State v. Scott

CourtCourt of Appeals of North Carolina
DecidedJuly 6, 2021
Docket19-250-2
StatusPublished

This text of State v. Scott (State v. Scott) 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. Scott, (N.C. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2021-NCCOA-314

No. COA19-250-2

Filed 6 July 2021

Alamance County, No. 13 CRS 3976

STATE OF NORTH CAROLINA

v.

WILLIAM LEE SCOTT

Appeal by defendant from judgment entered 23 July 2018 by Judge Paul C.

Ridgeway in Alamance County Superior Court. Heard in the Court of Appeals 15

October 2019. A divided panel of this Court found no prejudicial error in defendant’s

conviction by opinion filed 21 January 2020. State v. Scott, 269 N.C. App. 457, 838

S.E.2d 676 (2020). By opinion filed 16 April 2021, the Supreme Court of North

Carolina remanded to this Court “to apply the proper standard and review this

matter[.]” State v. Scott, __ N.C. __, 2021-NCSC-41, ¶ 11 (2021).

Attorney General Joshua H. Stein, by Assistant Attorney General Kathryne E. Hathcock, for the State.

M. Gordon Widenhouse, Jr., for defendant-appellant.

TYSON, Judge.

¶1 The Supreme Court of North Carolina remanded this case to this Court to

determine whether the State has carried its burden to prove and to apply a harmless STATE V. SCOTT

Opinion of the Court

error beyond a reasonable doubt standard of review to Defendant’s claim of

constitutional error. Defendant’s blood had been unlawfully seized from a hospital

where Defendant was treated following an auto collision. This Court previously

concluded the admission of blood alcohol concentration (“BAC”) search results of

Defendant’s blood was error. On remand, we determine whether the State has proved

the Fourth Amendment seizure violation was harmless beyond a reasonable doubt.

See U.S. Const. amend. IV.

I. Fourth Amendment Search

¶2 The Fourth Amendment of the Constitution of the United States guarantees

“[t]he right of the people to be secure in their persons, houses, papers, and effects,

against unreasonable searches and seizures[.]” U.S. Const. amend. IV. The Supreme

Court of the United States observed:

[t]he interests in human dignity and privacy which the Fourth Amendment protects forbid any such intrusions on the mere chance that desired evidence might be obtained. In the absence of a clear indication that in fact such evidence will be found, these fundamental human interests require law officers to suffer the risk that such evidence may disappear unless there is an immediate search.

Schmerber v. California, 384 U.S. 757, 769-70, 16 L. Ed. 2d 908, 919 (1966). “The

[Fourth] Amendment thus prohibits ‘unreasonable searches,’ . . . [and] the taking of

a blood sample . . . is a search.” Birchfield v. North Dakota, 579 U.S. ___, ___, 195 L.

Ed. 2d 560, 575 (2016); see also State v. Romano, 369 N.C. 678, 685, 800 S.E.2d 644, STATE V. SCOTT

649 (2017) (“drawing blood . . . constitutes a search under both the Federal and North

Carolina Constitutions.”).

¶3 The Supreme Court of the United States also concluded: “The reasonableness

of a search depends on the totality of the circumstances, including the nature and

purpose of the search and the extent to which the search intrudes upon reasonable

privacy expectations.” Grady v. North Carolina, 575 U.S. 306, 310, 191 L. Ed. 2d 459

(2015) (per curiam). Blood tests: (1) “require piercing the skin and extract[tion of] a

part of the subject’s body”; (2) are “significantly more intrusive than blowing into a

tube”; and (3) place in the hands of law enforcement “a sample that can be preserved

and from which it is possible to extract information beyond a simple BAC reading.”

Birchfield, 579 U.S. at ___, 195 L. Ed. 2d at 565-66 (citations and internal quotation

marks omitted).

