State v. Holt

CourtCourt of Appeals of North Carolina
DecidedMay 20, 2026
Docket25-560
StatusPublished
AuthorJudge Jefferson Griffin

This text of State v. Holt (State v. Holt) 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. Holt, (N.C. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-560

Filed 20 May 2026

Wake County, No. 19CR213303-910

STATE OF NORTH CAROLINA

v.

THERIC ARNOLD HOLT, Defendant.

Appeal by Defendant from judgment entered 23 February 2024 by Judge

James P. Hill in Wake County Superior Court. Heard in the Court of Appeals 24

February 2026.

Attorney General Jeff Jackson, by Assistant Attorney General Jessica Major, for the State.

John W. Moss for Defendant.

GRIFFIN, Judge.

Defendant Theric Arnold Holt appeals from a judgment entered after a jury

found him guilty of driving while impaired. Defendant argues the trial court erred

in allowing the admission of an expert witness’s opinion and a laboratory review

report because they violated his rights under the Confrontation Clauses of both the

United States and North Carolina Constitutions. We agree and award a new trial.

I. Factual and Procedural Background STATE V. HOLT

Opinion of the Court

On 19 July 2019, Wake Forest Police Department’s Corporal Kevin Murray

pulled over Defendant for running a red light. Cpl. Murray approached Defendant’s

vehicle and noticed Defendant’s breath smelled of alcohol and his eyes appeared

bloodshot and glassy. Cpl. Murray also saw a half-empty bottle of bourbon on the

passenger floorboard. Defendant admitted he had consumed one drink about an hour

and a half earlier before the traffic stop. In consideration of the circumstances, Cpl.

Murray asked Defendant to perform three field sobriety tests. Cpl. Murray also

offered Defendant a preliminary breath test, which Defendant initially declined. All

considering, Cpl. Murray formed an opinion that Defendant was appreciably

impaired by alcohol and arrested him for impaired driving.

Cpl. Murray transported Defendant to the Wake County Detention Center.

Defendant refused to provide a breath sample on the EC/IR II to measure alcohol

concentration. As a result of the refusal, Cpl. Murry applied for a warrant to collect

a blood sample from Defendant for analysis. One of the on-site nurses at the

detention center drew Defendant’s blood at 3:30 a.m. A nurse gave the blood sample

to Cpl. Murray, who sealed the package and put it into an evidence kit. After he

finished processing Defendant, Cpl. Murray returned to the Wake Forest Police

Department and locked the kit in an unrefrigerated locker at 4:37 a.m. About four

and a half hours later, an evidence technician moved the evidence kit containing

Defendant’s blood to an evidence room refrigerator. About four days later, another

technician moved the kit to another unit in an evidence refrigerator.

-2- STATE V. HOLT

On 25 July 2019, Irvin Allcox, an analyst for the Wake City-County Bureau of

Identification (“CCBI”), removed Defendant’s blood sample from its evidence

refrigerator for testing. Allcox completed Defendant’s blood test using the gas

chromatography method and determined the alcohol concentration was 0.15 grams

per 100 milliliters of blood. Dr. Richard Waggoner, who also works for the CCBI in

the DWI Blood Chemistry Unit, performed a technical and administrative review of

Allcox’s work. In performing both administrative and technical reviews, Dr.

Waggoner reviewed “the data and notes to ensure that all the CCBI laboratory and

CCBI main procedures and policies were followed;” confirmed the CCBI laboratory

request header information was appropriately placed; checked for spelling,

typographical, mathematical, and clerical errors; and made sure the information

within the lab report, especially the results, was supported by the underlying data.

After reviewing the gas chromatograph and performing his own calculations, Dr.

Waggoner approved Allcox’s work and came to the same conclusion that Defendant’s

blood alcohol concentration was 0.15 grams of alcohol per 100 milliliters of blood.

Defendant was found guilty in Wake County District Court of impaired

driving. He was sentenced to sixty days in custody of the Misdemeanant Confinement

Program, which was suspended for twelve months of supervised probation.

Additionally, Defendant had to complete twenty-four hours of community service.

Defendant appealed to Superior Court.

-3- STATE V. HOLT

In March 2023, Defendant stood trial in Wake County Superior Court. The

jury could not reach a unanimous verdict, and the trial judge declared a mistrial.

The case was called for trial again, approximately one year later. There, the

court accepted the State’s tender of Dr. Waggoner as an expert witness in the fields

of forensic chemistry and forensic toxicology. However, the State did not call Allcox

to testify, as he had retired from the Wake CCBI in March 2020. In his testimony,

Dr. Waggoner acknowledged he “did not perform the analysis on this case” and was

not “involved in the testing or the receipt of evidence.” Dr. Waggoner testified the

following could have presented possible problems in Allcox’s testing, but he

personally did not have the opportunity to check for these matters: clotting,

fermentation, the sample’s packaging, vial leaks, the blood volume, homogeneity, and

pipetted bubbles. Additionally, Dr. Waggoner testified clotting and fermentation of

the sample have the potential to produce artificially high alcohol levels.

Furthermore, the State introduced Exhibit 7, which began with the “CCBI

Laboratory Technical and Administrative Review/Coversheet” for Defendant’s

results. Exhibit 7 also contained Allcox’s underlying report Dr. Waggoner had

reviewed. Defendant objected to this on Confrontation Clause grounds, as well as

hearsay and authentication. In response, the trial court overruled Defendant’s

objection and received State’s Exhibit 7, subject to a limiting instruction for the jury.

The limiting instruction emphasized that Exhibit 7 was not received as substantive

evidence nor as proof of the alcohol concentration of the blood; rather, the exhibit

-4- STATE V. HOLT

must only be considered for the limited purpose of disclosing information Dr.

Waggoner had considered in arriving at his opinion.

This jury found Defendant guilty of driving while impaired under the sole

theory that “at the time of driving, having consumed sufficient alcohol that, at any

relevant time after the driving, [Defendant] had an alcohol concentration of 0.08 or

more grams of alcohol per 100 milliliters of blood.” Defendant timely appeals.

II. Analysis

Defendant contends the trial court’s admission of Dr. Waggoner’s opinion and

State’s Exhibit 7 violated his rights under the Confrontation Clauses of the Sixth

Amendment of the Constitution of the United States and of Article I, Section 23 of

the North Carolina Constitution.

Both the United States and North Carolina Constitutions feature

Confrontation Clauses. U.S. Const. amend. XI; N.C. Const. art. 1, § 23. While the

clauses are not identical in language, North Carolina courts have “generally

construed the right to confrontation under our state constitution consistent with the

federal provision.” State v. Fowler, 353 N.C. 599, 614–15, 548 S.E.2d 684, 696 (2001)

(citations omitted).

The Confrontation Clause guarantees the accused the right “to be confronted

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Bluebook (online)
State v. Holt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-holt-ncctapp-2026.