State v. Cromartie

CourtCourt of Appeals of North Carolina
DecidedDecember 3, 2025
Docket25-5
StatusUnpublished

This text of State v. Cromartie (State v. Cromartie) 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. Cromartie, (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An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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. COA25-5

Filed 3 December 2025

Durham County, No. 21CR054184-310

STATE OF NORTH CAROLINA

v.

MEREDITH DELYNN CROMARTIE, JR.

Appeal by Defendant from judgment entered 23 August 2022 by Judge Michael

J. O’Foghludha in Durham County Superior Court. Heard in the Court of Appeals 24

September 2025.

Attorney General Jeff Jackson, by Special Deputy Attorney General Sarah N. Cibik, for the State.

Patterson Harkavy LLP, by Paul E. Smith, for the Defendant.

WOOD, Judge.

Meredith Delynn Cromartie, Jr. (“Defendant”) appeals from a jury verdict

finding him guilty of second-degree kidnapping. After failing to enter a timely oral

or written notice of appeal, Defendant filed a petition for writ of certiorari to this

Court. On 19 April 2023, Defendant’s petition was granted, thus the matter is now STATE V. CROMARTIE

Opinion of the Court

before us on the merits. Defendant raises three issues on appeal. First, Defendant

argues the trial court erred by requiring him to wear a visible ankle restraint

throughout trial. Second, Defendant argues he received ineffective assistance of

counsel after he appeared at trial in an ankle restraint despite the trial court granting

a pre-trial motion to allow Defendant to appear in court without restraints. Third,

Defendant argues the trial court erred in admitting evidence of prior incidents of

alleged misconduct. For the reasons stated herein, we find Defendant received a fair

trial free from error and dismiss his ineffective assistance of counsel argument

without prejudice.

I. Factual and Procedural Background

On 19 August 2021, Defendant’s former girlfriend, Cristal Perez (“Perez”),

found semi-nude photos taken of another woman atop her bed on a camera that

belonged to Defendant. Upset about the photos, Perez packed a bag of clothing,

turned her cellphone off so Defendant could not track her location or reach her, and

drove to her mother’s home in Durham. Through camera footage and witness

testimony the evidence tended to show the following chain of events. Perez was

parked in the driveway of her mother’s home when Defendant pulled up and parked

his vehicle in the street blocking the driveway. Defendant got out of his vehicle, ran

up behind Perez, who was walking in the opposite direction of him trying to get inside

her mother’s house, and grabbed her arm. Defendant and Perez engaged in a heated

discussion. Defendant repeatedly grabbed at her until he was able to get ahold of her

-2- STATE V. CROMARTIE

from behind, pick her up, and carry her toward his vehicle. Perez kicked her feet into

the air while Defendant carried her to his vehicle. While still holding onto Perez,

Defendant opened the driver’s side door of his vehicle and attempted to force her into

it while her mother tried to stop him. Perez resisted by placing her feet up on the

side of the vehicle but Defendant succeeded in forcing her into his vehicle, then stood

in the door to block her exit. Perez testified that Defendant hit her during the

struggle and to prevent him from driving away with her, she took the keys out of the

ignition and threw them. Further, Perez testified she was not free to leave the vehicle

and was “100 percent trapped.” Police arrived, and after speaking with Defendant,

Perez, Perez’s mother, and other witnesses, arrested Defendant for kidnapping.

On 7 September 2021, Defendant was indicted on the charges of second-degree

kidnapping and assault on a female. Prior to trial on 29 December 2021, Defendant

filed motions requesting, among other things, that pursuant to Rule 403 and 404(b)

of the North Carolina Rules of Evidence, the trial court prohibit “the State from

mentioning or eliciting from any witness any alleged acts of prior misconduct on the

part of the defendant or any reference to the defendant’s past criminal record.”

Additionally, Defendant requested that the trial court,

direct the Sheriff or his deputies to remove any and all restraints from the defendant while he is in trial or in the alternative to hold the hearing required and to make specific findings of fact on the record as to why this particular defendant is required to be restrained during trial.

-3- STATE V. CROMARTIE

The trial court granted Defendant’s motion to allow him to wear city clothes and

appear without restraints during trial.

On 26 August 2022, a Durham County jury found Defendant guilty of second-

degree kidnapping and not guilty of assault on a female. Defendant was found to be

a prior felony record level II and sentenced in the aggravated range to 36 to 56 months

of imprisonment.

II. Analysis

Defendant raises three arguments on appeal. First, Defendant argues the trial

court erred by requiring him to appear throughout trial in a visible ankle restraint.

Second, Defendant argues he received ineffective assistance of counsel because trial

counsel failed to object to the ankle restraint. Third, Defendant argues the trial court

erred by admitting evidence of prior incidents of alleged misconduct.

A. Restraints

Defendant argues the trial court abused its discretion by subjecting him to

appear in an ankle restraint in the presence of the jury because there was no special

need for him to be restrained. Additionally, Defendant argues N.C. Gen. Stat. § 15A-

1031 required the trial court to give him an opportunity to object to the restraint and

to instruct the jurors not to consider the restraint when weighing evidence or

determining guilt. N.C. Gen. Stat. § 15A-1031 states:

A trial judge may order a defendant or witness subjected to physical restraint in the courtroom when the judge finds the restraint to be reasonably necessary to maintain order,

-4- STATE V. CROMARTIE

prevent the defendant’s escape, or provide for the safety of persons. If the judge orders a defendant or witness restrained, he must:

(1) Enter in the record out of the presence of the jury and in the presence of the person to be restrained and his counsel, if any, the reasons for his action; and

(2) Give the restrained person an opportunity to object; and

(3) Unless the defendant or his attorney objects, instruct the jurors that the restraint is not to be considered in weighing evidence or determining the issue of guilt.

If the restrained person controverts the stated reasons for restraint, the judge must conduct a hearing and make findings of fact.

N.C. Gen. Stat. § 15A-1031 (emphasis added).

In contrast, the State argues N.C. Gen. Stat. § 15A-1031 does not apply to the

case at hand because the trial court did not order Defendant to be restrained at trial

and the issue is not preserved for appellate review because trial counsel did not object

to Defendant wearing the ankle restraint. We agree.

Our Supreme Court and this Court have “held that failure to object to

shackling waives ‘any error which may have been committed.’” State v. Sellers, 245

N.C. App. 556, 558, 782 S.E.2d 86, 88 (2016) (quoting State v.

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Related

State v. Braswell
324 S.E.2d 241 (Supreme Court of North Carolina, 1985)
State v. Thompson
604 S.E.2d 850 (Supreme Court of North Carolina, 2004)
State v. Tolley
226 S.E.2d 353 (Supreme Court of North Carolina, 1976)
State v. Buckner
527 S.E.2d 307 (Supreme Court of North Carolina, 2000)
State v. Sellers
782 S.E.2d 86 (Court of Appeals of North Carolina, 2016)
State v. Edgar
777 S.E.2d 766 (Court of Appeals of North Carolina, 2015)

Cite This Page — Counsel Stack

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