State v. Murell

CourtCourt of Appeals of North Carolina
DecidedOctober 15, 2025
Docket24-1004
StatusUnpublished

This text of State v. Murell (State v. Murell) 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. Murell, (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An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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. COA 24-1004

Filed 15 October 2025

Buncombe County, Nos. 20CRS081859-100, 20CRS082704-100

STATE OF NORTH CAROLINA

v.

WILLIAM TODD MURELL, Defendant.

Appeal by defendant from judgment entered 13 November 2023 by Judge

David Strickland in Buncombe County Superior Court. Heard in the Court of Appeals

10 September 2025.

Attorney General Jeff Jackson, by Special Deputy Attorney General Robert C. Ennis, for the State.

The Sweet Law Firm, PLLC, by Kaelyn N. Sweet, for defendant-appellant.

DILLON, Chief Judge.

Defendant William T. Murell appeals from judgment entered by the trial court

upon a jury verdict convicting him of first-degree forcible rape. Defendant contends

that certain witness testimony violated his rights guaranteed by the Confrontation

Clause of the Sixth Amendment. Defendant also argues that the trial court erred

when it failed to declare a mistrial ex mero motu after certain evidence was published STATE V. MURELL

Opinion of the Court

to the jury. For the reasoning below, we conclude Defendant received a fair trial, free

of reversible error.

I. Background

Defendant and Nina1 met at a detox facility where both received treatment for

alcohol addiction. Eventually, after both left the facility, Nina ended up at

Defendant’s apartment. Over the course of a few days, Defendant forced Nina to

drink alcohol, physically and emotionally abused her, and subjected her to sexual

assault. Nina was later removed from Defendant’s apartment with the help of her

ex-wife (“Ex-wife”) and others. After being hospitalized for her injuries, Nina

underwent a sexual assault nurse examination (“SANE”) conducted by nurse

Courtney Sullivan of Mission Hospital. Subsequently, Defendant was charged and

indicted for various crimes including first-degree forcible rape, and the case

proceeded to a jury trial.

At trial, the State offered testimony from nurse Jacquelline Maillet, rather

than Nurse Sullivan, to explain the SANE report and Nina’s injuries. Additionally,

the State played a video for the jury which referred to previously excluded evidence.

The trial court, however, did not declare a mistrial. The jury convicted Defendant of

first-degree assault inflicting serious bodily injury and first-degree forcible rape.

Defendant timely appeals.

1 A pseudonym.

-2- STATE V. MURELL

II. Analysis

Defendant makes two arguments on appeal, which we address in turn.

A. The Confrontation Clause

Defendant argues his rights under the Confrontation Clause were violated.

Specifically, he contends the trial court erred by allowing a surrogate witness to

testify about the contents of Nurse Sullivan’s SANE report despite Defendant’s

constitutional guarantee to confront witnesses against him. Assuming, but not

deciding, the admission of this evidence violated the Sixth Amendment, we hold the

error was harmless.

We review de novo alleged violations of a defendant’s constitutional rights and

questions of law regarding conformity to the Rules of Evidence. State v. Abbitt, 385

N.C. 28, 40 (2023).

The Confrontation Clause of the Sixth Amendment provides “[i]n all criminal

prosecutions, the accused shall enjoy the right . . . to be confronted with the witnesses

against him.” U.S. Const. amend. VI. The Clause, however, comes into play when

the State seeks to introduce testimonial hearsay. Smith v. Arizona, 602 U.S. 779, 784

(2024); see also State v. Lester, 387 N.C. 90, 96 (2025). If a statement qualifies as

“testimonial hearsay,” but the person who made the statement does not testify at

trial, then “the ‘Sixth Amendment demands what the common law required:

unavailability and a prior opportunity for cross-examination.’” Lester, 387 N.C. at 97

-3- STATE V. MURELL

(quoting Michigan v. Bryant, 562 U.S. 344, 354 (2011)).

