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6 North Carolina opinions name it 1 courts 2022–2026 6 in the last five years
The cases below were cited by North Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
State v. Bursellgreen2 sentences2026Stat. § 14-51.4 (1), concluding that the provision “does incorporate a causal nexus requirement” and therefore, “the trial court committed an instructional error when it misstated the requirements of the felony disqualifier at [the defendant]’s trial.” Id. at 192 , 868 S.E.2d at 73. 2025The North Carolina Supreme Court clarified in State v. McLymore, 380 N.C. -6- 185, 868 S.E.2d 67 (2022), that Section 14-51.4(1) incorporates a causal nexus requirement. | 3 | 3 |
State v. Gomolagreen2 sentences2022“In determining whether the instruction is supported by the evidence, the evidence must be viewed in the light most favorable to the defendant.” State v. Gomola, 257 N.C. App. 816, 820 , 810 S.E.2d 797, 801 (2018) (emphasis omitted). ¶ 26 At trial, the following evidence was presented that, when taken in a light most favorable to Defendant, would support a defense of others instruction and a causal nexus instruction: Ciara testified that Michael had a history of violent and aggressive behavior towards her. 2022“In determining whether the instruction is supported by the evidence, the evidence must be viewed in the light most favorable to the defendant.” State v. Gomola, 257 N.C. App. 816, 820 , 810 S.E.2d 797, 801 (2018) (emphasis omitted). ¶ 26 At trial, the following evidence was presented that, when taken in a light most favorable to Defendant, would support a defense of others instruction and a causal nexus instruction: Ciara testified that Michael had a history of violent and aggressive behavior towards her. | 2 | 2 |
State v. Carwilegreen1 sentence2026Critically, after reviewing the jury instructions in their entirety, see Carwile, 297 N.C. App. at 157, we conclude the jury instructions accurately stated the law, and are therefore upheld, see Roache, 358 N.C. at 303 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in North Carolina. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Roache
green
1 sentence2026Critically, after reviewing the jury instructions in their entirety, see Carwile, 297 N.C. App. at 157, we conclude the jury instructions accurately stated the law, and are therefore upheld, see Roache, 358 N.C. at 303 . | 1 | 2026–2026 |
State v. Vaughn
green
2 sentences2025Indeed, this Court has stated “Where the State introduces such evidence, the existence of a causal nexus is a jury determination[.]” State v. Vaughn, 293 N.C. App. 770 , 777, 901 S.E.2d 260 , 266 (2024). -7- Here, the trial court properly instructed the jury on the causal nexus requirement: Additionally, self-defense is not available to a person who used defensive force and who was attempting to commit or committing a felony. 2025Indeed, this Court has stated “Where the State introduces such evidence, the existence of a causal nexus is a jury determination[.]” State v. Vaughn, 293 N.C. App. 770 , 777, 901 S.E.2d 260 , 266 (2024). -7- Here, the trial court properly instructed the jury on the causal nexus requirement: Additionally, self-defense is not available to a person who used defensive force and who was attempting to commit or committing a felony. | 1 | 2025–2025 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.