State v. Creighton

CourtCourt of Appeals of North Carolina
DecidedDecember 3, 2025
Docket25-373
StatusUnpublished

This text of State v. Creighton (State v. Creighton) 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. Creighton, (N.C. Ct. App. 2025).

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An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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. COA25-373

Filed 3 December 2025

Pitt County, Nos. 23CR001163-730, 23CR284161-730, 23CR284168-730

STATE OF NORTH CAROLINA

v.

BRANDON JOSEPH CREIGHTON, Defendant.

Appeal by defendant from judgment entered 25 April 2024 by Judge Marvin K.

Blount, III, in Pitt County Superior Court. Heard in the Court of Appeals 14 October

2025.

W. Michael Spivey for defendant-appellant.

Attorney General Jeff Jackson, by Assistant Attorney General John W. Congleton, for the State.

DILLON, Chief Judge.

Defendant Brandon Joseph Creighton appeals from the trial court’s judgment

finding him guilty of felony serious injury by vehicle, driving while impaired, reckless

driving, failure to maintain lane control, and felony death by vehicle.

First, Defendant argues the trial court violated his constitutional right to

confront a witness. We agree, but we conclude the error was harmless beyond a STATE V. CREIGHTON

Opinion of the Court

reasonable doubt. Second, Defendant argues the trial court plainly erred by failing

to instruct the jury on intervening negligence. We disagree. Third, Defendant argues

the trial court erred by denying Defendant’s motion to dismiss the charges of felony

death by vehicle and felony serious injury by vehicle. We disagree.

Accordingly, for the reasoning below, we conclude Defendant received a fair

trial, free from reversible error.

I. Background

This matter stems from a multi-vehicle traffic accident that occurred on a day

in April 2023 around noon on Highway 264 in Pitt County resulting in serious injuries

and a death. Defendant was indicted with several crimes based on the accident,

including felony death by motor vehicle. This matter came on for trial in April 2024.

The evidence at trial tended to show as follows: Defendant and Arianna King

were driving their respective vehicles on the same highway, in the same direction.

Defendant was driving his vehicle in the right, northbound lane of the highway; and

Ms. King was driving her vehicle in the left, northbound lane.

At some point, Defendant began moving his vehicle into the Ms. King’s lane of

travel, the left, northbound lane. As he did so, the back portion of his vehicle clipped

the front portion of Ms. King’s vehicle. This collision caused Ms. King to lose control

of her vehicle, resulting in her vehicle crossing over the median and colliding with a

southbound vehicle operated by Gene Herring. As a result of the collision, Mr.

Herring suffered serious injuries, while his passenger, Delores Pearce, was killed.

-2- STATE V. CREIGHTON

There was evidence that Defendant had been drinking just prior to and was

impaired at the time of the accident.

The jury returned verdicts finding Defendant guilty of felony death by vehicle

(for Ms. Pearce’s death), felony serious injury by vehicle (for Mr. Herring’s injuries),

driving while impaired, reckless driving, and failure to maintain lane control. The

trial court entered judgment consistent with the jury’s verdicts. Defendant appeals.

II. Analysis

Defendant makes three arguments on appeal, which we address in turn.

A. Confrontation Clause

Three of the crimes for which Defendant was convicted—namely, felony death

by vehicle, felony serious injury by vehicle, and driving while impaired—required the

State to prove Defendant was engaged in “impaired driving” at the time of the

accident. See N.C.G.S. §§ 20-141.4(a1); 20-141.4(a3); 20-138.1(a) (2023). The State

may prove “impaired driving” in one of two ways, either that the person was driving

“[w]hile under the influence of an impairing substance” or “[a]fter having consumed

sufficient alcohol that he has, at any relevant time after the driving, an alcohol

concentration of 0.08 or more.” N.C.G.S. § 20-138.1(a).

On appeal, Defendant argues his rights under the Confrontation Clause of the

federal constitution were violated when a State expert was allowed to testify

concerning the results of a test performed by another analyst which showed

Defendant had a blood alcohol concentration (“BAC”) greater than 0.08. We agree.

-3- STATE V. CREIGHTON

However, for the reasoning below, we hold the error was harmless beyond a

reasonable doubt.

1. The trial court erred, and the error was constitutional in nature.

We review alleged violations of constitutional rights de novo. State v. Flow,

384 N.C. 528, 546 (2023).

Under both our federal and state constitutions, criminal defendants have the

right to confront witnesses against them. U.S. Const. amend. VI; N.C. Const. art. I,

§ 23. However, the Confrontation Clause applies only to testimonial hearsay,

“statements made by people not in the courtroom[.]” State v. Lester, 387 N.C. 90, 91

(2025) (quoting Smith v. Arizona, 602 U.S. 779, 784 (2024)).

A report, such as a BAC report, is testimonial when it is sought for obtaining

evidence against a specifically identified person and created solely for an “evidentiary

purpose” to aid a police investigation of that person. See, e.g., Bullcoming v. New

Mexico, 564 U.S. 647, 664 (2011) (holding a BAC report was testimonial when the

defendant’s blood had been seized for the sole purpose of testing his alcohol content);

State v. Clark, 296 N.C. App. 718, 723 (2024) (“[L]ab reports created solely for an

evidentiary purpose, made in aid of a police investigation, [ ] rank as testimonial.”

(second alteration and emphasis in original)).

Conversely, a report might not be testimonial when used for the purpose of

identifying a culprit, when no suspect/defendant has yet been identified, see, e.g.,

Williams v. Illinois, 567 U.S. 50, 58 (2012) (holding a rape kit report was not

-4- STATE V. CREIGHTON

testimonial where it was “produced before any suspect was identified” and “[t]he

report was sought not for the purpose of obtaining evidence to be used against [the]

petitioner, who was not even under suspicion at the time, but for the purpose of

finding a rapist who was on the loose”), or to identify DNA other than that of the

victim’s, e.g., State v. Tate, 918 S.E.2d 886, 902 (N.C. Ct. App. 2025) (holding a rape

kit was not testimonial when completed “for the sole purpose of identifying the

potential presence of any DNA other than [the victim’s] own, not to identify a

potential suspect”).

Here, Defendant was known to law enforcement as the person who caused the

accident. The BAC report was prepared as part of the investigation of him. And the

testifying expert relied upon the statements in the report by the absent analyst.

Accordingly, we conclude Defendant’s constitutional rights under the Confrontation

Clause were violated by the testimony of the substitute analyst.

2. The error was harmless, beyond a reasonable doubt.

For preserved, non-constitutional errors, it is the defendant who bears the

burden on appeal of showing “a reasonable possibility [exists] that, had the error in

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Cite This Page — Counsel Stack

Bluebook (online)
State v. Creighton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-creighton-ncctapp-2025.