State v. James

CourtCourt of Appeals of North Carolina
DecidedNovember 5, 2025
Docket24-1116
StatusUnpublished

This text of State v. James (State v. James) 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. James, (N.C. Ct. App. 2025).

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An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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 Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-1116

Filed 5 November 2025

Johnston County, Nos. 22CR000795-500, 22CR000796-500

STATE OF NORTH CAROLINA

v.

RICHARD DARNELL JAMES, Defendant.

Appeal by defendant from judgment entered 25 August 2023 by Judge Craig

Croom in Johnston County Superior Court. Heard in the Court of Appeals 23

September 2025.

Yoder Law PLLC, by Jason Christopher Yoder, for defendant-appellant.

Attorney General Jeff N. Jackson, by Assistant Attorney General Catherine R. Laney, for the State.

FLOOD, Judge.

Defendant Richard Darnell James appeals from the trial court’s judgment

finding him guilty of felony assault, assault on a female, and being a habitual felon.

On appeal, Defendant argues the trial court: first, plainly erred in allowing a witness

to testify regarding a statement a hotel guest said to her; second, abused its discretion STATE V. JAMES

Opinion of the Court

by denying Defendant’s motion to reopen evidence; and third, erred in increasing

Defendant’s sentence after he indicated he was going to appeal. Upon careful review,

we conclude the trial court: first, did not plainly err in allowing the witness to testify

about the statement the hotel guest made to the witness, where the statement was

offered for a non-hearsay purpose; second, did not abuse its discretion in denying

Defendant’s motion to reopen evidence, where Defendant had the opportunity to illicit

further testimony, but made the tactical decision not to; and third, did not err in

increasing Defendant’s sentence, where Defendant’s sentence was within the

presumptive range and Defendant failed to rebut the presumption of regularity.

I. Factual and Procedural Background

In April of 2022, Latarshie Douglas and Defendant were in an intimate

relationship. On the night of 22 April 2022, Douglas was “partying” with friends and

family. Later that night, Desmond Richardson, Douglas’s ex-fiancé, gave her a ride

back to the Travelers Inn, where Douglas was staying. Before Douglas arrived, she

called the hotel clerk to let Defendant into her room.

Once they arrived at the Travelers Inn, Douglas and Richardson entered the

room and found Defendant sitting on the bed in the dark. Douglas asked Richardson

to leave so she could speak with Defendant alone. As Douglas was closing the door

behind Richardson, she began explaining to Defendant she needed time to think

about whether she wanted to continue seeing him. She then asked Defendant to leave

the room and sat on the bed facing away from him. Defendant “said okay[,]” “grabbed

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one object out of the room, opened the door, and [left] the room[.]” When Defendant

left the room, he left the door open, and after a brief moment, he came back into the

room.

At trial, Douglas testified that when Defendant came back into the room, she

“still had [her] back to him” when she was suddenly hit with pressure. She explained

that in the moment “the only thing [she could] do was just shield [her] face. . . [a]nd

ball up on the bed in a fetal position[,]” as Defendant continued to hit her. Once

Defendant left the room again, Douglas “proceeded to get up[,]” and go “to the door of

the hotel room,” where she saw “the front desk lady” coming down the sidewalk.

According to Douglas, “the front desk lady” asked her if she wanted her to call the

police and Douglas responded, “yes, please call the police.” Defendant, who was by

the door, then “grab[bed Douglas] by the top of [her] hair. Grabbing [her] back inside

the motel room . . . and . . . continue[d] to swing and hit, and try to hit [her].”

Charlotte Smith, who was working the “4:00 p.m. to 1:00 a.m. shift” at the

Travelers Inn, testified that around the same time as the above-described events, she

received a phone call from the hotel guest next to the room that Douglas was staying

in. During the phone call, the hotel guest told Smith, “there is some man beating the

crap out of his lady.” Smith then went to Douglas’s room, knocked, and announced

herself as “front desk.” Defendant “jerked the door open,” and although Smith could

not see into the room, she told Defendant he was “going to have to leave [the] room.”

After Defendant told Smith that he would leave, Smith observed Defendant “pull his

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arm back[,]” in such a way that made her feel like that “must be trouble.” Smith “left

right away[,]” “hit [her] palm on the” door of the neighboring room, told them to “call

the police[,]” ran back to the front desk, and called law enforcement herself.

Just after midnight on 23 April 2022, Officer Moreno responded to a dispatch

call that there was a domestic incident in progress at the Travelers Inn. When Officer

Moreno arrived, he spoke with Douglas, photographed her injuries on the left and

right side of her face, spoke with Smith, returned to Douglas to get some more

information, “cleared the scene[,]” and then left. At approximately 3:40 a.m., Officer

Moreno went back to the Travelers Inn in response to Douglas’s report that her tires

had been slashed. Later that morning, after receiving another report that Defendant

was back on the property, Officer Moreno returned to the property for a third time,

spoke with Defendant, and subsequently arrested him.

On 18 July 2022, a Johnston County Grand Jury indicted Defendant for felony

assault pursuant to N.C.G.S. § 14-33.2, assault on a female, injury to personal

property, and attaining the status of a habitual felon.

This matter came on for trial on 21 August 2023. During trial, Smith, Douglas,

and Officer Moreno testified to the account above. At the close of the State’s evidence,

the State voluntarily dismissed the charge of injury to personal property. After the

jury retired to deliberate, Defendant moved to reopen the case and introduce Officer

Moreno’s testimony about what he saw on the surveillance video. Defense counsel

specifically argued that—after speaking with Officer Moreno that morning about

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what he saw on the video—Officer Moreno’s additional testimony would be

exculpatory.

In considering whether the evidence would be exculpatory, the trial court

acknowledged that while there was testimony that Defendant drew his arm back,

“[t]here was no evidence about anything being on video that [] shows [Defendant]

actually hitting the victim in this case[.]” The trial court further explained that,

[t]here were opportunities for . . . [D]efendant to address this during either cross-examination or by putting on evidence. Even though they don’t necessarily have to put on evidence. And this has been brought up at this point where we have had closing arguments. The jury has been charged. The jury has been deliberating for roughly 30 minutes, and we are now back from lunch. Based on all of those findings in my discretion I am not going to permit the party to introduce additional evidence at this time.

The trial court then denied Defendant’s request to reopen the evidence but

allowed Defendant to make an offer of proof—meaning Defendant presented the

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State v. James, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-james-ncctapp-2025.