State v. Helms

CourtCourt of Appeals of North Carolina
DecidedApril 20, 2021
Docket20-295
StatusPublished

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

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2021-NCCOA-142

No. COA20-295

Filed 20 April 2021

Union County, Nos. 15CRS51369-70

STATE OF NORTH CAROLINA

v.

BOBBY DEWAYNE HELMS

Appeal by Defendant from judgment entered 22 October 2019 by Judge Jeffery

K. Carpenter in Union County Superior Court. Heard in the Court of Appeals 24

February 2021.

Attorney General Joshua H. Stein, by Assistant Attorney General Kristin J. Uicker, for the State-Appellee.

Appellate Defender Glenn Gerding, by Assistant Appellate Defender Amanda S. Zimmer, for Defendant-Appellant.

COLLINS, Judge.

¶1 Defendant appeals from judgment entered upon jury verdicts of guilty of two

counts of first-degree statutory sex offense and two counts of taking indecent liberties

with a child. Defendant contends that errors in the indictments divested the trial

court of jurisdiction. We discern no error.

I. Background STATE V. HELMS

Opinion of the Court

¶2 On 2 April 2015, Defendant was arrested on two counts of first-degree

statutory sex offense with a child under the age of thirteen, file number 15CR51369,

and two counts of taking indecent liberties with a child, file number 15CR51370. On

6 July 2015, he was indicted on all four charges in a separate indictment for each

count of each offense. The indictments for first-degree statutory sex offense were in

file number 15CRS51369 and the indictments for taking indecent liberties with a

child were in file number 15CRS51370. Each indictment was individually file-

stamped and signed by the Assistant Deputy Clerk of Superior Court, and signed and

dated by the Grand Jury Foreperson. Before trial, the State moved to join all four

offenses for trial. Defendant acquiesced to joinder and the trial court granted the

State’s motion.

¶3 The case came on for trial on 24 April 2017 and Defendant was ultimately

convicted of all four offenses. On appeal, this Court issued a split decision discerning

no error. See State v. Helms, 261 N.C. App. 774, 818 S.E.2d 645 (2018) (unpublished).

On appeal, the Supreme Court held that there was insufficient evidence to support

one of the aggravating factors used in sentencing and remanded the case for a new

sentencing hearing. See State v. Helms, 373 N.C. 41, 41-42, 832 S.E.2d 897, 897

(2019). On remand, the trial court arrested judgment on the indecent liberties

convictions and sentenced Defendant to two consecutive sentences of 300 to 420 STATE V. HELMS

months in prison for the first-degree statutory sex offense convictions. Defendant

gave oral notice of appeal.

II. Discussion

¶4 On appeal, Defendant contends that the trial court lacked jurisdiction over one

count of first-degree statutory sex offense and one count of taking indecent liberties

with a child because one indictment for each offense was facially invalid. Specifically,

Defendant argues that one indictment for each offense was facially invalid because

he was charged by separate indictments with identical charging language for the

first-degree statutory sex offenses in file number 15CRS51369, and separate

indictments with identical charging language for the offenses of taking indecent

liberties with a child in file number 15CRS51370.

¶5 As a threshold matter, Defendant’s argument as to the facial validity of his

indictments is properly before this Court, despite his failure to object in the trial court

or to raise this issue on his first appeal. Generally, a defendant waives any appellate

challenges to an indictment when the indictment is not challenged in the trial court.

State v. Call, 353 N.C. 400, 428-29, 545 S.E.2d 190, 208 (2001) (citation omitted); see

also N.C. Gen. Stat. § 15A-952(b)(6) (listing specific pretrial motions defendants must

make prior to arraignment). However, “when an indictment is alleged to be facially

invalid, thereby depriving the trial court of its jurisdiction, it may be challenged at

any time, notwithstanding a defendant’s failure to contest its validity in the trial STATE V. HELMS

court.” Call, 353 N.C. at 429, 545 S.E.2d at 208 (quotation marks and citation

omitted). Accordingly, Defendant’s challenge to his indictments is properly before

this Court

¶6 “A valid bill of indictment is essential to the jurisdiction of the Superior Court

to try an accused for a felony and have the jury determine his guilt or innocence, and

to give authority to the court to render a valid judgment.” State v. Stephenson, 267

N.C. App. 475, 478, 833 S.E.2d 393, 397 (2019) (quotation marks and citation

omitted). An indictment must contain

[a] plain and concise factual statement in each count which, without allegations of an evidentiary nature, asserts facts supporting every element of a criminal offense and the defendant’s commission thereof with sufficient precision clearly to apprise the defendant or defendants of the conduct which is the subject of the accusation.

N.C. Gen. Stat. § 15A-924(a)(5) (2015). An indictment is “constitutionally sufficient

if it apprises the defendant of the charge against him with enough certainty to enable

him to prepare his defense and to protect him from subsequent prosecution for the

same offense.” State v. McGriff, 151 N.C. App. 631, 634, 566 S.E.2d 776, 778 (2002)

(citation omitted). “In general, an indictment couched in the language of the statute

is sufficient to charge the statutory offense.” State v. Blackmon, 130 N.C. App. 692,

699, 507 S.E.2d 42, 46 (1998) (citation omitted). Moreover, it is “generally true tha[t] STATE V. HELMS

an indictment need only allege the ultimate facts constituting the elements of the

criminal offense and that evidentiary matters need not be alleged.” Id.

¶7 “[O]ur statutes permit, and our appellate courts have upheld, the use of short

form indictments in charging a defendant with a sex[] offense and taking indecent

liberties with a child.” State v. Mueller, 184 N.C. App. 553, 558, 647 S.E.2d 440, 445

(2007) (citations omitted). N.C. Gen. Stat. §15-144.2 allows for these “short-form

indictments” and provides:

If the victim is a person under the age of 13 years, it is sufficient to allege that the defendant unlawfully, willfully, and feloniously did engage in a sex offense with a child under the age of 13 years, naming the child, and concluding as aforesaid. Any bill of indictment containing the averments and allegations herein named shall be good and sufficient in law as an indictment for a sex offense against a child under the age of 13 years and all lesser included offenses.

N.C. Gen. Stat. § 15-144.2(b) (2015). Our appellate courts have consistently held that

indictments conforming with this statute also comply with the North Carolina and

the United States Constitution. See, e.g., State v. Wallace, 351 N.C. 481, 505, 528

S.E.2d 326, 342 (2000); State v. Randolph, 312 N.C. 198, 210, 321 S.E.2d 864, 872

(1984); State v. Lowe, 295 N.C.

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Related

State v. Randolph
321 S.E.2d 864 (Supreme Court of North Carolina, 1984)
State v. Call
545 S.E.2d 190 (Supreme Court of North Carolina, 2001)
State v. Wallace
528 S.E.2d 326 (Supreme Court of North Carolina, 2000)
State v. Lowe
247 S.E.2d 878 (Supreme Court of North Carolina, 1978)
State v. Blackmon
507 S.E.2d 42 (Court of Appeals of North Carolina, 1998)
State v. Mueller
647 S.E.2d 440 (Court of Appeals of North Carolina, 2007)
State v. McGriff
566 S.E.2d 776 (Court of Appeals of North Carolina, 2002)
State v. Johnson
801 S.E.2d 123 (Court of Appeals of North Carolina, 2017)
State v. Helms
818 S.E.2d 645 (Court of Appeals of North Carolina, 2018)

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