State v. Stephens

CourtCourt of Appeals of North Carolina
DecidedNovember 5, 2025
Docket24-590
StatusPublished

This text of State v. Stephens (State v. Stephens) 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. Stephens, (N.C. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-590

Filed 5 November 2025

Dare County, Nos. 15CRS051041-270, 15CRS051200-270, 15CRS051330-270, 15CRS051331-270, 15CRS051332-270, 15CRS051333-270, 15CRS051334-270, 15CRS051335-270, 15CRS051336-270, 17CR000013-270

STATE OF NORTH CAROLINA

v.

JERRY WAYNE STEPHENS, JR., Defendant.

Appeal by defendant from judgments entered 31 July 2023 by Judge Jerry R.

Tillett in Superior Court, Dare County. Heard in the Court of Appeals 29 January

2025.

Attorney General Jeff Jackson, by Assistant Attorney General Miranda S. Holley, for the State.

Appellate Defender Glenn Gerding, by Assistant Appellate Defender Amanda S. Zimmer, for defendant-appellant.

STROUD, Judge.

Defendant appeals the trial court’s judgments revoking his probation and

activating his sentence. The trial court lacked jurisdiction to revoke Defendant’s

probation in file numbers 15CRS051200, 15CRS051330-36, and 17CRS000013

because it did not enter its judgments until after Defendant’s probationary period

had expired. We therefore vacate those judgments. But we affirm Defendant’s

judgment in file number 15CRS051041 because the violation reports sufficiently STATE V. STEPHENS

Opinion of the Court

alleged absconding as the grounds for Defendant’s probation violation, and the trial

court did not abuse its discretion in finding that Defendant willfully absconded from

supervision.

I. Background

In 2015 and 2017, the State indicted Defendant for various crimes involving

drug use, breaking and entering, and larceny after breaking and entering. Although

these charges included file numbers that were and were not subjects of this appeal,

we limit our discussion to those file numbers Defendant included in his notice of

appeal: 15CRS051041, 15CRS051200, 15CRS051330-36, and 17CRS000013.

Defendant pled no contest to all the relevant charges on or about 31 July 2017. The

trial court sentenced Defendant to an active sentence in certain file numbers not

subject to this appeal. For each file number in this appeal, the court suspended his

ten-month to twenty-one-month active sentence and placed him on supervised

probation for thirty-six months. On the Judgment Suspending Sentence for file

number 15CRS051041, the trial court checked box 3 in the “suspension of sentence

section,” indicating that “[t]his period of probation shall begin when . . . [D]efendant

is released from incarceration.” The court did not check this box on the remaining

nine appealed judgments. During sentencing, the trial court stated that the

“sentences will run consecutively in each case, probation concurrently.”

After Defendant’s release from prison, the State filed probation violation

reports with the trial court on 4 October 2021. The reports alleged that Defendant

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tested positive for illicit substances. On or about 31 May 2022, the trial court

modified Defendant’s probation in the appealed charges, extended his probation for

eighteen months, and ordered him to comply with recovery court. The court issued

orders for Defendant’s arrest on or about 10 July 2023 after Defendant failed to

comply with the recovery court’s requirements. Additional probation violation

reports, dated 24 July 2023, alleged that Defendant: owed arrearages “in the amount

of $35,000.00”; failed to notify his probation officer of his whereabouts; and failed to

submit to urine testing (as well as other similar violations regarding Defendant’s

supervision). The same judge who originally sentenced Defendant and extended his

probation presided over Defendant’s probation revocation hearing on 1 August 2023.

The trial court entered judgments that same day finding that Defendant

willfully violated his probation and checked the box stating that the court revoked

Defendant’s probation for “willful violation of the condition(s) that he[ ] not commit

any criminal offense . . . or abscond from supervision.” The trial court revoked

Defendant’s probation and activated his sentence. On 7 August 2023, Defendant

entered written notice of appeal in the above-referenced file numbers.

