An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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. COA24-543
Filed 17 September 2025
Randolph County, No. 20CRS051310
STATE OF NORTH CAROLINA
v.
MICHAEL JARED MEDLEY, Defendant.
Appeal by defendant from judgment and order of commitment entered 23
March 2023 by Judge James P. Hill Jr. in Randolph County Superior Court. Heard
in the Court of Appeals 26 February 2025.
Attorney General Jeff Jackson, by Assistant Attorney General Hyrum J. Hemingway, for the State-appellee.
Hynson Law, PLLC, by Warren D. Hynson, for defendant-appellant.
GORE, Judge.
This case arises from defendant Michael J. Medley’s conviction for second-
degree murder following the shooting death of William Bennett outside a residence
in Randleman, North Carolina. On appeal, defendant argues the trial court erred by
omitting the “no duty to retreat” and “stand your ground” provisions from the jury’s
self-defense instructions, depriving him of a fair trial. This Court has jurisdiction to STATE V. MEDLEY
Opinion of the Court
review defendant’s appeal pursuant to N.C.G.S. §§ 7A-27(b) and 15A-1444(a) as the
judgment was entered in superior court, and defendant filed a timely notice of appeal.
Upon review, we discern no prejudicial error.
I.
On 28 March 2020, defendant shot and killed William Bennett outside David
Bennett’s residence in Randleman, North Carolina. Earlier that day, defendant had
driven David and another individual, Walter Rodriguez, to purchase drugs.
Afterward, an altercation broke out between defendant and David, during which
defendant elbowed David in the nose, resulting in a broken nose and visible injuries.
Despite the altercation, the group returned to David’s home later that evening, where
David entered the house, leaving defendant outside near his vehicle.
William, who was on the porch, approached defendant to inquire about David’s
injuries. Witnesses observed the two men conversing without any visible signs of
aggression. Moments later, a gunshot was heard, and William was seen running
toward the house, bleeding from a gunshot wound to the chest. William collapsed
inside and was pronounced dead later that night. Witnesses testified they did not see
William brandishing a weapon during the interaction.
Defendant fled the scene and was apprehended two days later. During a
standoff with law enforcement, defendant claimed he acted in self-defense, alleging
William had attacked him with a tree-climbing spike. However, a search of the scene
yielded no evidence of such a weapon, and testimony at trial described the spike as a
-2- STATE V. MEDLEY
large, conspicuous object that would have been difficult to conceal.
At trial, defendant was charged with second-degree murder in violation of
N.C.G.S. § 14-17. During the charge conference, the trial court agreed to instruct the
jury on second-degree murder and self-defense using the pattern jury instructions.
The court also provided an instruction on flight as evidence of consciousness of guilt.
Both the State and the defense reviewed and approved the final instructions before
they were given to the jury.
During deliberations, the jury asked for clarification regarding the size and
weight of defendant and the victim, but the trial court informed them that no
additional evidence could be provided and that they must rely on the evidence
presented at trial. The jury ultimately found defendant guilty of second-degree
murder, and he was sentenced to an active prison term of 483 to 592 months.
Defendant filed a timely notice of appeal.
II.
A.
During the charge conference, the trial court, in consultation with both parties,
agreed to provide the substantive instruction for second-degree murder involving the
use of a deadly weapon, along with all lesser-included offenses and self-defense
(N.C.P.I. — Crim. 206.30). This instruction was modified to exclude references to the
aggressor doctrine. However, the court entirely omitted the “no duty to retreat”
provisions contained in N.C.P.I. — Crim. 206.30 and failed to include the “stand-your-
-3- STATE V. MEDLEY
ground” instruction from N.C.P.I. — Crim. 308.10, which is incorporated by reference
in footnote 4 of N.C.P.I. — Crim. 206.30.
These omissions resulted in a deviation from the agreed-upon pattern jury
instruction. As established in State v. Lee, 370 N.C. 671, 676 (2018), when a trial
court departs from an agreed pattern instruction, the issue is preserved for appellate
review without the need for further objection.
B.
Challenges to the trial court’s jury instructions are reviewed de novo. State v.
