State v. Coffey

CourtCourt of Appeals of North Carolina
DecidedFebruary 20, 2024
Docket22-883
StatusPublished

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

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA22-883

Filed 20 February 2024

Wake County, Nos. 21 CRS 2396-99, 2404-07

STATE OF NORTH CAROLINA

v.

CHAD COFFEY

Appeal by Defendant from Judgments rendered 10 February 2022 by Judge R.

Allen Baddour, Jr. in Wake County Superior Court. Heard in the Court of Appeals

19 September 2023.

Attorney General Joshua H. Stein, by Assistant Attorney General Caden W. Hayes, for the State

Cheshire Parker Schneider, PLLC, by Elliot S. Abrams, for Defendant- Appellant.

Samuel J. Davis, Daniel K. Siegel and Kristi L. Graunke, for amicus curiae American Civil Liberties Union of North Carolina Legal Foundation.

Essex Richards, P.A., by Norris A. Adams, II, for amicus curiae North Carolina Fraternal Order of Police.

HAMPSON, Judge.

Factual and Procedural Background

Chad Coffey (Defendant) appeals from Judgments rendered pursuant to jury

verdicts finding Defendant guilty of twelve counts of felony obstruction of justice. The

Record before us, including the evidence presented at trial, tends to show the STATE V. COFFEY

Opinion of the Court

following:

Defendant was a deputy sheriff in Granville County, North Carolina for over

two decades. In 2007, Defendant received his firearm instructor certification and

obtained additional specialized instructor certifications. These instructor

certifications allowed Defendant to teach in-service courses for law enforcement

officers to satisfy requirements set by the North Carolina Sheriffs’ Education and

Training Standards Commission (the Commission). The Commission establishes

minimum education and training standards for justice officers, monitors compliance,

and certifies all justice officers have satisfied those standards, including firearm

training. N.C. Gen. Stat. § 17E-4(a) (2023). All active deputies who carry a firearm

must annually complete in-service training, including a classroom portion and

firearm qualification to maintain their law enforcement certification.

At the urging of Sheriff Brindel Wilkins and Chief Deputy Sherwood Boyd,

Defendant certified Wilkins’ and Boyd’s attendance at mandated trainings neither

had attended. Although neither Wilkins nor Boyd qualified at a shooting range,

Defendant filled out forms indicating firearms scores neither had attained.

Defendant acknowledged at trial he had falsified these documents.

On 26 October 2021, Defendant was indicted on fourteen counts of felony

common law obstruction of justice, two of which were later dismissed, and fourteen

counts of felony obtaining property by false pretenses, two of which were also later

dismissed. Each of the indictments for obstruction of justice alleged Defendant had

-2- STATE V. COFFEY

“unlawfully, willfully and feloniously with deceit and intent to defraud, did commit

the infamous offense of obstruction of justice by knowingly providing false and

misleading information in training records[.]” The indictments then specified

Defendant had indicated in documents mandatory in-service training and firearm

qualifications had been completed by Sheriff Wilkins and Chief Deputy Boyd

“knowing that [the trainings] had in fact not been completed, and knowing that these

records and/or the information contained in these records would be and were

submitted to [the Commission] thereby allowing” Wilkins and Boyd to maintain their

law enforcement certifications when they had failed to meet the requirements.

Defendant’s trial began on 7 February 2022. On 10 February 2022, the jury

delivered its verdict finding Defendant guilty of all twelve counts of obstruction of

justice and not guilty of each count of obtaining property by false pretenses. The trial

court sentenced Defendant to five to fifteen months of imprisonment on the first count

of obstruction of justice. The remaining counts were consolidated into two class H

felony Judgments with suspended sentences of five to fifteen months of

imprisonment. Defendant timely filed written Notice of Appeal on 14 February 2022.

Appellate Jurisdiction

The trial court rendered Judgment and sentenced Defendant on 10 February

2022. The Record also reflects written Judgments signed by the trial court on 10

February 2022, but these Judgments are neither file-stamped nor certified by the

Clerk. Rule 4 of the North Carolina Rules of Appellate Procedure provides appeal

-3- STATE V. COFFEY

from a judgment rendered in a criminal case must be given either orally at trial or by

filing notice of appeal with the clerk of superior court and serving copies thereof upon

all adverse parties within fourteen days after entry of the judgment. N.C.R. App. P.

