knowing and voluntary waiver (North Carolina) · Go Syfert
← North Carolina issues

knowing and voluntary waiver in North Carolina

30 North Carolina opinions name it 3 courts 1977–2024 3 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.

Followed or applied (18)

CaseFollowedCited
State v. Dunlapgreen
nc · 1986 · cited in 9 North Carolina opinions naming this issue, 1988–2020
2 sentences

2020See State v. Dunlap, 318 N.C. 384, 389 , 348 S.E.2d 801, 805 (1986) (stating that standby counsel is not “a satisfactory substitute for the right to counsel in the absence of a knowing and voluntary waiver”).

2020See State v. Dunlap, 318 N.C. 384, 389 , 348 S.E.2d 801, 805 (1986) (stating that standby counsel is not “a satisfactory substitute for the right to counsel in the absence of a knowing and voluntary waiver”).

79
Burdine v. Texasgreen
scotus · 1995 · cited in 2 North Carolina opinions naming this issue, 2011–2011
2 sentences

2011See State v. Carter, 338 N.C. 569, 581 , 451 S.E.2d 157, 163 (1994) (“Before a defendant is allowed to waive in-court representation by counsel, the trial court must insure that constitutional and statutory standards are satisfied.” (emphasis added)), cert. denied, 515 U.S. 1107 , 132 L.

2011See State v. Carter, 338 N.C. 569, 581 , 451 S.E.2d 157, 163 (1994) (" Before a defendant is allowed to waive in-court representation by counsel, the trial court must insure that constitutional and statutory standards are satisfied." (emphasis added)), cert. denied, 515 U.S. 1107 , 115 S.Ct. 2256 , 132 L.Ed.2d 263 (1995); State v. McLeod, 197 N.C.App. 707, 715 , 682 S.E.2d 396, 400 (2009) ("N.C.

22
Sheng v. Nintendo of America, Inc.green
scotus · 1995 · cited in 2 North Carolina opinions naming this issue, 2011–2011
2 sentences

2011See State v. Carter, 338 N.C. 569, 581 , 451 S.E.2d 157, 163 (1994) (“Before a defendant is allowed to waive in-court representation by counsel, the trial court must insure that constitutional and statutory standards are satisfied.” (emphasis added)), cert. denied, 515 U.S. 1107 , 132 L.

2011See State v. Carter, 338 N.C. 569, 581 , 451 S.E.2d 157, 163 (1994) (" Before a defendant is allowed to waive in-court representation by counsel, the trial court must insure that constitutional and statutory standards are satisfied." (emphasis added)), cert. denied, 515 U.S. 1107 , 115 S.Ct. 2256 , 132 L.Ed.2d 263 (1995); State v. McLeod, 197 N.C.App. 707, 715 , 682 S.E.2d 396, 400 (2009) ("N.C.

22
State v. Cartergreen
nc · 1994 · cited in 2 North Carolina opinions naming this issue, 2011–2011
2 sentences

2011See State v. Carter, 338 N.C. 569, 581 , 451 S.E.2d 157, 163 (1994) (“Before a defendant is allowed to waive in-court representation by counsel, the trial court must insure that constitutional and statutory standards are satisfied.” (emphasis added)), cert. denied, 515 U.S. 1107 , 132 L.

2011See State v. Carter, 338 N.C. 569, 581 , 451 S.E.2d 157, 163 (1994) (“Before a defendant is allowed to waive in-court representation by counsel, the trial court must insure that constitutional and statutory standards are satisfied.” (emphasis added)), cert. denied, 515 U.S. 1107 , 132 L.

22
State v. Stanbackgreen
ncctapp · 2000 · cited in 2 North Carolina opinions naming this issue, 2009–2017
2 sentences

2017App. 583 , 586, 529 S.E.2d 229 , 230-31 (2000) ("Furthermore, neither the statutory responsibilities of standby counsel nor the actual participation of standby counsel is a satisfactory substitute for the right to counsel in the absence of a knowing and voluntary waiver." (Citation, quotation marks, and ellipses omitted)).

2009App. 583, 586 , 529 S.E.2d 229, 230-31 (2000) (holding a new trial was warranted based on the trial court’s failure to comply with § 15A-1242 because “neither the statutory responsibilities of standby counsel . . . nor the actual participation of standby counsel... is a satisfactory substitute for the right to counsel in the absence of a knowing and voluntary waiver.”).

12
State v. Pruittgreen
nc · 1988 · cited in 2 North Carolina opinions naming this issue, 1994–2011
2 sentences

2011Furthermore, “[i]t is the trial court’s duty to conduct the inquiry of defendant to ensure that defendant understands the consequences of his decision.” Pruitt, 322 N.C. at 604 , 369 S.E.2d at 593 . *516 Moreover, “ ‘neither the statutory responsibilities of standby counsel, N.C.G.S. § 15A-1243, nor the actual participation of standby counsel... is a satisfactory substitute for the right to counsel in the absence of a knowing and voluntary waiver.’ ” Pruitt, 322 N.C. at 603 , 369 S.E.2d at 592 (quoting State v. Dunlap, 318 N.C. 384, 389 , 348 S.E.2d 801, 805 (1986)).

