was reaching around Austin’s back toward the gun.

Sarah ran toward them and pushed Short. Sarah fell to the ground with Short, STATE V. AUSTIN

struggled with him, then moved on top of him and put her hands around his neck.

Sarah got up again to go back into the house and, as she walked away, heard a second

gunshot. She turned around and saw that Austin, who was standing up at this time,

had shot Short, who was on the ground. Austin told Sarah to call 911, which she did.

¶ 10 In statements to police officers that evening, Austin explained that she had

previously told Short not to come on her property, that when he arrived, she told him

to leave, and that Short refused to leave. She also told the officers about the struggle

in the driveway and that Short had knocked her to the ground and grabbed for her

gun. Lastly, she told the officers that Short was on the ground and within three feet

of her when she shot him.

¶ 11 The State charged Austin with the first degree murder of Short. The case went

to trial. At trial, Billy Herald, who was working on a nearby property about twenty-

five to forty yards away from Austin’s home, testified that he had witnessed some of

the incident. Herald testified that he saw Sarah drive into Austin’s driveway at a

fairly high speed and then saw Short pull up behind her, yelling at her to stop. Herald

stopped watching until he heard Short shout, “she’s got a loaded gun,” a few minutes

later. He looked back and saw Short on his left knee with his hand up, and Austin

pointing a gun at him. He stopped watching again and then, shortly after, he heard

a gunshot. He looked back and saw Short behind Austin and Austin’s daughter

jumping on top of Short, then Short falling to the ground. Herald testified that he STATE V. AUSTIN

then saw Austin stand over Short, take two steps back, and then shoot Short at a

distance of five to six feet away. Before Austin shot Short, Herald heard him say,

“Please, please, just let me go. Let me go.”

¶ 12 Dr. Patrick Lantz, who performed the autopsy, testified that Short died from a

single gunshot wound to the face. Lantz stated that he observed stippling on Short’s

face, indicating that the shooting occurred at an intermediate range. Finally, Lantz

testified that he would not expect stippling of this nature in a shooting with a range

farther than three feet, but that it would depend on the ammunition used.

¶ 13 On 24 May 2019, the jury found Austin guilty of first degree murder and the

court sentenced her to life without parole. Austin gave notice of appeal in open court.

Analysis

¶ 14 Every issue Austin asserts on appeal concerns some aspect of a self-defense

provision in our General Statutes commonly called the “castle doctrine.” See N.C.

Gen. Stat. § 14-51.2.

¶ 15 “The ‘castle doctrine’ is derived from the principle that one’s home is one’s

castle and is based on the theory that if a person is bound to become a fugitive from

her own home, there would be no refuge for her anywhere in the world.” State v. Cook,

254 N.C. App. 150, 157, 802 S.E.2d 575, 579 (2017) (Stroud, J. dissenting). The castle

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State v. Austin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-austin-ncctapp-2021.