State v. Shumate

CourtCourt of Appeals of North Carolina
DecidedAugust 20, 2025
Docket24-674
StatusUnpublished

This text of State v. Shumate (State v. Shumate) 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. Shumate, (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An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority.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. COA24-674

Filed 20 August 2025

McDowell County, No. 21CRS050306-580

STATE OF NORTH CAROLINA

v.

ROBBIE EUGENE SHUMATE, Defendant.

Appeal by defendant from judgments entered 9 March 2023 by Judge J.

Thomas Davis in McDowell County Superior Court. Heard in the Court of Appeals

24 April 2025.

Attorney General Jeff Jackson, by Assistant Attorney General Andrew L. Hayes, for the State-appellee.

Mark Montgomery for defendant-appellant.

GORE, Judge.

On 2 March 2021, defendant Robbie Eugene Shumate was charged with

statutory rape of a child who is 15 years of age or younger, statutory sexual offense

with a child who is 15 years of age or younger, and taking indecent liberties with a

child. On 9 March 2023, a jury found defendant guilty of all charges. Defendant gave

oral notice of appeal in open court. STATE V. SHUMATE

Opinion of the Court

On appeal, defendant argues the trial court erred by (1) admitting expert

testimony regarding the characteristics of sexually abused children, (2) allowing

witnesses to refer to the victim’s accusations as a “disclosure,” and (3) permitting

testimony that allegedly vouched for the victim’s credibility. Defendant further

contends trial counsel’s failure to object to the use of the term “disclosure” constituted

ineffective assistance of counsel.

This Court has jurisdiction pursuant to N.C.G.S. §§ 7A-27(b) and 15A-1444(a).

Upon review, we discern no error.

I.

In the summer of 2019, “Chris,” then thirteen years old, lived with her

biological parents. Defendant, age thirty-three, was her neighbor. They began

communicating through Facebook, and defendant gave Chris gifts, including softball

gear and soda. Over time, Chris came to view defendant as her boyfriend.

At the end of June 2019, Chris and defendant met in person. Chris testified

that they engaged in sexual intercourse on at least two occasions. Approximately one

year later, Chris disclosed the incidents to her school counselor. She subsequently

underwent a forensic interview and medical examination. The forensic interview was

conducted at Lily’s Place by Andie Longo, during which Chris provided a detailed

account of the events.

Following the interview, Elizabeth Browning, a nurse practitioner with South

Mountain Children and Family Services, conducted a physical examination of Chris.

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The examination revealed no physical abnormalities, and Chris’s symptoms and

characteristics were consistent with those of a typical teenager. Chris declined an

anogenital exam, stating she did not want to be touched.

Officer Billie Brown, a detective with the McDowell County Sheriff’s Office,

later interviewed defendant. Defendant acknowledged knowing Chris, confirmed she

had been to his house, and admitted seeing her at a motel. Officer Brown obtained

defendant’s Facebook records, though some conversations were missing from the

production. The records contained only one message, and deleted conversations were

not recovered. When questioned about the messages, defendant expressed concern

that they could get him into trouble. However, he denied having sexual intercourse

with Chris.

II.

A.

On appeal, defendant argues the trial court erred in permitting Ms. Longo to

testify regarding the general characteristics of sexually abused children. We

disagree.

“The standard of review for this Court assessing evidentiary rulings is abuse

of discretion.” State v. Boston, 165 N.C. App. 214, 218 (2004) (citation omitted). A

trial court’s ruling will only be overturned upon a showing that the decision “is

manifestly unsupported by reason or is so arbitrary that it could not have been the

result of a reasoned decision.” State v. Hennis, 323 N.C. 279, 285 (1988) (citation

-3- STATE V. SHUMATE

omitted).

Under North Carolina law, “[e]vidence that a particular child’s symptoms are

consistent with those of children who have been sexually abused is admissible (1) only

through the testimony of an expert in the field, and (2) only for the limited purpose

of aiding the jury in assessing the complainant’s credibility.” State v. Hutchens, 110

N.C. App. 455, 460 (1993) (citation omitted).

Defendant identifies two lines of questioning at trial in support of his

argument. First, the State asked Ms. Longo, “[W]hat are some general characteristics

of a . . . of a child that may have been sexually abused?” Defense counsel objected,

and the trial court sustained the objection. The State then asked, “Do all children act

the same?” Defense counsel again objected, but the trial court overruled the objection.

Ms. Longo responded, “No.”

In the second line of questioning, the State asked Ms. Longo, “And why is a

child interviewed in a different setting than an adult would be?” Ms. Longo began

explaining why adults and children are interviewed differently. Defendant objected,

and the trial court overruled the objection. Ms. Longo then completed her

explanation.

Defendant relies on Hutchens to support his argument, but Hutchens is

distinguishable. In Hutchens, a non-expert counselor testified about behavioral

patterns and symptoms exhibited by the victim, which, as recognized in State v. Hall,

330 N.C. 808 (1992), were outside the perception of a lay witness. Hutchens, 110 N.C.

-4- STATE V. SHUMATE

App. at 460. Later, an expert witness testified that sexually abused children exhibit

symptoms such as “fear, anxiety, nightmares, sleep disturbances, feelings of

responsibility, guilt, helplessness, distrust, depression, suicidal thoughts, anger,

hostility, and isolation.” Id. at 458. The expert, however, had not evaluated the

victim and testified as to general characteristics. The trial court admitted the

expert’s testimony as substantive evidence, leading this Court to order a new trial.

Id. at 461.

Here, in contrast, Ms. Longo did not testify about specific symptoms exhibited

by the complainant, Chris. Her testimony remained within permissible bounds,

addressing general forensic interview principles rather than diagnosing or opining on

Chris’s behavior. Accordingly, the trial court did not err in overruling defendant’s

objections.

B.

Defendant next argues the trial court erred by allowing Ms. Longo and Ms.

Browning to repeatedly refer to Chris’s accusation as a “disclosure,” thereby implying

that her statements were truthful. Because defendant failed to preserve this issue at

trial, we review for plain error. See N.C.R. App. P. 10(a)(4). Under plain error review,

a defendant must demonstrate a fundamental error that likely impacted the jury’s

verdict. State v. Lawrence, 365 N.C. 506, 518 (2012). Defendant contends the trial

court plainly erred by permitting impermissible vouching testimony. We disagree.

“Our case law has long held that a witness may not vouch for the credibility of

-5- STATE V. SHUMATE

a victim.” State v. Giddens, 199 N.C. App. 115, 121 (2009) (citation omitted). “The

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Hennis
372 S.E.2d 523 (Supreme Court of North Carolina, 1988)
State v. Solomon
456 S.E.2d 778 (Supreme Court of North Carolina, 1995)
State v. Boston
598 S.E.2d 163 (Court of Appeals of North Carolina, 2004)
State v. Hutchens
429 S.E.2d 755 (Court of Appeals of North Carolina, 1993)
State v. Giddens
681 S.E.2d 504 (Court of Appeals of North Carolina, 2009)
State v. Hall
412 S.E.2d 883 (Supreme Court of North Carolina, 1992)
State v. Lawrence
723 S.E.2d 326 (Supreme Court of North Carolina, 2012)

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Bluebook (online)
State v. Shumate, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-shumate-ncctapp-2025.