State v. Hunt

CourtCourt of Appeals of North Carolina
DecidedOctober 15, 2024
Docket23-890
StatusPublished

This text of State v. Hunt (State v. Hunt) 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. Hunt, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA23-890

Filed 15 October 2024

Robeson County, Nos. 19 CRS 50642; 22 CRS 1726

STATE OF NORTH CAROLINA

v.

GRANT LEE HUNT

Appeal by defendant from judgment entered 24 March 2023 by Judge James

G. Bell in Robeson County Superior Court. Heard in the Court of Appeals 14 August

2024.

Attorney General Joshua H. Stein, by Special Deputy Attorney General Thomas J. Campbell, for the State.

Daniel M. Blau for defendant-appellant.

THOMPSON, Judge.

Grant Lee Hunt (defendant) appeals from a judgment entered upon a jury’s

verdict finding him guilty of assault with a deadly weapon inflicting serious injury

without intent to kill and injury to personal property. On appeal, defendant contends,

inter alia, that the trial court committed plain error by allowing a lay witness to give

an expert opinion about how the accident happened and defendant’s intent at the

time of the accident. After careful review, we vacate and remand for a new trial.

I. Factual Background and Procedural History STATE V. HUNT

Opinion of the Court

Defendant and Timothy Todd (Todd), the alleged victim in this case, have been

neighbors since defendant purchased his home in 2018. Testimony proffered at trial

established a great deal of animosity existed between defendant and Todd in the

interim period, which we will not exhaustively chronicle. Pertinent to the present

appeal, on 23 January 2019, defendant and his wife made a formal request to the

Robeson County Sheriff’s Department to conduct regular check-ins on their property

due to alleged harassment and trespassing onto their property by Todd, including

“coming onto the property at night with [a] [4-]wheeler and . . . throwing beer cans

and bottles in [defendant’s] yard[,] and watching [defendant’s] property.”

Two days later, on 25 January 2019, defendant was on his way home from

work, “on the phone with the wife, driving[,] [a]nd at this point that’s when I see an

object. You know, just out of - - out of the corner of my eye . . . it just happened so fast

. . . [i]t was instant . . . the impact.” Defendant testified that he “didn’t have time to

recognize anything at that point[,]” referring to the collision, but when he exited his

vehicle, defendant testified that he asked, “[w]here’s that son of a b[****][,]” and he

then realized “that there was an accident[,] [a]nd I s[aw] a 4-wheeler and [Todd].”

Defendant further testified that he attempted to check on Todd but was instructed to

leave the property by Todd’s sister, which defendant did. Defendant maintained that

he “did not go into [Todd’s] driveway to hit th[e] 4-wheeler[.]”

According to Todd, he had no recollection of the accident; he testified at trial

that he was “riding down the driveway . . . on the 4-wheeler . . . [to go to] the store to

-2- STATE V. HUNT

get gas” when the accident occurred, and that he realized he had been in an accident

when he “woke up six weeks later.” It is uncontested that Todd suffered a broken leg,

ankle, jaw, and eye socket in the accident.

A law enforcement officer who responded to the scene of the accident testified

that he first noticed “a 4-wheeler or ATV that was off the roadway in a yard and a

pickup truck that was kind of partially in the roadway . . . .” After admitting

photographs taken at the scene into evidence, the State then asked the law

enforcement officer who, again, responded to the scene of the accident, whether he

had “form[ed] an opinion whether this was an accident or an intentional act[,]” to

which the law enforcement officer replied, “[m]y opinion is it was an intentional act.”

On 6 July 2020, defendant was indicted upon a true bill of indictment by a

Robeson County Grand Jury for injury to personal property and assault with a deadly

weapon with intent to kill inflicting serious injury. The matter came on for trial at

the 22 March 2023 Criminal Session of Robeson County Superior Court. Two days

later, on 24 March 2023, defendant was found guilty upon a jury’s verdict of assault

with a deadly weapon inflicting serious injury without intent to kill, and injury to

personal property. Pursuant to the jury’s verdict, defendant was sentenced to an

active term of 120 to 156 months in the custody of the North Carolina Department of

Adult Correction. Defendant entered timely oral notice of appeal at trial.

