State v. Patton

CourtCourt of Appeals of North Carolina
DecidedAugust 1, 2023
Docket22-994
StatusPublished

This text of State v. Patton (State v. Patton) 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. Patton, (N.C. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA22-994

Filed 01 August 2023

Buncombe County, Nos. 19CRS080481, 20CRS091146 & 21CRS000101

STATE OF NORTH CAROLINA

v.

RONALD EUGENE PATTON, Defendant.

Appeal by Defendant from judgments entered 13 November 2021 by Judge

Karen Eady-Williams in Buncombe County Superior Court. Heard in the Court of

Appeals 9 May 2023.

Attorney General Joshua H. Stein, by Special Deputy Attorney General Stephanie A. Brennan, for the State.

W. Michael Spivey for Defendant-Appellant.

RIGGS, Judge.

Defendant Ronald Eugene Patton appeals from several judgments entered

after a jury found him guilty of second-degree forcible sexual offense, intimidating or

interfering with a witness, and attaining habitual felon status. On appeal, Mr.

Patton contends that the trial court: (1) lacked jurisdiction over the interfering with

a witness charge because the criminal conduct alleged in the indictment—bribery—

is not encompassed in the relevant statute, N.C. Gen. Stat. § 14-226 (2021); (2) erred

in denying his motion to dismiss that same charge for insufficient evidence of the STATE V. PATTON

Opinion of the Court

requisite criminal intent; and (3) prejudicially or plainly erred in its jury instruction

on witness interference. After careful review, we hold that: (1) bribery of a witness is

criminalized by N.C. Gen. Stat. § 14-226 such that the trial court had jurisdiction

over the charged offense; (2) the trial court properly denied Mr. Patton’s motion to

dismiss that charge; and (3) Mr. Patton’s alleged jury instruction arguments are

without merit.

I. FACTUAL AND PROCEDURAL HISTORY

J.L.A. (“Jane”) moved to Asheville, North Carolina from Ohio in February

2017. One day when she was waiting for the bus to take her to work, Mr. Patton

approached her and offered her some marijuana. Jane declined and boarded the bus

without further conversation with Mr. Patton. Later, Jane again ran into Mr. Patton

at the bus station as she was heading home; this time, Jane took down Mr. Patton’s

number in case she ever wanted to buy marijuana from him.

Jane waited to contact Mr. Patton for some time, but she did eventually text

message him to ask about buying marijuana. Mr. Patton obliged Jane’s request and

began selling marijuana to her. The two struck up a friendship, with Jane calling

Mr. Patton “grandpa” because he was twice her age. After several drug transactions,

Mr. Patton told Jane that he would give her $40 worth of marijuana in exchange for

sex; Jane responded by cursing at him and threatening to cut off contact.

Jane ceased talking to Mr. Patton after the above exchange. She resumed

contact with him out of desperation, and Mr. Patton gave her furniture and clothing

-2- STATE V. PATTON

and helped her buy a car. He also continued to supply her with marijuana and make

sexual comments to her, though Jane never reciprocated with any showing of

romantic or sexual interest.

On the night of 10 January 2019, Mr. Patton and Jane were together at her

house drinking wine, smoking marijuana, and watching movies. Mr. Patton ended

up staying over at Jane’s house, as he had arrived after the buses had ceased running

for the evening. Jane eventually fell asleep on the floor while Mr. Patton continued

to watch TV on her couch. She later awoke to Mr. Patton grinding his groin against

her backside through her blanket and leggings. Jane told Mr. Patton to stop and get

off her, but he instead held her down, shoved her head into a pillow, and continued

to thrust against her while groping her body. Jane fought back against Mr. Patton,

punching and scratching him in the face. After getting free and heading for the front

door to escape, Jane was grabbed from behind by her hair and dragged into the

bedroom by Mr. Patton.

Once in the bedroom, Mr. Patton released Jane to let her go to the bathroom;

as soon as she was finished, he grabbed her by the hair again. Mr. Patton then told

Jane to fellate him and that he would strip her and tie her up if she refused. Jane

refused and lied to him about having HIV in the hopes that he would not rape her;

Mr. Patton instead continued to try and force his penis into her mouth. He then

pushed her back onto the bed and tried to smother her with a pillow. When Jane

continued to struggle, Mr. Patton wrapped a cell phone charger cord around her neck

-3- STATE V. PATTON

to choke her. Mr. Patton eventually forced his penis into Jane’s mouth and

ejaculated, causing her to vomit.

Mr. Patton released Jane, and she immediately went to the bathroom to

continue vomiting. When she returned to the bedroom, Mr. Patton held her by her

wrist and walked her through the house as he collected his belongings. He then left

the house and got into a car that was waiting for him outside, whereupon Jane called

the police to report the assault. Law enforcement responded to the call, interviewed

Jane, photographed the scene, and collected physical evidence corroborating Jane’s

account. Jane went to the hospital with a police officer, where DNA evidence was

collected from Jane’s hair, fingernails, nose, and cheek.

On 4 February 2019, Mr. Patton was indicted for one count each of first-degree

forcible sex offense, first-degree kidnapping, and assault by strangulation. After Mr.

Patton’s arrest and while he was in jail, Jane received a call from an inmate,

purportedly named “Richie,” at the Buncombe County Jail. When Jane answered the

call and asked who was calling, Mr. Patton identified himself and the following

conversation ensued:

MR. PATTON: This is Gene.

JANE: Why are you calling me?

MR. PATTON: If you’re still in Asheville I’m gonna try and send you some money.

JANE: This is who?

-4- STATE V. PATTON

JANE: Why are you calling me? You’re not supposed to be talking to me.

MR. PATTON: I got $1,000 for ya.

Jane immediately hung up the phone; her tone of voice during the conversation

clearly conveyed a sense of distress. Mr. Patton called Jane again, but she did not

answer because she had blocked the number. Jane informed law enforcement of the

call and, on 1 March 2021, Mr. Patton was indicted with intimidating or interfering

with a witness in violation of N.C. Gen. Stat. § 14-226.

The State obtained a superseding indictment for forcible sexual offense and an

additional indictment for attaining habitual felon status ahead of trial. At trial, Jane

testified consistent with the above recitation of the facts, and the jailhouse phone call

was published to the jury. Jane testified that, after receiving the call, “I was shocked,

because, like, you’re not supposed to be contacting me. . . . I felt like he was trying to

bribe me trying to get out of what he done to me, like, no.”

Mr. Patton’s counsel moved to dismiss the charges against him at the close of

the State’s case-in-chief and at the close of all evidence; the trial court denied both

motions. The trial court then held the charge conference, during which the parties

discussed the appropriate instruction for the charge of interfering with a witness.

That conversation included the following objection from Mr. Patton’s counsel

concerning reference to the specific act of offering Jane $1,000 in the trial court’s

-5- STATE V. PATTON

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State v. Patton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-patton-ncctapp-2023.