2011Furthermore, “[i]t is the trial court’s duty to conduct the inquiry of defendant to ensure that defendant understands the consequences of his decision.” Pruitt, 322 N.C. at 604 , 369 S.E.2d at 593 . *516 Moreover, “ ‘neither the statutory responsibilities of standby counsel, N.C.G.S. § 15A-1243, nor the actual participation of standby counsel... is a satisfactory substitute for the right to counsel in the absence of a knowing and voluntary waiver.’ ” Pruitt, 322 N.C. at 603 , 369 S.E.2d at 592 (quoting State v. Dunlap, 318 N.C. 384, 389 , 348 S.E.2d 801, 805 (1986)).

12
State v. McFaddengreen
nc · 1977 · cited in 1 North Carolina opinions naming this issue, 2024–2024
2 sentences

2024Our Supreme Court has long held “the right to be defended by chosen counsel is not absolute.” McFadden, 292 N.C. at 612 , 234 S.E.2d at 745 (citation omitted). “[A]n indigent defendant does not have the right to have counsel of his choice to -8- STATE V.

2024Our Supreme Court has long held “the right to be defended by chosen counsel is not absolute.” McFadden, 292 N.C. at 612 , 234 S.E.2d at 745 (citation omitted). “[A]n indigent defendant does not have the right to have counsel of his choice to -8- STATE V.

11
Lynch v. Hazelwoodgreen
nc · 1985 · cited in 1 North Carolina opinions naming this issue, 2021–2021
1 sentence

2021La Fave Co., 312 N.C. 224 , 229 n.3 (1984) (“A party may, of course, expressly waive contractual arbitration.”), and that a knowing and voluntary waiver of a contract right effects a release “from the terms of the original proposition[,]” Johnson v. Noles, 224 N.C. 542, 545 (1944).

11
Johnson v. . Nolesgreen
nc · 1944 · cited in 1 North Carolina opinions naming this issue, 2021–2021
1 sentence

2021La Fave Co., 312 N.C. 224 , 229 n.3 (1984) (“A party may, of course, expressly waive contractual arbitration.”), and that a knowing and voluntary waiver of a contract right effects a release “from the terms of the original proposition[,]” Johnson v. Noles, 224 N.C. 542, 545 (1944).

11
State v. Boydgreen
ncctapp · 2009 · cited in 1 North Carolina opinions naming this issue, 2014–2014
2 sentences

2014“Because forfeiture does not require a knowing and voluntary waiver of the right to counsel, the inquiry pursuant to section 15A-1242 is not required in such cases.” State v. Boyd, 200 N.C.

2014App. 97, 102 , 682 S.E.2d 463, 467 (2009) (citing Montgomery), disc. review denied,_N.C._, 691 S.E.2d 414 (2010).

11
State v. McLeodgreen
ncctapp · 2009 · cited in 1 North Carolina opinions naming this issue, 2011–2011
2 sentences

2011See State v. Carter, 338 N.C. 569, 581 , 451 S.E.2d 157, 163 (1994) (" Before a defendant is allowed to waive in-court representation by counsel, the trial court must insure that constitutional and statutory standards are satisfied." (emphasis added)), cert. denied, 515 U.S. 1107 , 115 S.Ct. 2256 , 132 L.Ed.2d 263 (1995); State v. McLeod, 197 N.C.App. 707, 715 , 682 S.E.2d 396, 400 (2009) ("N.C.

2011See State v. Carter, 338 N.C. 569, 581 , 451 S.E.2d 157, 163 (1994) (" Before a defendant is allowed to waive in-court representation by counsel, the trial court must insure that constitutional and statutory standards are satisfied." (emphasis added)), cert. denied, 515 U.S. 1107 , 115 S.Ct. 2256 , 132 L.Ed.2d 263 (1995); State v. McLeod, 197 N.C.App. 707, 715 , 682 S.E.2d 396, 400 (2009) ("N.C.

11
Carpino v. Demosthenesgreen
scotus · 1995 · cited in 1 North Carolina opinions naming this issue, 2011–2011
1 sentence

2011See State v. Carter, 338 N.C. 569, 581 , 451 S.E.2d 157, 163 (1994) (" Before a defendant is allowed to waive in-court representation by counsel, the trial court must insure that constitutional and statutory standards are satisfied." (emphasis added)), cert. denied, 515 U.S. 1107 , 115 S.Ct. 2256 , 132 L.Ed.2d 263 (1995); State v. McLeod, 197 N.C.App. 707, 715 , 682 S.E.2d 396, 400 (2009) ("N.C.