II. Analysis

Defendant presents two arguments regarding the trial court’s jurisdiction to

revoke his probation. First, as to the judgments in file numbers 15CRS051200,

15CRS051330-36, and 17CRS000013, Defendant argues that the trial court lacked

jurisdiction to revoke his probation after the probationary period expired. Second,

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Defendant claims the trial court was without jurisdiction to revoke his probation in

file number 15CRS051041 because the violation report failed to provide him

“adequate notice” of the State’s intent to revoke his probation for absconding from

Defendant also argues that the trial court abused its discretion in finding he

willfully absconded from supervision and further erred in setting an anticipatory

bond as a condition to his probation. For the following reasons, we vacate Defendant’s

judgments in file numbers 15CRS051200, 15CRS051330-36, and 17CRS000013, but

affirm the judgment in file number 15CRS051041.

A. Expiration of Probationary Period

We first address whether “the trial court lacked jurisdiction to revoke

[Defendant’s] probation because the probationary period had expired[,]” as it is

dispositive for several of the probation violations. We agree with Defendant that his

probation expired in file numbers 15CRS051200, 15CRS051330-36, and

17CRS000013 before the judgments revoking his probation were entered and thus

vacate those judgments.

The issue of a court’s jurisdiction over a matter may be raised at any time, even for the first time on appeal or by a court sua sponte. It is well settled that a court’s jurisdiction to review a probationer’s compliance with the terms of his probation is limited by statute. An appellate court necessarily conducts a statutory analysis when analyzing whether a trial court has subject matter jurisdiction in a probation revocation hearing, and thus conducts a de novo review. Under a de novo review, the court considers the

-4- STATE V. STEPHENS

matter anew and freely substitutes its own judgment for that of the lower tribunal.

State v. Tincher, 266 N.C. App. 393, 395, 831 S.E.2d 859, 861-62 (2019) (citations,

quotation marks, and brackets omitted).

North Carolina General Statute Section 15A-1346 provides for

“commencement of probation” and states:

(a) Commencement of Probation.--Except as provided in subsection (b), a period of probation commences on the day it is imposed and runs concurrently with any other period of probation, parole, or imprisonment to which the defendant is subject during that period.

(b) Consecutive and Concurrent Sentences.--If a period of probation is being imposed at the same time a period of imprisonment is being imposed or if it is being imposed on a person already subject to an undischarged term of imprisonment, the period of probation may run either concurrently or consecutively with the term of imprisonment, as determined by the court. If not specified, it runs concurrently.

N.C. Gen. Stat. § 15A-1346 (2023) (emphasis added).

In Tincher, the defendant’s “probation was revoked in both file 06 CRS 51515

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Related

State v. Robinson
103 S.E.2d 376 (Supreme Court of North Carolina, 1958)
State v. Hilbert
549 S.E.2d 882 (Court of Appeals of North Carolina, 2001)
State v. Tennant
540 S.E.2d 807 (Court of Appeals of North Carolina, 2000)
State v. Lawing
182 S.E.2d 10 (Court of Appeals of North Carolina, 1971)
State v. Campbell
617 S.E.2d 1 (Supreme Court of North Carolina, 2005)
State v. Pennell
758 S.E.2d 383 (Supreme Court of North Carolina, 2014)
In re J.C.
783 S.E.2d 202 (Court of Appeals of North Carolina, 2014)
State v. Harwood
777 S.E.2d 116 (Court of Appeals of North Carolina, 2015)
State v. Johnson
782 S.E.2d 549 (Court of Appeals of North Carolina, 2016)
State v. Trent
803 S.E.2d 224 (Court of Appeals of North Carolina, 2017)
State v. Moore
807 S.E.2d 550 (Supreme Court of North Carolina, 2017)
State v. Melton
811 S.E.2d 678 (Court of Appeals of North Carolina, 2018)
State v. Tincher
831 S.E.2d 859 (Court of Appeals of North Carolina, 2019)

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