State v. Hicks

CourtSupreme Court of North Carolina
DecidedSeptember 1, 2023
Docket136PA22
StatusPublished

This text of State v. Hicks (State v. Hicks) is published on Counsel Stack Legal Research, covering Supreme Court 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. Hicks, (N.C. 2023).

Opinion

IN THE SUPREME COURT OF NORTH CAROLINA

No. 136PA22

Filed 1 September 2023

STATE OF NORTH CAROLINA

v. WENDY DAWN LAMB HICKS

On discretionary review pursuant to N.C.G.S. § 7A-31 of a unanimous decision

of the Court of Appeals, 283 N.C. App. 74 (2022), reversing a judgment entered on 12

December 2019 by Judge V. Bradford Long in Superior Court, Randolph County, and

remanding for a new trial. Heard in the Supreme Court on 25 April 2023.

Joshua H. Stein, Attorney General, by Michael T. Henry, Assistant Attorney General, for the State-appellant.

Marilyn G. Ozer for defendant-appellee.

EARLS, Justice.

Defendant Wendy Dawn Lamb Hicks was convicted of second-degree murder

after she shot and killed Caleb Adams in her home. Ms. Hicks and Mr. Adams had a

tumultuous relationship, and on the day of the murder, Ms. Hicks had warned Mr.

Adams by text message not to come to her residence. He ignored that warning and

came anyway, precipitating a confrontation between them that left him dead from

two gunshot wounds to his back. At trial, the jury was instructed on self-defense, the

defense of habitation, and the aggressor doctrine. Ms. Hicks contends, and the Court STATE V. HICKS

Opinion of the Court

of Appeals agreed, that the evidence did not support an instruction on the aggressor

doctrine.

In this case we are again confronted with the proper application of North

Carolina’s “castle doctrine” statute, which establishes that a person in their home,

motor vehicle, or workplace is presumed to have held “a reasonable fear of imminent

death or serious bodily harm” when using deadly force to repel an unlawful intruder.

N.C.G.S. § 14-51.2(b) (2021); see also State v. Benner, 380 N.C. 621, 632, 2022-NCSC-

28, ¶ 26 (“[W]hile the enactment of N.C.G.S. § 14-51.2 was not ‘intended to repeal or

limit any other defense that may exist under the common law,’ we have held that the

enactment of N.C.G.S. § 14-51.3 has supplanted the common law right to perfect self-

defense to the extent that it addresses a particular issue . . . .” (quoting N.C.G.S. § 14-

51.2(g))); State v. McLymore, 380 N.C. 185, 195, 2022-NCSC-12 ¶ 23 (“Commonly

known as the ‘Stand Your Ground’ Law, the Act ‘restate[d] the law [of self-defense]

in some respects and broaden[ed] it in others.’ ” (alterations in original) (quoting John

Rubin, The New Law of Self Defense?, North Carolina Criminal Law: A UNC School

of Government Blog (Aug. 17, 2011), https://nccriminallaw.sog.unc.edu/the-new-law-

of-self-defense)); State v. Coley, 375 N.C. 156, 162 (2020) (“Viewing the evidence at

trial in the light most favorable to defendant in order to determine whether the

evidence was competent and sufficient to support the jury instructions on self-defense

and the defense of habitation, we conclude that defendant was entitled to both

instructions.”).

-2- STATE V. HICKS

As a legal matter, the Court of Appeals held that the statutory presumption

entitling a person within their own home to use deadly force regardless of the

character of the assault against them remains subject to the limitation that a

defendant is not entitled to use self-defense if they were the aggressor in the

situation. See State v. Hicks, 283 N.C. App. 74, 81, 2022-NCCOA-263 ¶ 22. Ms. Hicks

does not argue that this is incorrect. Instead, Ms. Hicks maintains that there was no

evidence in the case from which a jury could find that she was the aggressor in these

circumstances.1 Thus, our only task is to determine whether, in the light most

favorable to the State, the evidence was sufficient to support a jury finding that Ms.

Hicks was the aggressor when she shot and killed Mr. Adams. The Court of Appeals

erroneously considered the evidence in the light most favorable to Ms. Hicks and

wrongly concluded that the evidence was insufficient. We hold that the evidence was

sufficient to give the aggressor doctrine instruction, find no error in the trial court’s

decision to give the instruction, and therefore reverse the decision of the Court of

Appeals.

I. Background

A. Evidence at Trial

1 At trial, during the charge conference, defense counsel objected to the aggressor

instruction on the ground that there was insufficient evidence to demonstrate that Ms. Hicks was the aggressor. In closing argument, defense counsel argued to the jury that if Ms. Hicks was defending her home, believing that Mr. Adams was there to harm her, then “it doesn’t matter who the aggressor was.”

-3- STATE V. HICKS

Wendy Hicks and Caleb Adams first met in September 2015 through their

employment at Dart Container. Within a few weeks, they developed an intimate

relationship that lasted until Mr. Adams’s death on 13 June 2017. Mr. Adams was

married to Dana Adams, and he remained so until his death. Ms. Hicks was also

married but divorced her husband in April 2016. Both Ms. Hicks and Mr. Adams

maintained intimate relationships with other individuals besides each other and

their spouses. Ms. Hicks made efforts to keep her other relationships secret from Mr.

Adams.

Ms. Hicks and Mr. Adams’s relationship was tumultuous; they had several

vehement arguments. They frequently referred to each other in a vulgar manner, as

demonstrated in their text messages. Mr. Adams was never violent with his wife,

though he used coarse language, which his wife attributed to his picking up truck

drivers’ “lingo.”

In early 2017, Mr. Adams introduced Ms. Hicks to methamphetamine. Mrs.

Adams testified that using methamphetamine affected Mr. Adams’s emotional state.

Specifically, she stated that methamphetamine use caused Mr. Adams to become

angry. Mr. Adams stored the methamphetamine at Ms. Hicks’s house, and she would

at times pick up drugs for him.

When Mr. Adams’s methamphetamine supplier was arrested, Ms. Hicks

introduced Mr. Adams to a new supplier, a man named Doug. Ms. Hicks testified that

after a while, she began performing oral sex on Doug at Mr. Adams’s instruction to

-4- STATE V. HICKS

pay for the methamphetamine. At some point, Ms. Hicks began a separate, intimate

relationship with Doug, which she tried to keep secret from Mr. Adams.

The relationship between Ms. Hicks and Mr. Adams became even more

strained around 23 May 2017, when Ms. Hicks posted a photo to Facebook of her and

Mr. Adams kissing, which was seen by Mr. Adams’s wife. Mrs. Adams confronted Mr.

Adams who denied that he was the man in the picture. Ms. Hicks then started placing

anonymous calls to Mrs. Adams. On 8 June 2017, she called Mrs. Adams around 7:00

a.m., blocking the caller ID, and disclosed that Mr. Adams was having an affair and

consuming drugs. Ms. Hicks called again later that day at about 2:00 p.m. and asked

Mrs. Adams if she knew that Mr. Adams had been involved in a wreck.

During the week of 12 June 2017, Ms. Hicks and Mr. Adams had several

arguments, including one about the photo she had posted to Facebook. Ms. Hicks also

testified that Mr. Adams was upset and angry because his supplier had raised the

price of methamphetamine and he was concerned about owing people money.

On the morning of 12 June 2017, Mr. Adams went to Ms. Hicks’s residence, a

trailer where she lived with her seventeen-year-old daughter, April. At trial, April

testified that she was awakened that morning by her mother and Mr.

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State v. Hicks, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hicks-nc-2023.