11
United States v. Andujar-Bascogreen
ca1 · 2007 · cited in 1 North Carolina opinions naming this issue, 2008–2008
1 sentence

2008See U.S. v. Andújar-Basco, 488 F.3d 549, 555 (1st Cir. P.R. 2007) ("As a general rule, any inculpatory or exculpatory statements made by a defendant (including silence with regard to particular questions) are admissible at trial insofar as they were the product of a knowing and voluntary waiver."); U.S. v. Burns, 276 F.3d 439, 442 (8th Cir. 2002) ("[W]here the accused initially waives his or her right to remain silent and agrees to questioning, but `subsequently refuses to answer further questions, the prosecution may note the refusal because it now constitutes part of an otherwise admissible

11
Tyreese Rowan v. Norman G. Owens, Superintendent, Indiana State Reformatory, Pendleton, Indianagreen
ca7 · 1984 · cited in 1 North Carolina opinions naming this issue, 2008–2008
1 sentence

2008See U.S. v. Andújar-Basco, 488 F.3d 549, 555 (1st Cir. P.R. 2007) ("As a general rule, any inculpatory or exculpatory statements made by a defendant (including silence with regard to particular questions) are admissible at trial insofar as they were the product of a knowing and voluntary waiver."); U.S. v. Burns, 276 F.3d 439, 442 (8th Cir. 2002) ("[W]here the accused initially waives his or her right to remain silent and agrees to questioning, but `subsequently refuses to answer further questions, the prosecution may note the refusal because it now constitutes part of an otherwise admissible

11
United States v. Arthur Lee Burns, Jr.green
ca8 · 2002 · cited in 1 North Carolina opinions naming this issue, 2008–2008
1 sentence

2008See U.S. v. Andújar-Basco, 488 F.3d 549, 555 (1st Cir. P.R. 2007) ("As a general rule, any inculpatory or exculpatory statements made by a defendant (including silence with regard to particular questions) are admissible at trial insofar as they were the product of a knowing and voluntary waiver."); U.S. v. Burns, 276 F.3d 439, 442 (8th Cir. 2002) ("[W]here the accused initially waives his or her right to remain silent and agrees to questioning, but `subsequently refuses to answer further questions, the prosecution may note the refusal because it now constitutes part of an otherwise admissible

11
Turner v. Safleygreen
scotus · 1986 · cited in 1 North Carolina opinions naming this issue, 2008–2008
1 sentence

2008See U.S. v. Andújar-Basco, 488 F.3d 549, 555 (1st Cir. P.R. 2007) ("As a general rule, any inculpatory or exculpatory statements made by a defendant (including silence with regard to particular questions) are admissible at trial insofar as they were the product of a knowing and voluntary waiver."); U.S. v. Burns, 276 F.3d 439, 442 (8th Cir. 2002) ("[W]here the accused initially waives his or her right to remain silent and agrees to questioning, but `subsequently refuses to answer further questions, the prosecution may note the refusal because it now constitutes part of an otherwise admissible

11
United States v. John Doe, Inc. Igreen
scotus · 1986 · cited in 1 North Carolina opinions naming this issue, 2008–2008
1 sentence

2008See U.S. v. Andújar-Basco, 488 F.3d 549, 555 (1st Cir. P.R. 2007) ("As a general rule, any inculpatory or exculpatory statements made by a defendant (including silence with regard to particular questions) are admissible at trial insofar as they were the product of a knowing and voluntary waiver."); U.S. v. Burns, 276 F.3d 439, 442 (8th Cir. 2002) ("[W]here the accused initially waives his or her right to remain silent and agrees to questioning, but `subsequently refuses to answer further questions, the prosecution may note the refusal because it now constitutes part of an otherwise admissible

11
State v. Allengreen
nc · 2005 · cited in 1 North Carolina opinions naming this issue, 2006–2006
2 sentences

2006See Allen, 359 N.C. at 440 , 615 S.E.2d at 266 .

2006See Allen, 359 N.C. at 440 , 615 S.E.2d at 266 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in North Carolina. Read the followed side critically anyway.

Also cited on this issue (17)

CaseCitedYears
State v. Swink green
ncctapp · 2017
2 sentences

2024RAGER Opinion of the Court determine whether defendant made a knowing and voluntary waiver of his right to a jury trial[,]” id. at 219 , 797 S.E.2d at 331 , this Court held that “the record reflect[ed] that [defendant’s] waiver was knowing and voluntary.” Id. at 225 , 797 S.E.2d at 335 .

2024RAGER Opinion of the Court determine whether defendant made a knowing and voluntary waiver of his right to a jury trial[,]” id. at 219 , 797 S.E.2d at 331 , this Court held that “the record reflect[ed] that [defendant’s] waiver was knowing and voluntary.” Id. at 225 , 797 S.E.2d at 335 .