II. Discussion

-3- STATE V. HUNT

On appeal, defendant contends, inter alia, that the trial court “committed plain

error by allowing a lay witness to give an expert opinion about how the accident

happened, and that [defendant] had intentionally hit [Todd].” We agree.

A. Standard of review

At the outset, we note that defense counsel failed to object to the testimony

proffered by the lay witness at trial; therefore, this issue is subject to plain error

review. Under plain error, “a defendant must demonstrate that a fundamental error

occurred at trial.” State v. Lawrence, 365 N.C. 506, 518, 723 S.E.2d 326, 334 (2012).

“To show that an error was fundamental, a defendant must establish prejudice—that,

after examination of the entire record, the error had a probable impact on the jury’s

finding that the defendant was guilty.” Id. (internal quotation marks and citation

omitted).

B. Law enforcement officer’s testimony

Generally, a law enforcement officer who does not witness an accident, but

later observes the scene of the accident is permitted to testify about physical facts

observed at the scene, including the condition of the vehicles after the accident and

their positioning. See State v. Wells, 52 N.C. App. 311, 314, 278 S.E.2d 527, 529 (1981)

(noting that our Supreme Court has held in several cases that “it is competent for an

investigating officer to testify as to the condition and position of the vehicles and other

physical facts observed by him at the scene of an accident”).

-4- STATE V. HUNT

On the other hand, if the law enforcement officer did not personally observe the

accident, “[t]he jury is just as well qualified as the witness to determine what

inferences the facts will permit or require.” Shaw v. Sylvester, 253 N.C. 176, 180, 116

S.E.2d 351, 355 (1960). In fact, a law enforcement officer’s “testimony as to his

conclusions from those facts is incompetent.” Wells, 52 N.C. App. at 529, 278 S.E.2d

at 529.

In State v. Denton, this Court observed that, “we can find no instance of lay

accident analysis testimony in North Carolina.” State v. Denton, 265 N.C. App. 632,

636, 829 S.E.2d 674, 678 (2019) (emphasis in original). “Accident reconstruction by

its very nature requires expert analysis of the information collected from the scene of

the accident and falls under Rule of Evidence 702 . . . .” Id. Indeed, in State v.

Maready, this Court held that, “[a]ccident reconstruction opinion testimony may only

be admitted by experts, who have proven to the trial court’s satisfaction that they have

a superior ability to form conclusions based upon the evidence gathered from the

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

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Buie
671 S.E.2d 351 (Court of Appeals of North Carolina, 2009)
State v. Braswell
324 S.E.2d 241 (Supreme Court of North Carolina, 1985)
State v. Smith
524 S.E.2d 28 (Supreme Court of North Carolina, 2000)
State v. Wells
278 S.E.2d 527 (Court of Appeals of North Carolina, 1981)
State v. Ward
555 S.E.2d 251 (Supreme Court of North Carolina, 2001)
State v. Castaneda
674 S.E.2d 707 (Court of Appeals of North Carolina, 2009)
State v. Jones
558 S.E.2d 97 (Supreme Court of North Carolina, 2002)
State v. Odom
300 S.E.2d 375 (Supreme Court of North Carolina, 1983)
State v. Weldon
333 S.E.2d 701 (Supreme Court of North Carolina, 1985)
State v. Williams
263 S.E.2d 774 (Supreme Court of North Carolina, 1980)
Shaw v. Sylvester
116 S.E.2d 351 (Supreme Court of North Carolina, 1960)
State v. Harshaw
532 S.E.2d 224 (Court of Appeals of North Carolina, 2000)
State v. Williams
338 S.E.2d 75 (Supreme Court of North Carolina, 1986)
State v. Peterson
652 S.E.2d 216 (Supreme Court of North Carolina, 2007)
State v. Maready
695 S.E.2d 771 (Court of Appeals of North Carolina, 2010)
State v. Lawrence
723 S.E.2d 326 (Supreme Court of North Carolina, 2012)
State v. Moore
715 S.E.2d 847 (Supreme Court of North Carolina, 2011)
Cheek v. Barnwell Warehouse & Brokerage Co.
183 S.E. 729 (Supreme Court of North Carolina, 1936)
State v. Denton
829 S.E.2d 674 (Court of Appeals of North Carolina, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Hunt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hunt-ncctapp-2024.