State v. Graves

CourtCourt of Appeals of North Carolina
DecidedNovember 5, 2024
Docket24-308
StatusPublished

This text of State v. Graves (State v. Graves) 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. Graves, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-308

Filed 5 November 2024

Cabarrus County, No. 21CRS51517

STATE OF NORTH CAROLINA

v.

NOLAN KIEL GRAVES

Appeal by defendant from judgment entered 21 July 2023 by Judge Eric C.

Morgan in Cabarrus County Superior Court. Heard in the Court of Appeals 9 October

2024.

Attorney General Joshua H. Stein, by Special Deputy Attorney General, Robert C. Montgomery, for the State.

Law Office of Christopher J. Heaney, by Christopher J. Heaney, for the defendant-appellant.

TYSON, Judge.

Nolan K. Graves (“Defendant”) appeals from judgment entered upon a jury’s

verdict and conviction of first-degree murder. We discern no error.

I. Background

On 24 March 2021, law enforcement officers were looking for Lena Morgan

(“Lena”) and went to a hotel located in Kannapolis, North Carolina. The officers were

seeking to serve a pending warrant on Lena’s sister, Mackenzie Morgan

(“Mackenzie”). While there, officers observed an SUV pull into the hotel parking lot. STATE V. GRAVES

Opinion of the Court

The driver of the SUV was drinking something from a brown paper bag. The driver

was later identified as Defendant.

The officers approached the SUV, smelled marijuana, and asked the occupants

inside of the SUV to exit. Defendant and a passenger, later identified as Frederick

Baldwin (“Baldwin”), exited the vehicle. The Officers observed a firearm present

inside the SUV. Defendant and Baldwin were arrested and handcuffed. Lena was

not present when Defendant was arrested.

During the encounter, Mackenzie came out of the hotel room. Officers did not

initially arrest Mackenzie because they mistakenly believed they were executing the

arrest warrant for Lena instead of Mackenzie. After the officers realized the warrant

was for Mackenzie, and not Lena, they arrested Mackenzie.

While watching Defendant for at least two hours, an officer heard him say once

that Mackenzie, but not Lena, had set him up for arrest. The officer did not hear him

say anything about Lena. The officer assured Defendant he had not been set up, but

he had been in the wrong place at the wrong time. Defendant left jail on 9 April 2021,

wearing a bondsman-required ankle monitor.

On 11 April 2021, someone with the username “Jpc Cartel” sent a Facebook

social media message stating: “Got popped. Stay away from Mackenzie Morgan and

[L]ena [M]organ.” On 13 April 2021, the same user sent the message: “Lena [M]organ

got me busted.” The record does not identify the messages’ recipients.

Lena was charging her phone outside a convenience store on 18 April 2021.

-2- STATE V. GRAVES

Surveillance cameras captured someone ride by the store driving a red vehicle,

shooting at and murdering Lena. The convenience store clerk believed Defendant

was the shooter based upon the video footage and having seen Defendant come inside

the convenience store several times a week in the year before the shooting.

After the shooting, a law enforcement officer reached Defendant’s bondsman,

who had access to Defendant’s ankle monitor data. Later that afternoon, an officer

arrested Defendant. Defendant possessed a key inside his pocket to a red Toyota

Camry parked nearby.

At trial, the State introduced the Facebook messages regarding Lena and

Mackenzie. The State offered a “Certificate of Authenticity of Domestic Records of

Regularly Conducted Activity” from Facebook, instead of using an affidavit signed

before a notary or a testifying witness, to authenticate the messages. An individual

named “Adeline Ballard,” signed the statement as Facebook’s “Custodian of Records.”

The certificate included a declaration “under penalty of perjury that the

foregoing certification is true and correct to the best of [the signatory’s] knowledge.”

Defense counsel objected to the Facebook messages on constitutional and evidentiary

grounds and argued the documents were not properly authenticated and inadmissible

hearsay. The trial court overruled Defendant’s objections.

Testimony during the trial tended to show Defendant had another person rent

a red car for him on 16 April 2021. Defendant was given the keys. The convenience

store clerk also identified Defendant as the driver of the red vehicle, which drove by

-3- STATE V. GRAVES

the convenience store. The clerk testified Defendant typically had a handgun when

he came into the store. The State also offered evidence tending to show data from the

ankle monitor Defendant was wearing placed Defendant at a street intersection

adjacent to the convenience store at 12:52 p.m. on 18 April 2021, the approximate

place and time when Lena was shot and murdered.

The jury found Defendant to be guilty of first-degree murder. The trial court

sentenced him to life imprisonment without possibility of parole. Defendant orally

tendered notice of appeal.

II. Hearsay

Defendant argues trial court erred in admitting hearsay evidence of the

Facebook messages under the business records exception without allowing Defendant

to confront the person who had authenticated the evidence.

A. Standard of Review

Our caselaw is mixed regarding the proper standard of review to apply to the

admission of evidence over a party’s hearsay objections, particularly when the

hearsay objection relates to the authenticity of the proffered evidence:

Generally, we review trial court decisions to admit or exclude evidence for abuse of discretion. Brown v. City of Winston-Salem, 176 N.C. App. 497, 505, 626 S.E.2d 747, 753 (2006). But we review de novo a trial court’s admission of evidence over a party’s hearsay objection. State v. Hicks, 243 N.C. App. 628, 638, 777 S.E.2d 341, 348 (2015). However, there is an apparent conflict in our caselaw as to our standard of review when the hearsay objection is rooted in the authentication of the proffered

-4- STATE V. GRAVES

evidence. Under one line of cases, we have reviewed authentication of documentary evidence under the same de novo standard as the trial court’s admission of such evidence. See State v. Crawley, 217 N.C. App. 509, 515, 719 S.E.2d 632, 637 (2011) (“A trial court’s determination as to whether a document has been sufficiently authenticated is reviewed de novo on appeal as a question of law.”) (citing State v. Owen, 130 N.C. App. 505, 510, 503 S.E.2d 426, 430 (1998)); State v. Watlington, 234 N.C. App. 580, 590, 759 S.E.2d 116, 124 (2014) (citing Crawley). In other cases, we have reviewed similar rulings for abuse of discretion. See In re Foreclosure by Goddard & Peterson, PLLC, 248 N.C. App. 190, 198, 789 S.E.2d 835, 842 (2016); State v. Mobley, 206 N.C. App. 285, 696 S.E.2d 862 (2010) (reviewing for abuse of discretion trial court’s admission of jailhouse phone call over authentication objection).

State v. Hollis, __ N.C. App. __, __, 905 S.E.2d 265, 267-68 (2024).

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Alford v. . McCormac
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State v. McKiver
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In re S.W.
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In re S.D.J.
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State v. Crawley
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State v. Graves, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-graves-ncctapp-2024.