4 (2023). Here, the Record reflects the written Judgments were signed by Judge R.

Allen Baddour, Jr. on 10 February 2022, and Defendant’s written Notice of Appeal

was file-stamped on 14 February 2022. There is no dispute between the parties that

Judgments were in fact entered and Defendant’s written Notice of Appeal was timely.

Therefore, this Court has appellate jurisdiction over this appeal.

Issue

The dispositive issues before us are whether: (I) obstruction of justice is a

cognizable common law offense in North Carolina; and (II) the indictments in this

case were sufficient to allege common law obstruction of justice.

Analysis

I. Common Law Obstruction of Justice

As a threshold matter, Defendant contends obstruction of justice is not an

offense at common law in North Carolina. Thus, Defendant asserts the indictments

fail to allege a valid offense. We disagree.

Our legislature adopted the common law by statute, providing: “All such parts

of the common law as were heretofore in force and use within this State . . . are hereby

declared to be in full force within this State.” N.C. Gen. Stat. § 4-1 (2023). Contrary

to Defendant’s assertions, obstruction of justice was historically an offense at common

-4- STATE V. COFFEY

law, and our courts have consistently recognized it as a common law offense.

Blackstone described a series of “offenses against public justice” in his treatise on

English common law. 4 William Blackstone, Commentaries on the Laws of England

127-41.

Moreover, our courts have consistently recognized common law obstruction of

justice as a cognizable offense. See e.g., State v. Bradsher, 382 N.C. 656, 659, 879

S.E.2d 567, 570 (2022); State v. Ditenhafer, 373 N.C. 116, 128, 834 S.E.2d 392, 400

(2019); State v. Mitchell, 259 N.C. App. 866, 878, 817 S.E.2d 455, 462-63, disc. review

denied, 371 N.C. 478, 818 S.E.2d 278 (2018). Our Supreme Court has even expressed

that the existence of statutory forms of obstruction of justice did not serve to abrogate

the common law offense. In re Kivett, 309 N.C. 635, 670, 309 S.E.2d 442, 462 (1983)

(“Obstruction of justice is a common law offense in North Carolina. Article 30 of

Chapter 14 of the General Statutes does not abrogate this offense.”). Thus, common

law obstruction of justice is a cognizable offense in North Carolina.

II. Sufficiency of the Indictments to Allege Common Law Obstruction of Justice

Defendant further argues the trial court erred by denying his Motion to

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

Related

Clayton v. Willis
489 So. 2d 813 (District Court of Appeal of Florida, 1986)
State v. Preston
325 S.E.2d 686 (Court of Appeals of North Carolina, 1985)
Henry v. Deen
310 S.E.2d 326 (Supreme Court of North Carolina, 1984)
State v. Wright
696 S.E.2d 832 (Court of Appeals of North Carolina, 2010)
State v. Eastman
438 S.E.2d 460 (Court of Appeals of North Carolina, 1994)
Burgess v. Busby
544 S.E.2d 4 (Court of Appeals of North Carolina, 2001)
Grant v. High Point Regional Health System
645 S.E.2d 851 (Court of Appeals of North Carolina, 2007)
In Re Inquiry Concerning a Judge, No. 76, Kivett
309 S.E.2d 442 (Supreme Court of North Carolina, 1983)
People v. Thomas
475 N.W.2d 288 (Michigan Supreme Court, 1991)
Blackburn v. Carbone
703 S.E.2d 788 (Court of Appeals of North Carolina, 2010)
State v. Cousin
757 S.E.2d 332 (Court of Appeals of North Carolina, 2014)
State v. Ellis
776 S.E.2d 675 (Supreme Court of North Carolina, 2015)
State v. Brice
806 S.E.2d 32 (Supreme Court of North Carolina, 2017)
State v. Mitchell
817 S.E.2d 455 (Court of Appeals of North Carolina, 2018)
State v. White
827 S.E.2d 80 (Supreme Court of North Carolina, 2019)

Cite This Page — Counsel Stack

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