State v. Bowman

CourtCourt of Appeals of North Carolina
DecidedFebruary 6, 2024
Docket23-82
StatusPublished

This text of State v. Bowman (State v. Bowman) 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. Bowman, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA23-82

Filed 6 February 2024

Durham County, Nos. 19 CRS 2363–64, 56406

STATE OF NORTH CAROLINA

v.

JAMES FREDRICK BOWMAN, Defendant.

Appeal by Defendant from judgment entered 25 January 2022 by Judge

Josephine K. Davis in Durham County Superior Court. Heard in the Court of Appeals

17 October 2023.

Attorney General Joshua H. Stein, by Special Deputy Attorney General Jasmine McGhee, for the State.

Appellate Defender Glenn Gerding, by Assistant Appellate Defender Aaron Thomas Johnson, for Defendant-Appellant.

CARPENTER, Judge.

James Fredrick Bowman (“Defendant”) appeals from judgment entered after a

jury found him guilty of two counts of first-degree forcible sexual offense, one count

of first-degree forcible rape, one count of possession of a firearm by a felon, one count

of assault by pointing a gun, one count of assault on a female, and one count of

communicating threats. On appeal, Defendant argues the trial court erred by

instructing the jury on only one count of first-degree forcible sexual offense, thus

jeopardizing his right to a unanimous verdict. Additionally, Defendant argues STATE V. BOWMAN

Opinion of the Court

remand is required to correct clerical errors in the judgment. After careful review,

we agree with Defendant. Therefore, we reverse in part and remand this case for a

new trial concerning the two counts of first-degree forcible sexual offense and for

correction of clerical errors in the judgment.

I. Factual & Procedural Background

At around 5:00 a.m. on 9 September 2019, S.B. (“Victim”) awoke when

Defendant banged on her window, yelling at her to open the door to her home. Once

Victim opened the door, Defendant accused Victim of sleeping with someone else and

punched her in the chest. Defendant appeared to be heavily intoxicated and was

armed with a handgun. Defendant exclaimed, “[s]ince you want to act like a whore,

I’m going to treat you like a whore.” Defendant, while brandishing a gun, then

ordered Victim to strip. Defendant proceeded to assault Victim anally, orally, and

vaginally, while threatening to kill Victim, dismember her body, and bury her in

pieces.

On 21 October 2019, a Durham County grand jury indicted Defendant for the

following seven offenses: one count of first-degree forcible rape, two counts of first-

degree forcible sexual offense, one count of possession of a firearm by a felon, one

count of assault by pointing a gun, one count of assault on a female, and one count of

communicating threats. On 23 March 2021, the case went to trial, which ended in a

hung-jury mistrial. On 17 January 2022, the case went to a second trial in Durham

County Superior Court.

-2- STATE V. BOWMAN

At the close of all evidence, the trial court held a charge conference and

instructed the jury. Defendant did not object to the jury instructions. The trial court

read the elements for first-degree forcible sexual offense and explained the burden of

proof. The trial court did not read the instructions for each count charged, nor did

the court otherwise notify the jury that Defendant was charged with two separate

counts of first-degree forcible sexual offense.

The trial court did state that “all 12 of you must agree to your verdict. You

cannot reach a verdict by majority vote.” But while the verdict sheets listed two

counts of first-degree forcible sexual offense, the two counts were not separated by

specific instances of sexual act. The two counts were simply separated on the verdict

sheet as “count 2” and “count 3.” This is similar to Defendant’s indictment, which

listed the two first-degree forcible sexual offenses as the second and third counts.

The jury found Defendant guilty on all seven charges, including the two counts

of first-degree forcible sexual offense. Defendant then admitted the existence of an

aggravating factor. The trial court entered judgment on the jury’s verdicts and

imposed a consolidated aggravated-range sentence of 365 to 498 months of active

imprisonment. Defendant gave oral notice of appeal in open court following the entry

of judgment.

II. Jurisdiction

This Court has jurisdiction under N.C. Gen. Stat. § 7A-27(b)(1) (2021).

III. Issues

-3- STATE V. BOWMAN

The issues on appeal are whether: (1) the trial court committed plain error by

instructing the jury on only one count of first-degree forcible sexual offense, thus

jeopardizing Defendant’s right to a unanimous verdict; and (2) remand is required to

correct clerical errors in the judgment.

IV. Analysis

A. Jury Instructions

Defendant first contends the trial court committed plain error by instructing

the jury on only one count of first-degree forcible sexual offense, thus jeopardizing his

right to a unanimous verdict. After careful review, we agree with Defendant.

When the issue is properly preserved at trial, “[t]he question of whether a trial

court erred in instructing the jury is a question of law reviewed de novo.” State v.

McGee, 234 N.C. App. 285, 287, 758 S.E.2d 661, 663 (2014). We review unpreserved

jury-instruction issues, however, for plain error. State v. Collington, 375 N.C. 401,

410, 847 S.E.2d 691, 698 (2020). Here, Defendant did not object to the jury

instructions at trial, so we will review only for plain error. See id. at 410, 847 S.E.2d

at 698.

Under plain-error review, this Court must first determine that an error

occurred at trial. See State v. Towe, 366 N.C. 56, 62, 732 S.E.2d 564, 568 (2012).

Second, the defendant must demonstrate the error was “fundamental,” which means

the error probably caused a guilty verdict and “seriously affect[ed] the fairness,

integrity, or public reputation of judicial proceedings.” State v. Grice, 367 N.C. 753,

-4- STATE V. BOWMAN

764, 767 S.E.2d 312, 320–21 (2015) (quoting State v. Lawrence, 365 N.C. 506, 519,

723 S.E.2d 326, 335 (2012)). Notably, the “plain error rule . . . is always to be applied

cautiously and only in the exceptional case . . . .” State v. Odom, 307 N.C. 655, 660,

300 S.E.2d 375, 378 (1983) (quoting United States v. McCaskill, 676 F.2d 995, 1002

(4th Cir. 1982)).

First-degree forcible sexual offense includes “a sexual act with another person

by force and against the will of the other person” by use, or threatened use, of a deadly

weapon. N.C. Gen. Stat. § 14-27.26 (2021). A sexual act includes “[c]unnilingus,

fellatio, analingus, or anal intercourse, but does not include vaginal intercourse.

Sexual act also means the penetration, however slight, by any object into the genital

or anal opening of another person’s body.” Id. § 14-27.20(4).

“It is the duty of the trial court to instruct the jury on the law applicable to the

substantive features of the case arising on the evidence . . . .” State v. Robbins, 309

N.C.

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Bluebook (online)
State v. Bowman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bowman-ncctapp-2024.