State v. Lynch

CourtCourt of Appeals of North Carolina
DecidedMay 19, 2020
Docket19-358
StatusPublished

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Bluebook
State v. Lynch, (N.C. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA19-358

Filed: 19 May 2020

Lenoir County, Nos. 16CRS050202, 17CRS000096-97

STATE OF NORTH CAROLINA

v.

JUSTIN LAVONE LYNCH, Defendant.

Appeal by Defendant from judgment entered 19 March 2018 by Judge Charles

Henry in Lenoir County Superior Court. Heard in the Court of Appeals 18 March

2020.

Attorney General Joshua H. Stein by Assistant Attorney General Sherri H. Lawrence, for the State.

Glover & Petersen, P.A., by James R. Glover, for Defendant-Appellant.

DILLON, Judge.

Defendant Justin Lynch appeals from a judgment entered against him for first-

degree murder, robbery with a dangerous weapon, and assault with a deadly weapon

with the intent to kill inflicting serious injury. Defendant was sentenced to life

without parole for the murder conviction and to shorter terms for the other

convictions.

I. Background STATE V. LYNCH

Opinion of the Court

This case arises out of the robbery of a bar on 22 January 2016, perpetrated by

two masked individuals. The evidence at trial tended to show that Defendant was

one of the masked individuals. During the robbery, Defendant shot and killed the

owner of the bar, and he and his accomplice fled with the cash register. Officers

tracked down Defendant and his accomplice and arrested them. Defendant was

advised of his Miranda rights and signed a waiver, never asking to speak with a

lawyer. Defendant was interrogated alone by two officers at the police station.

Defendant adamantly denied any involvement during much of the

interrogation. However, towards the end of the recorded, three-hour interrogation,

Defendant finally confessed to his involvement.

Prior to trial, Defendant moved to have his confession suppressed. His motion

was denied.

At trial, the State introduced Defendant’s confession and the testimonies of

others involved in the robbery implicating Defendant. The jury convicted Defendant.

Defendant appeals.

II. Analysis

A. Voluntariness of Defendant’s Confession

On appeal, Defendant argues that it was error for the trial court to admit his

confession. He contends that his confession was not voluntary “because it was

-2- STATE V. LYNCH

produced by the hope for a sentence less tha[n] life imprisonment [in]duced by the

statements and actions of the officers who interrogated him.”

The transcript from the interrogation tends to show that Defendant was not

predisposed to confess; he repeatedly denied any involvement; he was predisposed to

believe that he would receive a life sentence whether he confessed or not; the

interrogators told Defendant that they had overwhelming evidence of his guilt; they

told him that they believed he was lying; they told Defendant that he had a better

chance of a lesser sentence if he cooperated with them; and Defendant eventually

cooperated, confessing to his involvement and naming his accomplice, believing that

by cooperating, he had a better chance of a reduced sentence.

1. A confession induced by hope may be involuntary, depending on the totality of the circumstances.

“It has been the law of this State from its beginning that an extrajudicial

confession of guilt by an accused is admissible against him only when it is voluntary.”

State v. Fox, 274 N.C. 277, 292, 163 S.E.2d 492, 502 (1968) (emphasis added)

(citations omitted). In an opinion penned during the first decade of our Supreme

Court’s existence, our original three justices each expressed the view that a confession

-3- STATE V. LYNCH

which was induced by some promise or hope is involuntary and, therefore,

inadmissible.1 State v. Roberts, 12 N.C. 259, 260 (1827) (granting a new trial).

We stress, though, that a confession motivated by some hope of leniency, in and

of itself, does not render a confession involuntary. Indeed, hope may be part of a

defendant’s calculus in voluntarily deciding to confess.

It is when this hope develops from something said by one in authority, such as

by an interrogating officer, that our Supreme Court has held that a confession may

be deemed involuntary. But even hope so derived is not per se involuntary. Rather,

the court “looks at the totality of the circumstances.” State v. Jackson, 308 N.C. 549,

581, 304 S.E.2d 134,152 (1983). And where a “defendant’s will [i]s not overborne [by

the hope],” his confession can still be said to be “made freely and voluntarily with full

knowledge of the consequences.” State v. Richardson, 316 N.C. 594, 604, 342 S.E.2d

823, 831 (1986) (requiring the reviewing court to look at the totality of the

circumstances to determine whether a confession induced, in part, by hope is

voluntary).