Osorio, 196 N.C. App. 458, 466 (2009). Employing de novo review, this Court
considers the matter anew and freely substitutes its own judgment for that of the
trial court. State v. Williams, 362 N.C. 628, 632–33 (2008).
When competent evidence of self-defense is introduced at trial, a defendant is
entitled to a jury instruction on self-defense that includes the applicable stand-your-
ground provision. See Lee, 370 N.C. at 674; State v. Bass, 371 N.C. 456, 542 (2018).
The statutory framework for perfect self-defense in North Carolina is outlined in
N.C.G.S. § 14-51.3(a)(1) and has been further clarified in case law. See State v.
McLymore, 380 N.C. 185, 191 (2022) (holding that N.C.G.S. § 14-51.3 supplants the
common law right to perfect self-defense and provides the exclusive statutory
framework for such claims). When determining whether a perfect self-defense
instruction is required, the evidence must be viewed in the light most favorable to the
defendant. State v. Moore, 363 N.C. 793, 796 (2010).
-4- STATE V. MEDLEY
The State concedes that defendant was entitled to a perfect self-defense
instruction, which should have informed the jury that defendant had no duty to
retreat. The State further acknowledges that the trial court erred in omitting this
instruction.
As defendant acknowledges, to establish reversible error from the trial court’s
omission, he must show that the omission resulted in prejudice. An error is
considered prejudicial only if “there is a reasonable possibility that, had the error in
question not been committed, a different result would have been reached at the trial
out of which the appeal arises.” State v. Phillips, 386 N.C. 513 (2024) (quoting
N.C.G.S. § 15A-1443(a)); Lee, 370 N.C. at 676. This analysis requires an evaluation
of the strength of the State’s evidence supporting the conviction and whether the
jury’s considerations suggest they might have reached a different conclusion with the
omitted instruction. State v. Brichikov, 383 N.C. 543, 557 (2022).
The burden is on the defendant to establish the existence of such prejudice on
appeal. State v. Tatum-Wade, 229 N.C. App. 83, 94 (2013). A defendant cannot rely
on a bare assertion of prejudice but must specifically explain how the error affected
the jury’s verdict. Id. at 94–95; State v. Bailey, 280 N.C. 264, 269 (1972). A
“particularized argument” showing the impact of the error is required to meet this
burden. Tatum-Wade, 229 N.C. App. at 94–95.
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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. COA24-543
Filed 17 September 2025
Randolph County, No. 20CRS051310
STATE OF NORTH CAROLINA
v.
MICHAEL JARED MEDLEY, Defendant.
Appeal by defendant from judgment and order of commitment entered 23
March 2023 by Judge James P. Hill Jr. in Randolph County Superior Court. Heard
in the Court of Appeals 26 February 2025.
Attorney General Jeff Jackson, by Assistant Attorney General Hyrum J. Hemingway, for the State-appellee.
Hynson Law, PLLC, by Warren D. Hynson, for defendant-appellant.
GORE, Judge.
This case arises from defendant Michael J. Medley’s conviction for second-
degree murder following the shooting death of William Bennett outside a residence
in Randleman, North Carolina. On appeal, defendant argues the trial court erred by
omitting the “no duty to retreat” and “stand your ground” provisions from the jury’s
self-defense instructions, depriving him of a fair trial. This Court has jurisdiction to STATE V. MEDLEY
Opinion of the Court
review defendant’s appeal pursuant to N.C.G.S. §§ 7A-27(b) and 15A-1444(a) as the
judgment was entered in superior court, and defendant filed a timely notice of appeal.
Upon review, we discern no prejudicial error.
I.
On 28 March 2020, defendant shot and killed William Bennett outside David
Bennett’s residence in Randleman, North Carolina. Earlier that day, defendant had
driven David and another individual, Walter Rodriguez, to purchase drugs.
Afterward, an altercation broke out between defendant and David, during which
defendant elbowed David in the nose, resulting in a broken nose and visible injuries.
Despite the altercation, the group returned to David’s home later that evening, where
David entered the house, leaving defendant outside near his vehicle.
