State v. Littlejohn

CourtCourt of Appeals of North Carolina
DecidedSeptember 17, 2025
Docket24-410
StatusUnpublished

This text of State v. Littlejohn (State v. Littlejohn) 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. Littlejohn, (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An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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. COA24-410

Filed 17 September 2025

Rutherford County, Nos. 22CRS050742, 22CRS000746

STATE OF NORTH CAROLINA

v.

WALTER ASHLEY LITTLEJOHN, Defendant.

Appeal by Defendant from judgment entered 3 February 2023 by Judge J.

Thomas Davis in Rutherford County Superior Court. Heard in the Court of Appeals

15 January 2025.

Attorney General Jeff Jackson, by Assistant Attorney General Megan Shook, for the State.

Appellate Defender Glenn Gerding, by Assistant Appellate Defender David S. Hallen, for defendant-appellant.

STADING, Judge.

Walter Ashley Littlejohn (“Defendant”) appeals from final judgment entered

upon jury verdicts finding him guilty of felonious restraint and attaining habitual

felon status; he also pleaded guilty to assault inflicting physical injury on a detention

facility employee. Defendant maintains the indictment was defective, necessitating

vacatur of his felonious restraint conviction, and contends the trial court erred in STATE V. LITTLEJOHN

Opinion of the Court

instructing the jury on felonious restraint. Defendant also asserts that even if the

trial court did not err in its instruction, his trial attorney rendered ineffective

assistance of counsel (“IAC”). Since Defendant’s appeal was untimely, he petitioned

our Court for certiorari. For the reasons below, we deny Defendant’s petition for writ

of certiorari (“PWC”).

I. Background

On 3 April 2022, Defendant was walking alone when a silver Jeep Renegade

pulled up alongside him. The Jeep was driven by Kenyon McEntire, with Jennifer

Gibson in the front passenger seat, and Stevon Wilkerson in the back seat. Defendant

and Ms. Gibson had ended their relationship a few weeks earlier. Defendant entered

the Jeep and sat in the back seat. Defendant told Ms. Gibson to sit in the back seat

with him. Ms. Gibson complied because Defendant was acting “irate,” and she was

“[t]rying to keep the situation calm.” The group rode to Ms. Gibson’s mother’s house.

Upon arrival, Mr. Wilkerson stepped out, and Defendant held Ms. Gibson and yelled

for Mr. McEntire to drive. Ms. Gibson stated she wanted to leave, but Defendant

prevented her from leaving the Jeep.

Mr. McEntire then drove away from the house with Defendant and Ms. Gibson

still in the back seat. During the drive, Defendant reportedly tried to open a “samurai

sword,” but was unable to do so in the confined space. When they reached a Super 8

Motel, Defendant got out, apologized for “what had happened in the past,” and

attempted to convince Ms. Gibson to accompany him inside the motel. Ms. Gibson

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declined Defendant’s request. Mr. McEntire then drove everyone to his mother’s

house, where they were met by law enforcement. Defendant initially stood between

Ms. Gibson and a law enforcement officer, stating “she’s not talking to you.”

Defendant eventually moved aside when threatened with arrest for his obstruction of

an investigation. After speaking with Ms. Gibson, law enforcement officers arrested

Defendant.

On 19 September 2022, the Rutherford County Grand Jury indicted Defendant

for second-degree kidnapping and attaining the status of habitual felon. The matter

proceeded to trial on 2 February 2023. The jury found Defendant guilty of felonious

restraint, as a lesser included offense of kidnapping, and determined he had attained

habitual felon status. Before sentencing, Defendant pleaded guilty to assault

inflicting physical injury on a detention facility employee. On 3 February 2023, the

trial court imposed a sentence of 96 to 128 months in the Department of Adult

Correction for the felonious restraint conviction, and a concurrent term of 38 to 58

months for his guilty plea to assault inflicting physical injury on a detention facility

employee.

On 20 February 2023, Defendant sent a handwritten letter to the Rutherford

County Clerk of Superior Court requesting his trial transcript. The letter also stated

that Defendant was “filing on [his] own behalf a[n] . . . MAR[.]” On 2 March 2023,

the trial court entered appellate entries recognizing Defendant’s indigent status and

appointed the Appellate Defender’s Office to represent him. Defendant submitted an

-3- STATE V. LITTLEJOHN

additional letter on 26 March 2023, again requesting his trial transcripts. The letter

also stated he wanted “to be updated on what’s going on with [his] appeal.” On 13

June 2024, Defendant petitioned this Court for certiorari. The State subsequently

moved to dismiss Defendant’s appeal and responded to the PWC.

II. Jurisdiction

We must address whether this Court has jurisdiction to entertain Defendant’s

appeal in light of his PWC and the State’s motion to dismiss. The State argues that

Defendant failed to satisfy the jurisdictional requirements necessary to confer

appellate review under North Carolina law, emphasizing that he never entered a

valid notice of appeal. In particular, the State notes that Defendant’s handwritten

letter to the Clerk of Superior Court failed to satisfy Rule 4 because it was untimely,

was never served on the State, and did not identify the court to which he was

appealing. See N.C. R. App. P. 4. After careful consideration, we deny Defendant’s

PWC and dismiss his appeal. See Cryan v. Nat’l Council of YMCA of the United

States, 384 N.C. 569, 573, 887 S.E.2d 848, 851 (2023).

It is well settled that “[c]ompliance with the requirements for entry of notice of

appeal is jurisdictional.” State v. Oates, 366 N.C. 264, 266, 732 S.E.2d 571, 573 (2012).

“Rule 4 authorizes two modes of appeal for criminal cases.” Id. at 268, 732 S.E.2d at

574. A criminal defendant “may take appeal by . . . giving oral notice of appeal at

trial, or [by] filing notice of appeal with the clerk of superior court and serving copies

thereof upon all adverse parties within fourteen days after entry of judgment.” N.C.

-4- STATE V. LITTLEJOHN

R. App. P. 4(a)(1)–(2). “[T]he window for the filing of a written notice of appeal in a

criminal case opens on the date of rendition of the judgment or order and closes

fourteen days after entry of the judgment or order.” Oates, 366 N.C. at 264, 732 S.E.2d

at 572.

Still, this Court has the discretionary authority to issue a writ of certiorari

“when the right to prosecute an appeal has been lost by failure to take timely action,”

such as where a criminal defendant’s notice of appeal fails to comply with Rule 4.

N.C. R. App. P. 21(a)(1); N.C. Gen. Stat. § 7A-32(c) (2023) (“The Court of Appeals has

jurisdiction . . . to issue the prerogative writs, including . . . certiorari[.]”).

“The writ of certiorari is one of the ‘prerogative’ writs that the Court of Appeals

may issue in aid of its own jurisdiction.” Cryan, 384 N.C. at 572, 887 S.E.2d at 851

(citation omitted). “Our precedent establishes a two-factor test to assess whether

certiorari review by an appellate court is appropriate. First, a writ of certiorari

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Related

State v. Springle
781 S.E.2d 518 (Court of Appeals of North Carolina, 2016)
State v. Oates
732 S.E.2d 571 (Supreme Court of North Carolina, 2012)
State v. High
750 S.E.2d 9 (Court of Appeals of North Carolina, 2013)

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Bluebook (online)
State v. Littlejohn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-littlejohn-ncctapp-2025.