State v. Crooks

CourtCourt of Appeals of North Carolina
DecidedNovember 17, 2020
Docket20-146
StatusPublished

This text of State v. Crooks (State v. Crooks) 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. Crooks, (N.C. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA20-146

Filed: 17 November 2020

Catawba County, No. 17 CRS 4801

STATE OF NORTH CAROLINA

v.

NOWLIN POWELL CROOKS

Appeal by defendant from judgments entered 19 September 2019 and 20

September 2019 by Judge Kevin M. Bridges in Catawba County Superior Court.

Heard in the Court of Appeals 8 September 2020.

Attorney General Joshua H. Stein, by Assistant Attorney General Donna B. Wojcik, for the State.

Stephen G. Driggers for defendant.

DIETZ, Judge.

Defendant Nowlin Crooks appeals his conviction for possession of a firearm by

a felon, arguing that he was entitled to a jury instruction on the defense of

justification. He also challenges the civil judgment entered against him for the

attorneys’ fees of his court-appointed counsel.

As explained below, the trial court properly declined to instruct on justification

because undisputed trial evidence showed that Crooks continued to possess the

firearm well after any potential threat had ended despite many options for STATE V. CROOKS

Opinion of the Court

relinquishing possession. We therefore find no error in the trial court’s criminal

judgment.

The State concedes error with respect to the civil judgment for attorneys’ fees

because Crooks was not provided sufficient opportunity to be heard. We agree and

therefore vacate that judgment and remand for further proceedings.

Facts and Procedural History

This case involves two versions of events so deeply inconsistent that telling

both accounts is impractical. Because this appeal concerns the sufficiency of evidence

supporting a jury instruction on justification, we recount the version of events

described by Defendant Nowlin Crooks, which is the more favorable version for his

argument, and ignore the accounts of the State’s witnesses, who offered a

dramatically different version of events. State v. Mercer, 373 N.C. 459, 464, 838

S.E.2d 359, 363 (2020).

In August 2017, Crooks was walking to the store when he passed by David

Harrison’s home in a trailer park. Harrison was on his porch and invited Crooks

inside for a drink. Crooks and Harrison began drinking bourbon. The two men had

seven or eight shots of bourbon.

While the two men were drinking, Harrison suddenly stood up while only a few

feet from Crooks, pulled a pistol out of his pocket, pointed it toward the wall near

Crooks, and fired a shot at the wall. Before pulling out the gun, Harrison had not

-2- STATE V. CROOKS

threatened Crooks in any way. Harrison also did not appear angry or upset. As soon

as Harrison fired the shot at the wall, Crooks stood up, grabbed the pistol from

Harrison, and left the trailer.

Crooks then went looking for a woman named Karen Tucker, who was dating

his father. Crooks believed that Tucker likely would be sober and safely could take

the gun from him. Crooks went to a nearby trailer and knocked on the door. Karen

Tucker’s daughter Lacey answered the door, but Crooks did not give the gun to Lacey

because Crooks worried that she was high on drugs. Lacey’s sister Echo also was

present in the trailer. Echo told Crooks that Karen was nearby in Crooks’s father’s

trailer. Crooks testified that he did not try to go to his father’s trailer after learning

that Karen was there because the “sheriffs got over there.” Instead, Crooks waited

with the gun in his possession, in the presence of Lacey and Echo, until Karen arrived.

Crooks then gave Karen the gun.

Law enforcement who responded to the trailer park found a number of

intoxicated people outside the trailers, including Harrison and Crooks. Harrison

claimed that Crooks stole the gun from his living room while Harrison was in the

bathroom. Karen Tucker’s daughter Lacey told officers that Crooks pounded on the

door to her trailer and, when she opened it, Crooks pointed the gun at her and went

into the kitchen of the trailer with her while holding the gun to her head.

Crooks told the officers he took the gun from Harrison after Harrison held it

-3- STATE V. CROOKS

close to him and fired a shot at the ceiling. None of the other witnesses heard any gun

shots. Officers searched the inside of Harrison’s trailer and did not find any bullet

holes but did find a shell casing sitting on a coffee table.

The State later charged Crooks with a number of offenses, including possession

of a firearm by a felon. At trial, Crooks requested a jury instruction on the defense of

justification. The trial court denied the request. The jury found Crooks guilty of

possession of a firearm by a felon. The trial court sentenced Crooks to 25 to 39 months

in prison and also entered a civil judgment of $2,220 against Crooks for the attorneys’

fees of his court-appointed counsel. Crooks filed a timely pro se notice of appeal that

had a number of procedural defects. Crooks never served the notice of appeal on the

State.

Crooks later petitioned for a writ of certiorari to remedy the defects with his

notice of appeal. The State does not oppose the petition. In our discretion, we allow

the petition and issue a writ of certiorari to address the merits of this appeal. See

N.C. R. App. P. 21.

Analysis

I. Jury instruction on defense of justification

Crooks first argues that the trial court erred by denying his request for a jury

instruction on the defense of justification. Ordinarily, when a defendant requests

specific jury instructions, the trial court “must give the instructions requested, at

-4- STATE V. CROOKS

least in substance, if they are proper and supported by the evidence.” State v.

Edwards, 239 N.C. App. 391, 392, 768 S.E.2d 619, 620 (2015). On appeal, we review

de novo whether the evidence supported the requested instruction. Id. at 393, 768

S.E.2d at 621.

The doctrine of justification is available as a defense to the charge of possession

of a firearm by a felon. State v. Mercer, 373 N.C. 459, 463, 838 S.E.2d 359, 362 (2020).

The justification defense is appropriate when, taken in the light most favorable to the

defendant, there is evidence of each of the following factors:

(1) that the defendant was under unlawful and present, imminent, and impending threat of death or serious bodily injury; (2) that the defendant did not negligently or recklessly place himself in a situation where he would be forced to engage in criminal conduct; (3) that the defendant had no reasonable legal alternative to violating the law; and (4) that there was a direct causal relationship between the criminal action and the avoidance of the threatened harm.

Id. at 464, 838 S.E.2d at 363.

Here, the evidence at trial was insufficient to establish the first factor of the

Mercer test. Even assuming that Harrison’s drunken act of firing his pistol into the

wall or ceiling of his house represented an “impending threat of death or serious

bodily injury” to Crooks, that threat was gone once Crooks left Harrison’s trailer with

the gun. But after that point, undisputed evidence showed that Crooks continued to

possess the gun. He admitted at trial that he could have disposed of the gun in various

-5- STATE V. CROOKS

ways, such as throwing it on a roof or hiding it somewhere until police arrived. More

importantly, Crooks testified that, once he took the gun to the Tuckers’ home and

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Related

State v. Craig
606 S.E.2d 387 (Court of Appeals of North Carolina, 2005)
State v. Friend
809 S.E.2d 902 (Court of Appeals of North Carolina, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Crooks, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-crooks-ncctapp-2020.