¶4 Without probable cause, exigent circumstances, or an exception to the warrant

requirement, a warrantless search violates the Fourth Amendment to the

Constitution of the United States. This Court unanimously agreed Defendant’s

constitutional rights were violated. State v. Scott, 269 N.C. App. 457, 465, 838 S.E.2d

676, 681 (2020), rev’d, __ N.C. __, 2021-NCSC-41 (2021). See U.S. Const. amend. IV;

State v. Welch, 316 N.C. 578, 587, 342 S.E.2d 789, 794 (1986) (interpreting the

balancing test set forth in Schmerber, 384 U.S. at 770–72, 16 L. Ed. 2d at 919-20, as

“forbidding law enforcement authorities acting without a search warrant from STATE V. SCOTT

requiring a defendant to submit to the drawing of a blood sample unless probable

cause and exigent circumstances exist to justify a warrantless seizure of the blood

sample”).

¶5 This Court also unanimously agreed Defendant’s motion to suppress should

have been allowed. Scott, 269 N.C. App. at 465, 838 S.E.2d at 681. The order

resulting in the production of the blood to the State was not based on either probable

cause or exigent circumstances. Id. at 464–65, 838 S.E.2d at 681.

¶6 We previously concluded Defendant’s Fourth Amendment rights were violated

by law enforcement officers, compelling the production and seizure of his blood from

the hospital without a warrant. We review whether the State has proved the

subsequent introduction of evidence obtained from the State Bureau of Investigation

laboratory’s analysis of Defendant’s blood and its admission at trial, was harmless

beyond a reasonable doubt.

II. Standard of Review

¶7 Upon remand, the State must show, and this Court applies a harmless error

beyond a reasonable doubt standard of review. The standard of review for federal

constitutional errors applies to this case. See State v. Ortiz-Zape, 367 N.C. 1, 13, 743

S.E.2d 156, 164 (2013) (“When violations of a defendant’s rights under the United

States Constitution are alleged, harmless error review functions the same way in

both federal and state courts.” (quoting State v. Lawrence, 365 N.C. 506, 513, 723 STATE V. SCOTT

S.E.2d 326, 331 (2012)); State v. Autry, 321 N.C. 392, 399, 364 S.E.2d 341, 346 (1988)

(“[If] the search violated defendant’s constitutional rights and . . . the evidence . . .

was improperly admitted at trial, we find any such error in its admission harmless

beyond a reasonable doubt.”); State v. Peterson, 361 N.C. 587, 594, 652 S.E.2d 216,

222 (2007).

¶8 N.C. Gen. Stat. § 15A-1443(b) “reflects the standard of prejudice with regard

to violation of the defendant’s rights under the Constitution of the United States, as

set out in the case of Chapman v. California, 386 U.S. 18, 17 L. Ed. 2d at 705 (1967).”

N.C. Gen. Stat. § 15A-1443 official cmt. (2019). The burden falls “upon the State to

demonstrate, beyond a reasonable doubt, that the error was harmless.” N.C. Gen.

Stat. § 15A-1443(b) (2019); see also Brecht v. Abrahamson, 507 U.S. 619, 630, 123 L.

Ed. 2d 353, 367 (1993); Chapman, 386 U.S. at 24; 17 L. Ed. 2d at 710-11; Lawrence,

365 N.C. at 513, 723 S.E.2d at 331. “[B]efore a federal constitutional error can be

held harmless, the court must be able to declare a belief that [the error] was harmless

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Related

Schmerber v. California
384 U.S. 757 (Supreme Court, 1966)
Chapman v. California
386 U.S. 18 (Supreme Court, 1967)
Brecht v. Abrahamson
507 U.S. 619 (Supreme Court, 1993)
State v. Autry
364 S.E.2d 341 (Supreme Court of North Carolina, 1988)
State v. Peterson
652 S.E.2d 216 (Supreme Court of North Carolina, 2007)
State v. Welch
342 S.E.2d 789 (Supreme Court of North Carolina, 1986)
State v. Lawrence
723 S.E.2d 326 (Supreme Court of North Carolina, 2012)
State v. Ortiz-Zape
743 S.E.2d 156 (Supreme Court of North Carolina, 2013)
Grady v. North Carolina
575 U.S. 306 (Supreme Court, 2015)
Davis v. Ayala
576 U.S. 257 (Supreme Court, 2015)
Birchfield v. N. Dakota. William Robert Bernard
579 U.S. 438 (Supreme Court, 2016)
State v. Romano
369 N.C. 678 (Supreme Court of North Carolina, 2017)

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State v. Scott, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-scott-ncctapp-2021.