State v. Jordan

CourtSupreme Court of North Carolina
DecidedMarch 22, 2024
Docket124PA22
StatusPublished

This text of State v. Jordan (State v. Jordan) is published on Counsel Stack Legal Research, covering Supreme Court 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. Jordan, (N.C. 2024).

Opinion

IN THE SUPREME COURT OF NORTH CAROLINA

No. 124PA22

Filed 22 March 2024

STATE OF NORTH CAROLINA

v. RICHARD HENRY JORDAN, JR.

On discretionary review pursuant to N.C.G.S. § 7A-31 of a unanimous decision

of the Court of Appeals, 282 N.C. App. 651 (2022), reversing an order entered on 22

January 2020 by Judge Daniel Kuehnert in Superior Court, Mecklenburg County,

and remanding the case. Heard in the Supreme Court on 7 November 2023.

Joshua H. Stein, Attorney General, by Michael T. Henry, Special Deputy Attorney General, for the State-appellant.

Christopher A. Brook for defendant-appellee.

DIETZ, Justice.

While investigating reports of a stolen car, law enforcement officers observed

a suspect retreat to a nearby home. The officers followed the suspect into the home

and saw evidence of an illegal drug operation.

The issue presented in this case is whether defendant—one of the participants

in that drug operation—has standing to challenge the officers’ warrantless entry into

the home. Defendant told the police he did not live there. Defendant’s uncle, who was

also present, told the officers that he lived there and consented to a search. The uncle

also told the officers that one of the other men present—the original suspect that led STATE V. JORDAN

Opinion of the Court

officers to the home—was temporarily staying there and had some personal

belongings in the home. The uncle did not indicate that defendant lived in the home

or frequently visited.

After a suppression hearing, the trial court orally denied defendant’s motion

to suppress, referencing defendant’s lack of any reasonable expectation of privacy in

the home. The court’s oral ruling did not include clearly identified findings of fact,

with much of the court’s discussion being mere recitation of the evidence. The court

instructed the State to prepare a draft order, which the court would then enter to

memorialize its ruling.

That never happened, and the case went to trial without the trial court

memorializing its oral ruling in a written order with express fact findings. After the

jury convicted defendant of a number of drug-related offenses, defendant appealed.

The Court of Appeals reversed the trial court’s denial of the motion to suppress,

reasoning that the trial record would not support any finding that defendant lacked

a reasonable expectation of privacy in the home.

As explained below, we reverse the decision of the Court of Appeals. The

evidence presented at the suppression hearing could support findings that defendant

lacked standing to challenge the search. But the trial court never made those

findings, despite being compelled to do so because the trial record contains materially

conflicting evidence. See State v. Bartlett, 368 N.C. 309, 312 (2015).

We therefore reverse the decision of the Court of Appeals and remand with

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instructions to further remand this matter to the trial court to make findings of fact

based on the trial record. The trial court, based on those new findings, may again

deny the motion to suppress, leaving defendant’s convictions intact, or it may grant

the motion to suppress in whole or in part and order a new trial. See State v.

Hammonds, 370 N.C. 158, 160–62 (2017).

Facts and Procedural History

In 2017, law enforcement officers arrived in a residential neighborhood to

investigate reports of a stolen car. The officers located the stolen car in a parking lot.

While observing the car, officers saw Marcel Thompson leave a nearby house and

approach the car as if he planned to enter it. After Thompson saw the officers, he

turned and hurried back towards the house.

Thompson knocked on the door of the house and said “it’s the police” loudly

enough for the officers to hear as they followed him. Defendant opened the door to let

Thompson into the home. Thompson left the door open as he entered. One officer put

his foot through the threshold of the door and told the occupants that he wanted to

speak with them. After Thompson declined to step outside, the officer fully entered

the home, while another officer moved into the doorway.

The second officer observed defendant close a safe that was sitting on a table

in the center of the room. The officer saw defendant lock the safe and put a key in his

pocket. That officer also saw baggies, razor blades, and white powder on the same

table.

-3- STATE V. JORDAN

There were two other individuals in the house with Thompson and defendant.

Officers asked the occupants who lived in the home. One of the occupants, James

Deitz,1 told the officers that he resided in the home. Officers later learned that Deitz

is defendant’s uncle.

The officers asked Deitz for permission to search the home, and Deitz

consented. When the officers asked to search the safe, defendant claimed the safe was

not his. Defendant then objected to the officers searching the safe and refused to

provide them with the key. When the officers asked defendant if he lived in the home,

he stated, “I don’t have anything to do with anything that’s in here. I don’t live here.

This has nothing to do with me.”

Defendant further explained, “I came to visit my uncle. I don’t live in here

period, there is nothing here in my name.” When the officers again asked if defendant

lived at the home, he responded, “No, I don’t live here.” The officers then pointed out

that because defendant had the key to the safe, he must at least own what is in the

safe, but defendant again responded, “No.”

The officers discussed with Deitz who resided in the house. Deitz told the

officers that Thompson had been staying in the house for a few days. Thompson

confirmed that he had various belongings in the home. Neither Deitz nor Thompson

indicated that defendant also stayed at the home, which was relatively small and had

1 The State uses the name “James Deitz.” Defendant uses the name “James Deese.”

As explained below, because the trial court did not enter a written order, the record does not definitively resolve the correct spelling of this witness’s surname.

-4- STATE V. JORDAN

only one bedroom, and no one identified any of defendant’s belongings inside the

home.

The officers later obtained a warrant to search the safe and the home. Inside

the safe, the officers found a firearm, cocaine in different baggies, and money.

Throughout the home, the officers found baggies, syringes, razor blades, and scales.

The State charged defendant with trafficking cocaine, possession of a firearm

by a felon, possession of drug paraphernalia, and attaining habitual felon status.

Before trial, defendant filed a motion to suppress the evidence, claiming that

the officers unlawfully entered Deitz’s home. At the hearing, both parties briefly

addressed the issue of defendant’s expectation of privacy in the home, but it was not

a focus of either side’s arguments.

At the end of the hearing, the trial court orally denied defendant’s motion to

suppress. As is common in these scenarios, the trial court’s oral ruling did not include

clearly defined findings of fact and conclusions of law. Instead, the trial court

indicated that it would enter a written order memorializing the oral ruling. The court

instructed the State to prepare a draft order. The parties acknowledge on appeal that

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State v. Jordan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-jordan-nc-2024.