State v. Vaughn

CourtCourt of Appeals of North Carolina
DecidedNovember 19, 2025
Docket24-1089
StatusPublished

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

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-1089

Filed 19 November 2025

New Hanover County, Nos. 23CR224178-640, 23CR224179-640

STATE OF NORTH CAROLINA

v.

MICHAEL VAUGHN

Appeal by Defendant from judgments entered 19 April 2024 by Judge Bob R.

Cherry following jury verdicts in New Hanover County Superior Court. Heard in the

Court of Appeals 13 August 2025.

Attorney General Jeff Jackson, by Assistant Attorney General Allison C. Hawkins, for the State.

Center for Death Penalty Litigation, by Ryan Christopher Kuchinski, for the Defendant.

WOOD, Judge.

Michael Vaughn (“Defendant”) appeals from judgments following jury verdicts

finding him guilty of providing false information to a firearms dealer and attempted

possession of a firearm by a convicted felon. On appeal, Defendant raises three

issues: (1) the trial court erred when it denied Defendant’s Motion to Dismiss both

the providing false information charge and attempted possession charge at the close

of the State’s evidence and again at the close of all evidence; (2) the trial court STATE V. VAUGHN

Opinion of the Court

prejudicially erred when it failed to instruct the jury it was required to find Defendant

intended to possess a firearm as a felon and committed an overt act toward such

possession as the elements of attempt; and (3) North Carolina’s statute banning

felons from possessing firearms is unconstitutional. After careful review of the

record, we conclude the trial court erred by failing to instruct the jury on the elements

of attempt and, when paired with the State’s erroneous statements of the law during

closing arguments, it constituted prejudicial error.

I. Factual and Procedural Background

In 2002, Defendant pleaded guilty to possession of cocaine, resulting in a felony

conviction. On 28 November 2022, Defendant decided to pawn a watch because he

was low on money for bills and gas. While at the pawn shop Defendant began talking

to the clerk about obtaining a weapon for self-defense. Defendant decided to put a

shotgun on layaway. He made an initial payment toward the purchase price of the

shotgun but could not complete the necessary forms because his identification did not

match his current address.

In January 2023, Defendant returned to the pawn shop to pay off the balance

remaining on the shotgun, at which time he was asked to complete a federal firearms

transaction record (“ATF form 4473”). One of the questions on the ATF form 4473 is,

“Have you ever been convicted in any court, including a military court, of a felony or

any other crime for which the judge could have imprisoned you for more than one

year, even if you received a shorter sentence, including probation?” Defendant

-2- STATE V. VAUGHN

indicated “no” despite his 2002 felony conviction. As a result, Defendant’s application

to purchase the firearm was denied. The clerk informed Defendant of the denial but

could not explain why when asked.

Two days after Defendant attempted to purchase the shotgun, Detective Troy

Herman (“Detective Herman”) from the Wilmington Police Department received

notification of the failed attempted purchase, including the information Defendant

provided on the ATF form 4473. The detective verified the information on the

application, which was accurate apart from the response concerning the previous

felony conviction. He also obtained copies of the security videos from the shop and on

31 January 2023 took out arrest warrants on Defendant for possession of a firearm

by a felon and providing false information to a firearms dealer.

On 5 March 2023, the Burgaw police surrounded Defendant’s home with guns

drawn. Defendant came to the door very confused. The police read him the charges

regarding the possession of a firearm and he responded, “I’ve never had a gun.” The

Burgaw officer informed him the charges were from New Hanover County.

Defendant was confused and thought the situation was “so crazy” but complied with

the officers.

On 17 April 2024, Defendant’s case came on for trial. Defendant testified in

his own defense. He testified that in 2013 he attended an expunction clinic held at a

library and met with an attorney to have his conviction expunged in order to improve

his job prospects. Defendant testified that he gave the attorney the details about his

-3- STATE V. VAUGHN

2002 conviction, and the attorney stated he had all he needed to complete the

expunction paperwork and Defendant did not need to come back. Afterwards,

Defendant believed his conviction had been expunged, as he went on to hold jobs that

required background checks including one at the United States military base at Camp

Lejeune. He had “no problem” passing the background check and being allowed on

and off base.

At the close of State’s evidence Defendant moved to dismiss his charges for

insufficient evidence. The trial court denied the motion. At the charge conference

the parties engaged in extended discussion with the trial court about specific

instructions, including the necessity for an instruction on attempt. The trial court

noted “[t]hey’re getting the intent in there” and asked if there was a certain intent

instruction the parties desired. Defendant requested that the instruction that

possession is a general intent crime while attempt is a specific intent crime be given.

Defendant renewed his motion to dismiss at the close of all evidence. Following the

trial court’s instructions to the jury, the defense stated “I realize that you probably

should have given them an attempt instruction. So [I] know it wasn’t done at that

time, but I’m just realizing it now.” The trial court heard from the State who

responded, “intent’s defined and basically saying he intended to - - for the intent” and

left it to the trial court’s discretion. The trial court denied Defendant’s request for

additional instructions on attempt but noted Defendant’s objection saying it would

-4- STATE V. VAUGHN

only be addressed if “the jurors come back and ask for some more specific instruction

on attempt itself.”

The jury acquitted Defendant on the possession of a firearm by a felon charge

and convicted him on attempted possession of a firearm by a felon and providing

materially false information charges. The trial court sentenced Defendant to a prison

term of 8 to 19 months on the attempted possession charge and suspended his

sentence for providing false information. Defendant gave oral notice of appeal in open

court.

II. Analysis

Defendant raises three issues on appeal: (1) the trial court erred when it denied

Defendant’s Motion to Dismiss both the providing false information charge and

attempted possession charge at the close of the State’s evidence and again at the close

of all evidence; (2) the trial court prejudicially erred when it failed to instruct the jury

it was required to find Defendant intended to possess a firearm as a felon and

committed an overt act toward such possession as the elements of attempt; and (3)

North Carolina’s statute banning felons from possessing firearms is unconstitutional.

A. Motions to Dismiss

Defendant contends the State did not provide sufficient evidence to establish

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