State v. Crisp

CourtCourt of Appeals of North Carolina
DecidedDecember 21, 2021
Docket20-882
StatusPublished

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

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2021-NCCOA-697

No. COA20-882

Filed 21 December 2021

Swain County, No. 14CRS050106

STATE OF NORTH CAROLINA

v.

ALEXANDER MICHAEL CRISP

Appeal by Defendant from judgment entered 16 September 2019 by Judge

Alan Z. Thornburg in Swain County Superior Court. Heard in the Court of Appeals

22 September 2021.

Attorney General Joshua H. Stein, by Assistant Attorney General Marissa K. Jensen, for the State-Appellee.

Appellate Defender Glenn Gerding, by Assistant Appellate Defender Candace Washington, for Defendant-Appellant.

COLLINS, Judge.

¶1 Defendant Alexander Crisp appeals from a judgment entered upon a jury

verdict of guilty of second-degree murder. Defendant argues that the trial court

plainly erred by omitting a jury instruction on the defense of accident. Defendant

also argues that the trial court erred by sentencing him as a Class B1 felon because

the jury’s verdict was ambiguous in light of evidence that Defendant acted with a

depraved heart. Because there was insufficient evidence to support an accident STATE V. CRISP

Opinion of the Court

instruction and there was no evidence to support a depraved-heart theory of malice,

we discern no error.

I. Procedural History

¶2 Defendant was indicted for first-degree murder on 10 March 2014. Defendant

was tried before a jury from 29 July to 16 September 2019. The jury found Defendant

guilty of second-degree murder. The trial court sentenced Defendant, as a Class B1

felon with a prior record level of II, to 221 to 278 months in prison with credit for time

served in pretrial confinement. Defendant timely gave written notice of appeal.

II. Factual Background

¶3 In February 2014, Defendant, his girlfriend Summer Lynn Johnson, and their

seven-month-old daughter were living in a trailer on the property of Defendant’s

parents. Defendant’s parents, Michael Crisp and Andrea Crisp (“Mr. Crisp” and

“Mrs. Crisp”) lived in a home nearby on the same property.

¶4 The evidence at trial tended to show the following: On the morning of

19 February 2014, Defendant, Johnson, and their daughter were the only persons in

the trailer. Between 5:30 and 6:00 am, Defendant was asleep on the couch and woke

to Johnson “yelling at [him] to wake up.” When Defendant saw their daughter

“crawling down the hallway right through the kitchen,” Defendant picked her up and

began to make her a bottle. Defendant estimated that he and Johnson were up for

30 to 40 minutes and continued to argue, “yell[ing] back and forth” and “confront[ing]

each other.” STATE V. CRISP

¶5 During the argument, Johnson suffered a gunshot wound to her left eye.

Defendant called 911 at 6:19 am. After the 911 dispatcher instructed him to perform

CPR, Defendant ended the call and called his parents’ home phone to reach his

mother, who knew CPR. Defendant’s parents both ran to the trailer, where they saw

Defendant at the back door. Mrs. Crisp heard Defendant yell, “She shot herself in

the eye.” Mrs. Crisp entered the trailer and began to perform CPR on Johnson.

¶6 Two ambulances arrived at the trailer at 6:29 am. Paramedics and EMTs

entered the trailer, went to the back bedroom where Johnson was laying, and directed

Mrs. Crisp to discontinue CPR. The paramedics and EMTs noticed Defendant

racking the slide of a pistol and requested that he put the gun down. The paramedics

and EMTs’ attempts to resuscitate Johnson were unsuccessful and Johnson was

pronounced dead at 6:40 am.

¶7 At trial, the State’s theory was that Johnson was planning to leave Defendant,

the argument between Defendant and Johnson escalated, and Defendant

intentionally shot Johnson. Defendant’s theory was that Johnson shot herself either

accidentally or intentionally. Defendant testified that he was not in the bedroom and

did not fire the gun. Likewise, multiple witnesses testified that Defendant stated

that he was outside the bedroom when the gun fired.