1 Our first Chief Justice John Louis Taylor, our only foreign-born Chief Justice (born in London), stated: “The true rule is, that a confession cannot be received in evidence, where the Defendant has been influenced by any threat or promise[.]” State v. Roberts, 12 N.C. 259, 260 (1827). Justice John Hall stated: “In order to make the confessions of a prisoner evidence to a Jury, it should appear that he was not induced to make them from a hope of favor, or compelled by fear of injury.” Id. at 260-61. Justice Leonard Henderson, for whom the town of Henderson is named, stated: “Confessions are either voluntary or involuntary. They are called voluntary, when made neither under the influence of hope or fear. . . . [I]t is said, and said with truth, that confessions induced by hope . . . are, of all kinds of evidence, the least to be relied on, and are therefore entirely to be rejected.” Id. at 261-62.

-4- STATE V. LYNCH

In any event, it is the role of the trial judge, and the appellate judges on review,

to consider the totality of the circumstances in determining whether a confession was

so induced by hope so as to render it involuntary.

2. Where there are no disputes as to what occurred during the interrogation, we review de novo whether Defendant’s confession was voluntary.

It is the role of the trial court to resolve disputes about what was said or done

by the defendant or the investigating officers during an interrogation. See

Richardson, 316 N.C. at 600-01, 342 S.E.2d at 828 (1986). However, where there is

no dispute or after the trial court has resolved such disputes, whether a defendant’s

confession was voluntary “is a question of law and is fully reviewable on appeal.”

State v. Barden, 356 N.C. 316, 339, 572 S.E.2d 108, 124 (2002) (internal quotation

marks omitted) (citation omitted). That is, whether certain conduct and language by

the interrogating officers “amounted to such threats or promises or influenced the

defendant by hope and fear as to render [his] subsequent confession involuntary” is

reviewed de novo on appeal, as a question of law. Richardson, at 601, 342 S.E.2d at

828; see State v. Rook, 304 N.C. 201, 216, 283 S.E.2d 732, 742 (1981) (holding that

where a defendant is influenced by hope and fear the subsequent confession is

involuntary); see also State v. Andrew, 61 N.C. 205, 206 (1867) (“What facts amount

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Related

Bram v. United States
168 U.S. 532 (Supreme Court, 1897)
State v. Smith
400 S.E.2d 712 (Supreme Court of North Carolina, 1991)
State v. Hayes
334 S.E.2d 741 (Supreme Court of North Carolina, 1985)
State v. Fox
163 S.E.2d 492 (Supreme Court of North Carolina, 1968)
State v. Fuqua
152 S.E.2d 68 (Supreme Court of North Carolina, 1967)
State v. Gainey
558 S.E.2d 463 (Supreme Court of North Carolina, 2002)
State v. Jackson
304 S.E.2d 134 (Supreme Court of North Carolina, 1983)
State v. Dishman
107 S.E.2d 750 (Supreme Court of North Carolina, 1959)
State v. Rook
283 S.E.2d 732 (Supreme Court of North Carolina, 1981)
State v. McCullers
460 S.E.2d 163 (Supreme Court of North Carolina, 1995)
State v. Corley
311 S.E.2d 540 (Supreme Court of North Carolina, 1984)
State v. Pruitt
212 S.E.2d 92 (Supreme Court of North Carolina, 1975)
State v. Barden
572 S.E.2d 108 (Supreme Court of North Carolina, 2002)
State v. Richardson
342 S.E.2d 823 (Supreme Court of North Carolina, 1986)
State v. . Drake
18 S.E. 166 (Supreme Court of North Carolina, 1893)
State v. . Roberts
12 N.C. 259 (Supreme Court of North Carolina, 1827)
State v. Andrew.
61 N.C. 205 (Supreme Court of North Carolina, 1867)

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Bluebook (online)
State v. Lynch, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lynch-ncctapp-2020.