State v. Hubbard

CourtCourt of Appeals of North Carolina
DecidedFebruary 4, 2026
Docket25-102
StatusUnpublished
AuthorJudge April Wood

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

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedu re.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-102

Filed 4 February 2026

Wake County, Nos. 22CR205465-910, 23CR015237-910

STATE OF NORTH CAROLINA

v.

JESSIAH JAMES HUBBARD

Appeal by Defendant from judgment entered 21 February 2024 by Judge A.

Graham Shirley II in Wake County Superior Court. Heard in the Court of Appeals

14 October 2025.

Attorney General Jeff Jackson, by Assistant Attorney General Clarence Turpin, V, for the State.

Caryn Strickland, for the Defendant.

WOOD, Judge.

Jessiah James Hubbard (“Defendant”) appeals from jury verdicts finding him

guilty of failing to report his change of address for the sex offender registry in

violation of N.C. Gen. Stat. § 14-208.11(a)(2) and of having attained habitual felon

status. Defendant raises two issues on appeal. First, Defendant argues the trial STATE V. HUBBARD

Opinion of the Court

court failed to conduct a competency hearing in response to “red flags” relevant to his

competency. Second, Defendant argues his waiver of his Sixth Amendment right to

counsel was invalid because the trial court erred by failing to comply with N.C. Gen.

Stat. § 15A-1242.

I. Factual and Procedural Background

On 3 April 2022, Defendant was arrested by Cary Police Department Officer

Matthew Watson for failing to report his change of address for the sex offender

registry in violation of N.C. Gen. Stat. § 14-208.11(a)(2). At his arrest, Defendant

had been living in a homeless encampment in the woods adjacent to the Embassy

Suites in Cary, while the sex offender registry listed his current address in Raleigh.

Those on the sex offender registry must report a change of address, including when

residing in temporary housing or out-of-doors like “in a tent” or “under a bridge,”

within three business days to the last registering sheriff and within ten days to the

sheriff of the new county to which they have moved, if applicable. N.C. Gen. Stat. §§

14-208.11(a)(2), 14-208.9(a).

On 19 April 2022, Defendant was indicted for failing to report his change of

address for the sex offender registry in violation of N.C. Gen. Stat. § 14-208.11(a)(2).

Defendant’s initial hearing was held on 26 October 2022. From the outset,

Defendant’s court appointed attorney, Assistant Public Defender Patrick Koch

(“Attorney Koch”), informed the trial court of Defendant’s intention to represent

himself. Specifically, Attorney Koch stated:

-2- STATE V. HUBBARD

MR. KOCH: Your Honor, I believe it is my client’s wish to represent himself so I think he also wants to be heard on some matters. I’ve advised him of his right to remain silent and that the court reporter is recording everything he’s to say, but he’s informed me some time ago that he wants to represent himself. And we’ve been brought over a couple times, and we weren’t reached, but I think that’s still his wish.

THE COURT: All right. [Defendant], I understand you want to address the Court. Let me remind you of a couple things before you do that. First of all, you do have a right to remain silent. Anything you say can and will be used against you.

Secondly, Mr. Koch at this moment is your attorney. If you have any questions about what you should say to me or if I ask you any questions and you want to confer with your counsel before you answer, you are welcome to do that. But if you wish to speak to me, I’ll be happy to hear from you, sir.

THE DEFENDANT: Okay. Is there any questions you want to ask me about the self-representation?

...

THE COURT: Well, I want to know what the concern about your attorney is first. You’re asking for your attorney to withdraw, or do you just - -

THE DEFENDANT: Standby counsel.

THE COURT: So you’ve just decided you want to represent yourself?

THE DEFENDANT: I decided this a while back, yes.

THE COURT: Do you understand you have a right to counsel?

-3- STATE V. HUBBARD

THE DEFENDANT: Yeah.

THE COURT: You understand that, if you can’t afford counsel, one will be appointed for you?

THE DEFENDANT: Okay.

The trial court explained the role of standby counsel to Defendant and explained what

would be expected of him if he represented himself. Attorney Koch informed the trial

court that Defendant faced a class F felony and that he faced a maximum possible

punishment of up to 59 months incarceration. Defendant acknowledged he

understood.

The trial court further inquired into Defendant’s level of reading and writing

comprehension, and Defendant informed the trial court he has a GED. After further

inquiries into Defendant’s desire to represent himself, the trial court ultimately

concluded Defendant had knowingly waived his right to counsel after explicitly

asking him twice if it was his wish to represent himself in the matter and to waive

his right to counsel. Defendant answered in the affirmative.

The trial court then proceeded to ask if there were any issues before the Court

other than the “attorney issue.” Defendant replied, “[w]ell, can we at least - - out of

respect to the families, will the State give a minute of silence for the deceased

children?” The trial court responded, “[a]ll right. What’s before the Court at this time

is the motion to allow you to represent yourself, which I have now granted. I need you

to sign that form. That’s what we are doing today.” Defendant then requested

-4- STATE V. HUBBARD

standby counsel, was administered the oath affirming his waiver of counsel, and

signed the written waiver of counsel form. As the hearing concluded, Defendant

commented, “[w]hy can’t we do a moment of silence for them? Why can’t we do a

minute of silence for them, huh? Why can’t we do a minute of silence for the children

in this matter? Why can’t we do that?”

On 4 January 2023, Defendant appeared pro se with standby counsel, Attorney

Nicholas Saparilas (“Attorney Saparilas”), at his arraignment hearing on the charge

of failing to report his change of address for the sex offender registry in violation of

N.C. Gen. Stat. § 14-208.11(a)(2). Defendant attempted to “not plead[] to anything,”

and insisted, “I am entering no plea.” The trial court entered a plea of not guilty on

his behalf. Defendant became argumentative, insisted the trial court read aloud a

letter he had written and stated, “[y]ou all are endangering the women and children

- - ,” and asked, “[w]hy did you extradite me from Michigan - - ?” The trial court asked

Defendant if he was able to understand instructions and what he was being asked to

do; Defendant answered, “I don’t understand what you’re saying.” The trial court

then considered whether Defendant needed to be evaluated. That same day the trial

court entered a motion and order sua sponte committing Defendant to Central

Regional Hospital for examination to determine his capacity to proceed.

On 31 January 2023, Susan Hurt, Ph.D. (“Dr. Hurt”) from Central Regional

Hospital evaluated Defendant and prepared a forensic evaluation summary for the

trial court. The summary indicated that when asked why Defendant thought the

-5- STATE V. HUBBARD

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Drope v. Missouri
420 U.S. 162 (Supreme Court, 1975)
State v. Young
231 S.E.2d 577 (Supreme Court of North Carolina, 1977)
State v. White
338 S.E.2d 614 (Court of Appeals of North Carolina, 1986)
State v. Cooper
213 S.E.2d 305 (Supreme Court of North Carolina, 1975)
State v. Veney
817 S.E.2d 114 (Court of Appeals of North Carolina, 2018)
State v. Frederick
730 S.E.2d 275 (Court of Appeals of North Carolina, 2012)
State v. Gentry
743 S.E.2d 235 (Court of Appeals of North Carolina, 2013)

Cite This Page — Counsel Stack

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