State v. Hocutt

CourtCourt of Appeals of North Carolina
DecidedJuly 5, 2023
Docket22-851
StatusPublished

This text of State v. Hocutt (State v. Hocutt) 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. Hocutt, (N.C. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA22-851

Filed 05 July 2023

Wayne County, No. 20 CRS 51147

STATE OF NORTH CAROLINA

v.

CALVIN RAY HOCUTT, Defendant.

Appeal by Defendant from judgment entered 17 February 2022 by Judge

William W. Bland in Wayne County Superior Court. Heard in the Court of Appeals

25 April 2023.

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

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

RIGGS, Judge.

Defendant Calvin Ray Hocutt appeals from a judgment entered after a jury

found him guilty of felony cruelty to an animal. Mr. Hocutt contends, among other

arguments, that the trial court committed plain error in admitting written hearsay

as substantive evidence when: (1) the eyewitness who gave the written statement

testified at trial that he was unable to remember the most incriminating portions of

that statement; (2) that same witness testified he was drunk, legally blind, and

suffered from short-term memory issues at the time the statement was made; and (3) STATE V. HOCUTT

Opinion of the Court

the admission of the statement as substantive evidence and subsequent publication

to the jury was contrary to the North Carolina Rules of Evidence and so prejudicial

as to warrant a new trial. The State disagrees, countering that the written statement

was admissible under the hearsay exception found in Rule 803(5), which allows for

the admission of recorded hearsay “concerning a matter about which a witness once

had knowledge but now has insufficient recollection to enable him to testify fully and

accurately . . . .” N.C. R. Evid. 803(5) (2021). Because we hold that the State failed

to establish the necessary foundation to admit the disputed hearsay evidence under

Rule 803(5), and because said hearsay was the only evidence introduced tending to

show Mr. Hocutt as the perpetrator of the crime, we agree with Defendant that the

trial court plainly erred and order a new trial.

I. FACTUAL AND PROCEDURAL HISTORY

On 21 March 2022, Michael Lozier and his father, Thomas “Tommy” Lozier,

each lived in adjacent single-wide motorhomes that they rented from their neighbor,

Jean “Rambo” Gelin, in Dudley, North Carolina. Michael was in his room that

afternoon when he received a phone call from his stepmother asking him to come

outside because she had heard a gunshot in the neighborhood. He met his father,

who was drunk, in their shared driveway; the two did not think much of the event,

as gunshots were common in the neighborhood.

Rambo returned home that evening after dark. One of his dogs, Campbell, was

not in his usual place by Rambo’s backdoor and, on the following morning, Rambo

-2- STATE V. HOCUTT

received a text message from Tommy’s wife that Campbell had been shot the day

before. Rambo met with Tommy and Michael in Rambo’s front yard, and Tommy told

Rambo that Mr. Hocutt had shot Campbell. Rambo called the Wayne County Sheriff’s

Department at Tommy’s urging, and Deputy Brandon Elrod responded to the

shooting.

When Deputy Elrod arrived, he met Michael, Tommy, and Rambo inside

Rambo’s fenced front yard. Campbell’s body was also in the front yard, and Deputy

Elrod observed a small entry wound in the dog’s chest. A search of the area for other

evidence, such as shell casings, proved unsuccessful. Tommy did offer to give a

statement; however, that statement was dictated to his son because Tommy could not

read or write. Michael transcribed the following statement, as signed by Tommy:

Yesterday about 5:00 pm I was in the nabors [sic] yard an [sic] I herd [sic] a gun shot at Rambo’s house (121/Brookterrace) an [sic] seen [Mr. Hocutt] runing [sic] away from Rambo’s front gate with a rifle (22) back to his house[.] [Mr. Hocutt] then told me he shot the dog in the chest an [sic] killed him[.] I herd [sic] a real loud wine [sic] an [sic] then it stoped [sic] all together [sic].

At the time Tommy signed the document, no one read it back to him to confirm its

accuracy. The document also did not disclose that Tommy was both legally blind and

drunk at the time he saw Mr. Hocutt running from Rambo’s house.

Detective Milburn Powers interviewed Rambo, Tommy, and Michael later that

week. Detective Powers also obtained and executed a search warrant for Mr. Hocutt’s

home in an attempt to locate a small-caliber rifle, but no evidence was obtained as a

-3- STATE V. HOCUTT

result. Detective Powers subsequently learned that Mr. Hocutt did own such a rifle,

but that it had been reported stolen on 4 April 2020.

Mr. Hocutt was indicted for felony cruelty to animals on 1 March 2021. Trial

began on 15 February 2022 and, after jury selection, the trial court held a voir dire

hearing regarding Tommy’s recorded out-of-court statement. Michael testified first,

telling the trial court that he transcribed his father’s statement because his father

could not read or write. He further testified that, while the trial court was on break

after jury selection, he had spoken with Tommy, Mr. Hocutt, and Mr. Hocutt’s father,

Joshua Smith,1 about Tommy’s anticipated testimony. In that conversation:

[Tommy] was saying to [Mr. Smith], . . . it weren’t fair, you know . . . .

....

[T]hat Rambo was kind of like, ah—you know, pushing him towards, you know . . . making it that, you know, the event . . . , whatever, you know, the statement that he wrote right there, he said he felt that he, you know, he was kind of pushed into making that statement by the deputy and Rambo and whoever, you know[.]

Michael then confirmed for the trial court that he was going to testify truthfully and

without pressure from anyone else.

Tommy’s voir dire testimony followed, during which he stated that his written

statement was “pretty much [accurate] or close to it.” He acknowledged that he

1 Mr. Smith was also Tommy’s co-worker.

-4- STATE V. HOCUTT

signed it; when asked if his son wrote down what he had said, Tommy testified “I

guess. I guess he did because he’s sitting in the front seat and I’m in the back seat.”

He also testified that he was drunk when he saw Mr. Hocutt the day before, drunk at

the time he gave the statement, and that he and Mr. Smith wanted to bring that to

the prosecutor’s attention. On cross-examination, Tommy testified that the written

statement was never read back to him because “I had trust in my son that he

was . . . filling it out as he was listening to it, I guess.” Like Michael, he assured the

trial court that he would testify truthfully, to the best of his recollection, and without

influence.

Once the jury returned to the courtroom, the State called Michael as its first

witness. Michael testified consistent with the above recitation of the facts, and

Tommy’s written statement was admitted into evidence without objection during this

testimony. He further testified that Tommy was drunk on a daily basis, including on

the dates in question, due to several tragic deaths in the family.

Tommy testified next. When asked if he saw Mr. Hocutt carrying anything on

the day of the shooting, Tommy testified:

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Related

State v. Love
576 S.E.2d 709 (Court of Appeals of North Carolina, 2003)
State v. Spinks
523 S.E.2d 129 (Court of Appeals of North Carolina, 1999)
State v. Waddell
527 S.E.2d 644 (Supreme Court of North Carolina, 2000)
State v. Lawrence
723 S.E.2d 326 (Supreme Court of North Carolina, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Hocutt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hocutt-ncctapp-2023.