III. Discussion

A. Accident Instruction

¶8 Defendant argues that the trial court plainly erred by failing to instruct the STATE V. CRISP

jury on the defense of accident.

¶9 A party may not make the trial court’s omission of a jury instruction “the basis

of an issue presented on appeal unless the party objects thereto before the jury retires

to consider its verdict, stating distinctly that to which objection is made and the

grounds of the objection[.]” N.C. R. App. P. 10(a)(2). Defendant neither requested an

instruction on the defense of accident nor objected to the trial court’s omission of such

an instruction. However, because Defendant “specifically and distinctly” contends

that the trial court’s omission of an accident instruction amounted to plain error, we

will review this issue for plain error. N.C. R. App. P. 10(a)(4); State v. Smith, 362

N.C. 583, 596, 669 S.E.2d 299, 308 (2008) (reviewing jury instructions for plain error

where defendant failed to object at trial).

¶ 10 “For error to constitute plain error, a defendant must demonstrate that a

fundamental error occurred at trial.” State v. Lawrence, 365 N.C. 506, 518, 723

S.E.2d 326, 334 (2012) (citation omitted). “To show that an error was fundamental,

a defendant must establish prejudice—that, after examination of the entire record,

the error ‘had a probable impact on the jury’s finding that the defendant was guilty.’”

Id. (quoting State v. Odom, 307 N.C. 655, 660, 300 S.E.2d 375, 378 (1983)).

¶ 11 A trial court must

instruct the jury on all of the substantive features of a case. This is a duty which arises notwithstanding the absence of a request by one of the parties for a particular instruction. All defenses arising from the evidence presented during the trial constitute substantive features of a case and therefore STATE V. CRISP

warrant the trial court’s instruction thereon.

Id. at 381, 368 S.E.2d at 617 (citations omitted). “When determining whether the

evidence is sufficient to entitle a defendant to jury instructions on a defense or

mitigating factor, courts must consider the evidence in the light most favorable to

defendant.” State v. Mercer, 373 N.C. 459, 464, 838 S.E.2d 359, 363 (2020) (quotation

marks and citations omitted).

¶ 12 The defense of accident “is not an affirmative defense, but acts to negate the

mens rea element of homicide.” State v. Lytton, 319 N.C. 422, 425-26, 355 S.E.2d 485,

487 (1987) (citations omitted). “A killing will be excused as an accident when it is

unintentional and when the perpetrator, in doing the homicidal act, did so without

wrongful purpose or criminal negligence while engaged in a lawful enterprise.” State

v. Riddick, 340 N.C. 338, 342, 457 S.E.2d 728, 731 (1995) (citation omitted). “The

defense of accident is triggered in factual situations where a defendant, without

premeditation, intent, or culpable negligence, commits acts which bring about the

death of another.” Id. (quotation marks and citations omitted).

¶ 13 The evidence in the present case, when viewed in the light most favorable to

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Related

State v. Henderson
307 S.E.2d 846 (Court of Appeals of North Carolina, 1983)
State v. Lytton
355 S.E.2d 485 (Supreme Court of North Carolina, 1987)
State v. Odom
300 S.E.2d 375 (Supreme Court of North Carolina, 1983)
State v. Peterson
210 S.E.2d 883 (Court of Appeals of North Carolina, 1975)
State v. Riddick
457 S.E.2d 728 (Supreme Court of North Carolina, 1995)
State v. Smith
669 S.E.2d 299 (Supreme Court of North Carolina, 2008)
State v. Fuller
531 S.E.2d 861 (Court of Appeals of North Carolina, 2000)
State v. Lawrence
723 S.E.2d 326 (Supreme Court of North Carolina, 2012)
State v. Lail
795 S.E.2d 401 (Court of Appeals of North Carolina, 2016)
State v. Mosley
806 S.E.2d 365 (Court of Appeals of North Carolina, 2017)
State v. Arrington
819 S.E.2d 329 (Supreme Court of North Carolina, 2018)

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Bluebook (online)
State v. Crisp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-crisp-ncctapp-2021.