Our General Statutes, after a constitutional violation is shown, place the

burden on the State to “demonstrate, beyond a reasonable doubt, that the error was

harmless.” N.C.G.S. § 15A-1443(b) (2023); see also State v. King, 386 N.C. 601, 608

(2024) (explaining that a defendant is entitled to a fair trial, not a perfect trial, and

thus, if a constitutional violation is harmless, a defendant is not entitled to reversal).

In assessing whether a Confrontation Clause violation was harmless, we look to see

whether “other ‘competent overwhelming evidence of defendant’s guilt exist[s].’”

State v. Lewis, 361 N.C. 541, 544, 549 (2007).

After being removed from Defendant’s apartment, Nina was taken to a local

hospital where her extensive injuries were documented, and a CT scan indicated a

severe and potentially fatal head injury. Due to Nina’s head injury, she was

transferred to Mission Hospital where she was interviewed by Nurse Sullivan. Nurse

Sullivan completed a SANE and compiled the photographs she took and Nina’s

interview statements into a report.

When the case came for trial, Nurse Sullivan no longer worked at Mission

Hospital; and the State opted to call Nurse Maillet, the program coordinator at

Mission Hospital, as an expert on SANE reports to testify regarding the contents of

Nurse Sullivan’s SANE report. The trial court overruled Defendant’s objection to

Nurse Maillet’s testimony based on the Confrontation Clause.

During the State’s direct, Nurse Maillet walked through each component of the

-4- STATE V. MURELL

SANE report and opined on whether Nurse Sullivan’s photographs were consistent

with the statements in the report from Nina to Nurse Sullivan.

Defendant claims he was prejudiced by this testimony as the testimony

supported two of the elements of the crime for which Defendant was convicted.

Defendant was convicted of first-degree forcible rape, which required the State

to prove, in part, that Defendant “use[d], threatene[d] to use, or display[ed] a

dangerous or deadly weapon” and/or “inflict[ed] serious personal injury upon the

victim.” N.C.G.S. § 14-27.21(a)(1), (2) (2023). Defendant argues Nurse Maillet’s

testimony about Nurse Sullivan’s SANE report was offered by the State to prove these

two elements.

With respect to the “dangerous or deadly weapon” element of § 14-27.21, the

jury only found that Defendant committed first-degree forcible rape by inflicting

serious personal injury upon Nina. To that end, because the jury did not convict

Defendant under the deadly weapon theory, Defendant’s contention that the trial

court reversibly erred in allowing the SANE report statements which stated

Defendant “held a knife to [Nina’s] neck” did not contribute to his conviction. Thus,

this error was harmless. See State v. Bunch, 363 N.C. 841, 845 (2010) (“On a general

level, ‘[a]n error is harmless beyond a reasonable doubt if it did not contribute to the

defendant’s conviction.’ ”). Accordingly, we limit our analysis to the issue of “serious

personal injury.”

“Serious personal injury” may be proven by either mental or bodily injury.

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Related

State v. Baker
441 S.E.2d 551 (Supreme Court of North Carolina, 1994)
State v. Blizzard
610 S.E.2d 245 (Court of Appeals of North Carolina, 2005)
State v. Herring
370 S.E.2d 363 (Supreme Court of North Carolina, 1988)
State v. Blackstock
333 S.E.2d 245 (Supreme Court of North Carolina, 1985)
State v. Bunch
689 S.E.2d 866 (Supreme Court of North Carolina, 2010)
State v. Boone
297 S.E.2d 585 (Supreme Court of North Carolina, 1982)
State v. Taylor
669 S.E.2d 239 (Supreme Court of North Carolina, 2008)
State v. Lewis
648 S.E.2d 824 (Supreme Court of North Carolina, 2007)
Michigan v. Bryant
179 L. Ed. 2d 93 (Supreme Court, 2011)
Smith v. Arizona
602 U.S. 779 (Supreme Court, 2024)

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