State v. French

CourtCourt of Appeals of North Carolina
DecidedOctober 6, 2020
Docket19-968
StatusPublished

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

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA19-968

Filed: 6 October 2020

Lincoln County, Nos. 16CRS054353, 16CRS054354, 16CRS054359, 17CRS000336

STATE OF NORTH CAROLINA

v.

TIMOTHY DAVID FRENCH, Defendant.

Appeal by Defendant from judgment entered 29 November 2017 by Judge

Casey M. Viser in Lincoln County Superior Court. Heard in the Court of Appeals on

26 August 2020.

Attorney General Joshua H. Stein, by Special Deputy Attorney Brenda Menard, for the State.

Appellate Defender Glenn Gerding, by Assistant Appellate Defender James R. Grant, for Defendant-Appellant.

INMAN, Judge.

A thief who led law enforcement officers on a high-speed chase after

discovering a three-year-old child in the back seat of the truck he had stolen was

properly convicted of larceny of a motor vehicle, first-degree kidnapping, and

abduction of a child.

Timothy David French (“Defendant”) petitions this Court from a judgment

following a jury verdict finding him guilty of larceny of a motor vehicle, possession of STATE V. FRENCH

Opinion of the Court

stolen property, abduction of a child, first-degree kidnapping, and obtaining habitual

felon status. Defendant asserts that the trial court erred by denying his motion to

dismiss the child abduction charge when the State failed to show evidence of

Defendant’s intent to abduct the child, by instructing the jury on theories of

kidnapping not contained in the indictment, and by entering a judgment on verdicts

for both larceny and possession of the same stolen property.

After careful review, we hold that Defendant has failed to show error in the

denial of Defendant’s motion to dismiss as to the abduction charge, or that the trial

court committed plain error by instructing on theories for kidnapping not alleged in

the indictment. The State concedes and we hold that the trial court erred by entering

judgment on verdicts for both larceny and possession of the same stolen property.

I. FACTUAL AND PROCEDURAL HISTORY

The evidence presented at trial tends to show the following:

On the morning of 17 December 2016, a three-year-old child was strapped into

a car seat in the back of his father’s truck at a gas station on Gastonia Highway. The

two were on their way to a parade. The father ran inside to make a purchase. The

truck remained in the father’s view while he was inside the store, but when he looked

away for “a split second,” Defendant got into the driver’s seat of the truck and sped

off. The child’s father ran outside screaming that his son was still in the truck and a

bystander promptly called 911.

-2- STATE V. FRENCH

Police arrived at the gas station, obtained a description of the truck and the

child, and sent a message to law enforcement to be on the lookout for both. An officer

nearby saw a vehicle matching the description circulated by law enforcement and

began to follow the truck. After calling in the license plate number, he confirmed it

was the truck with the child likely still inside. Defendant drove normally until the

officer turned on his blue lights. Defendant then accelerated, passing the car in front

of him on the three-lane-road. Defendant proceeded to lead police on a high-speed

chase, exceeding 100 miles-per-hour, crossing the median several times, and

traversing state lines.

During the chase, Defendant called 911. He identified himself as the driver of

the truck and told the operator there was a child in the back seat of the vehicle.

Defendant claimed he mistakenly thought the truck was his “buddy’s” and that this

was all a “prank” that had gone “south.” Defendant tried to bargain with the operator

because he “didn’t want the kid to get hurt,” saying he would let “the kid” out if the

officers stopped chasing him. He refused to pull over despite the operator’s repeated

pleas to do so. Defendant eventually hung up and continued to drive at excessive

speeds for fifteen more minutes, driving into oncoming traffic at least once.

In total, Defendant drove approximately 23 miles for at least 20 minutes with

the child in the truck before jumping a curb and getting stuck in a wooded area.

Defendant attempted to reverse the truck, spinning the wheels. He then tried to

-3- STATE V. FRENCH

escape on foot and was quickly apprehended by law enforcement officers. The child

was still secured in his car seat and “appeared well.” Defendant told officers that he

had been unaware the child was in the truck at the time he initially drove away. He

said he “wanted to make a deal” and provide information about other crimes but did

not make any other statements to arresting officers.

On 8 May 2017, a Lincoln County grand jury indicted Defendant on one count

each of first-degree kidnapping, abduction of a child, larceny of a motor vehicle,

possession of stolen property, and obtaining habitual felon status. At the pre-trial

charge conference, parties agreed to instruct the jury solely on the “removal” theory

for first-degree kidnapping, reflecting the language of the indictment. Defendant’s

trial began on 27 November 2017.

At trial, the prosecutor requested jury instructions on all three theories of

kidnapping––confinement, restraint, and removal–––to which Defendant’s counsel

responded, “I mean, it’s not going to matter to me.” The jury found Defendant guilty

on all charges on 29 November 2017. Defendant then pled guilty to attaining status

as an habitual felon. The trial court consolidated the convictions to a single judgment,

sentenced Defendant to a term of 82 to 159 months of imprisonment, and ordered

Defendant to register as a sex offender for 30 years upon release. Defendant did not

give oral or written notice of appeal. On 7 December 2018, Defendant filed a Petition

for Writ of Certiorari with this Court, which was allowed on 20 December 2018.

-4- STATE V. FRENCH

II. ANALYSIS

A. Defendant’s Motion to Dismiss

Defendant asserts that the trial court erred in denying his motion to dismiss

the child abduction charge because the State did not establish that Defendant acted

with the requisite intent to abduct the child. Defendant also argues that the trial

court committed plain error in failing to instruct the jury on a scienter requirement.

After careful review, we disagree.

We review a trial court’s denial of a motion to dismiss de novo. State v.

McKinnon, 306 N.C. 288, 298, 293 S.E.2d 118, 125 (1982). We consider whether,

viewed in the light most favorable to the State and giving the State the benefit of all

reasonable inferences, the jury was presented with substantial evidence of each

element of the offense charged. State v. Herring, 322 N.C. 733, 738, 370 S.E.2d 363,

367 (1988). Defining the elements of our child abduction statute also presents a

question of law subject to de novo review. State v. Jones, 237 N.C. App. 526, 530, 767

S.E.2d 341, 344 (2014).

Willfulness Requirement in Child Abduction

Defendant argues that the child abduction statute requires the State to show

substantial evidence of Defendant’s “willfulness” in abducting the child. The plain

language of the statute compels us to disagree.

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State v. French, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-french-ncctapp-2020.