William, who was on the porch, approached defendant to inquire about David’s
injuries. Witnesses observed the two men conversing without any visible signs of
aggression. Moments later, a gunshot was heard, and William was seen running
toward the house, bleeding from a gunshot wound to the chest. William collapsed
inside and was pronounced dead later that night. Witnesses testified they did not see
William brandishing a weapon during the interaction.
Defendant fled the scene and was apprehended two days later. During a
standoff with law enforcement, defendant claimed he acted in self-defense, alleging
William had attacked him with a tree-climbing spike. However, a search of the scene
yielded no evidence of such a weapon, and testimony at trial described the spike as a
-2- STATE V. MEDLEY
large, conspicuous object that would have been difficult to conceal.
At trial, defendant was charged with second-degree murder in violation of
N.C.G.S. § 14-17. During the charge conference, the trial court agreed to instruct the
jury on second-degree murder and self-defense using the pattern jury instructions.
The court also provided an instruction on flight as evidence of consciousness of guilt.
Both the State and the defense reviewed and approved the final instructions before
they were given to the jury.
During deliberations, the jury asked for clarification regarding the size and
weight of defendant and the victim, but the trial court informed them that no
additional evidence could be provided and that they must rely on the evidence
presented at trial. The jury ultimately found defendant guilty of second-degree
murder, and he was sentenced to an active prison term of 483 to 592 months.
Defendant filed a timely notice of appeal.
II.
A.
During the charge conference, the trial court, in consultation with both parties,
agreed to provide the substantive instruction for second-degree murder involving the
use of a deadly weapon, along with all lesser-included offenses and self-defense
(N.C.P.I. — Crim. 206.30). This instruction was modified to exclude references to the
aggressor doctrine. However, the court entirely omitted the “no duty to retreat”
provisions contained in N.C.P.I. — Crim. 206.30 and failed to include the “stand-your-
-3- STATE V. MEDLEY
ground” instruction from N.C.P.I. — Crim. 308.10, which is incorporated by reference
in footnote 4 of N.C.P.I. — Crim. 206.30.
These omissions resulted in a deviation from the agreed-upon pattern jury
instruction. As established in State v. Lee, 370 N.C. 671, 676 (2018), when a trial
court departs from an agreed pattern instruction, the issue is preserved for appellate
review without the need for further objection.
B.
Challenges to the trial court’s jury instructions are reviewed de novo. State v.
Osorio, 196 N.C. App. 458, 466 (2009). Employing de novo review, this Court
considers the matter anew and freely substitutes its own judgment for that of the
trial court. State v. Williams, 362 N.C. 628, 632–33 (2008).
When competent evidence of self-defense is introduced at trial, a defendant is
entitled to a jury instruction on self-defense that includes the applicable stand-your-
ground provision. See Lee, 370 N.C. at 674; State v. Bass, 371 N.C. 456, 542 (2018).
The statutory framework for perfect self-defense in North Carolina is outlined in
N.C.G.S. § 14-51.3(a)(1) and has been further clarified in case law. See State v.
McLymore, 380 N.C. 185, 191 (2022) (holding that N.C.G.S. § 14-51.3 supplants the
common law right to perfect self-defense and provides the exclusive statutory
framework for such claims). When determining whether a perfect self-defense
instruction is required, the evidence must be viewed in the light most favorable to the
defendant. State v. Moore, 363 N.C. 793, 796 (2010).
-4- STATE V. MEDLEY
The State concedes that defendant was entitled to a perfect self-defense
instruction, which should have informed the jury that defendant had no duty to
retreat. The State further acknowledges that the trial court erred in omitting this
instruction.
As defendant acknowledges, to establish reversible error from the trial court’s
omission, he must show that the omission resulted in prejudice. An error is
considered prejudicial only if “there is a reasonable possibility that, had the error in
question not been committed, a different result would have been reached at the trial
out of which the appeal arises.” State v. Phillips, 386 N.C. 513 (2024) (quoting
N.C.G.S. § 15A-1443(a)); Lee, 370 N.C. at 676. This analysis requires an evaluation
of the strength of the State’s evidence supporting the conviction and whether the
jury’s considerations suggest they might have reached a different conclusion with the
omitted instruction. State v. Brichikov, 383 N.C. 543, 557 (2022).
The burden is on the defendant to establish the existence of such prejudice on
appeal. State v. Tatum-Wade, 229 N.C. App. 83, 94 (2013). A defendant cannot rely
on a bare assertion of prejudice but must specifically explain how the error affected
the jury’s verdict. Id. at 94–95; State v. Bailey, 280 N.C. 264, 269 (1972). A
“particularized argument” showing the impact of the error is required to meet this
burden. Tatum-Wade, 229 N.C. App. at 94–95. Speculative claims or mere assertions
are insufficient. State v. Garcell, 363 N.C. 10, 58 (2009); State v. Frye, 341 N.C. 470,
494 (1995).
-5- STATE V. MEDLEY
In this case, defendant has failed to demonstrate a reasonable possibility that
the trial court’s error affected the jury’s verdict.
III.
Defendant contends the trial court erred by omitting the no-duty-to-retreat
and stand-your-ground provisions from the jury’s self-defense instructions. He
argues this omission deprived the jury of the proper legal framework to evaluate his
self-defense claim under N.C.G.S. § 14-51.3, which provides that a person lawfully
present at the scene has no duty to retreat before using defensive force. Defendant
further asserts that the omission created ambiguity about his right to stand his
ground, potentially leading the jury to infer that he was required to retreat. He
claims this error undermined his right to a fair trial and improperly shifted the
burden of proof, which rests with the State, resulting in prejudice. Citing N.C.G.S. §
15A-1443(a), defendant argues the incomplete instructions likely misled the jury and
affected the verdict, warranting a new trial.
The evidence at trial overwhelmingly refuted defendant’s claim of self-defense.
Witnesses consistently testified that the victim was unarmed and posed no imminent
threat to defendant. Law enforcement conducted a thorough search of the scene and
found no tree-climbing spike or other weapon matching defendant’s description.
Furthermore, the knives recovered from the victim’s pockets were significantly
smaller and of a different shape than the purported weapon, and neither showed any
signs of blood or use. The absence of any corroborating evidence for defendant’s
-6- STATE V. MEDLEY
version of events, coupled with testimony from multiple witnesses, strongly
undermined his credibility.
Additionally, defendant’s flight from the scene and subsequent actions—
evading law enforcement, attempting to conceal evidence, and engaging in a two-hour
standoff—were inconsistent with a claim of justified self-defense. These behaviors
demonstrated a consciousness of guilt that further supported the jury’s verdict.
The record contains no evidence that the jury based its decision on defendant’s
failure to retreat. During deliberations, the jury’s questions focused on the
comparative size and strength of defendant and the victim—factors directly relevant
to the reasonableness of defendant’s use of force. This indicates the jury concentrated
on evaluating the proportionality of defendant’s response to the alleged threat rather
than on whether defendant should have retreated.
Moreover, the State did not argue that defendant was required to retreat or
suggest that his failure to do so was culpable. Unlike in Lee, where the State
explicitly emphasized the defendant’s failure to retreat, 370 N.C. at 676, the
arguments in this case centered on the implausibility of defendant’s account and the
strength of the evidence against him.
Defendant’s argument for prejudice relies on speculative assertions rather
than particularized evidence. While defendant contends the omission of the “no duty
to retreat” instruction left the jury with a “misleading and incomplete” understanding
of self-defense, he has not identified any specific aspect of the trial or the jury’s
-7- STATE V. MEDLEY
deliberations that supports this claim. As the court held in State v. Tatum-Wade, a
bare assertion of prejudice is insufficient; the defendant must provide a detailed
explanation of how the error affected the verdict. 229 N.C. App. at 94. Here, no such
explanation has been provided.
IV.
Given the overwhelming evidence of guilt, the absence of any indication that
the jury considered defendant’s failure to retreat, and the speculative nature of
defendant’s prejudice argument, the omission of the “no duty to retreat” instruction
does not warrant reversal. Accordingly, we discern no prejudicial error in the trial
court’s written judgment and order of commitment.
NO PREJUDICIAL ERROR.
Judges ZACHARY and COLLINS concur.
Report per Rule 30(e).
-8-