32020–2024
Faretta v. California green
scotus · 1975
2 sentences

1994A defendant who chooses to represent himself "must be permitted to do so upon the sole condition that he make a knowing and voluntary waiver of the right to counsel." Id. at 835 , 95 S.Ct. at 2541 , 45 L.Ed.2d at 581-82 .

1994A defendant who chooses to represent himself "must be permitted to do so upon the sole condition that he make a knowing and voluntary waiver of the right to counsel." Id. at 835 , 95 S.Ct. at 2541 , 45 L.Ed.2d at 581-82 .

21993–1994
Berghuis v. Thompkins green
scotus · 2010
1 sentence

2017We do not need to reach the prejudice issue, though, because we hold that, as in Berghuis , defendant understood his Miranda rights and that, through a “course of conduct indicating waiver,” Berghuis, 560 U.S. at 386 (quoting Butler, 441 U.S. at 373 ), he effected a knowing and voluntary waiver of them.

12017–2017
North Carolina v. Butler red
scotus · 1979
2 sentences

2017We do not need to reach the prejudice issue, though, because we hold that, as in Berghuis , defendant understood his Miranda rights and that, through a “course of conduct indicating waiver,” Berghuis, 560 U.S. at 386 (quoting Butler, 441 U.S. at 373 ), he effected a knowing and voluntary waiver of them.

2017Here, as in Berghuis , defendant never said “during the interrogation ... that he wanted to remain silent, that he did not want to talk with the police, or that he wanted an attorney.” Id. at 375 .

12017–2017
State v. Boyd green
nc · 2010
1 sentence

2014App. 97, 102 , 682 S.E.2d 463, 467 (2009) (citing Montgomery), disc. review denied,_N.C._, 691 S.E.2d 414 (2010).

12014–2014
State v. Montgomery green
ncctapp · 2000
2 sentences

2009Id. at 525 , 530 S.E.2d at 69 .

2009Id. at 525 , 530 S.E.2d at 69 .

12009–2009
Carnley v. Cochran green
scotus · 1962
2 sentences

2006Specifically, defendant relies on Carnley v. Cochran, 369 U.S. 506 , 82 S.Ct. 884 , 8 L.Ed.2d 70 (1962) and State v. Williams, 65 N.C.App. 498 , 309 S.E.2d 721 (1983) in asserting that his motion to suppress the use of the prior convictions at issue under N.C.

2006Specifically, defendant relies on Carnley v. Cochran, 369 U.S. 506 , 82 S.Ct. 884 , 8 L.Ed.2d 70 (1962) and State v. Williams, 65 N.C.App. 498 , 309 S.E.2d 721 (1983) in asserting that his motion to suppress the use of the prior convictions at issue under N.C.

12006–2006
State v. Williams green
ncctapp · 1983
2 sentences

2006Specifically, defendant relies on Carnley v. Cochran, 369 U.S. 506 , 82 S.Ct. 884 , 8 L.Ed.2d 70 (1962) and State v. Williams, 65 N.C.App. 498 , 309 S.E.2d 721 (1983) in asserting that his motion to suppress the use of the prior convictions at issue under N.C.

2006Specifically, defendant relies on Carnley v. Cochran, 369 U.S. 506 , 82 S.Ct. 884 , 8 L.Ed.2d 70 (1962) and State v. Williams, 65 N.C.App. 498 , 309 S.E.2d 721 (1983) in asserting that his motion to suppress the use of the prior convictions at issue under N.C.

12006–2006
Tap Electrical Contracting Service, Inc. v. Sweeney green
scotus · 1995
1 sentence

1999Id.

11999–1999
Illinois v. Allen green
scotus · 1970
2 sentences

1993Id. at 835 , 45 L.

1993Id., 422 U.S. at 835 , 95 S.Ct. at 2541 , 45 L.Ed.2d at 581-82 .

11993–1993
Dunaway v. New York green
scotus · 1979
1 sentence

1984Defendant challenges the admission of his confession on two grounds: (1) the confession was obtained as a result of an illegal detention in violation of Dunaway v. New York, 442 U.S. 200 (1979); and (2) the confession was ob *502 tained by threats and promises and was without a knowing and voluntary waiver of defendant’s Miranda rights.

11984–1984
State v. McZorn green
nc · 1975
2 sentences

1982In State v. McZorn, 288 N.C. 417 , 219 S.E. 2d 201 (1975), death penalty vacated, 428 U.S. 904 , 49 L.Ed. 2d 1210 , 96 S.Ct. 3210 (1976), this Court speaking through Chief Justice Sharp set forth five factors to be considered among others as part of the totality of circumstances which determine whether initial warnings to a defendant have become so stale and remote as to raise a substantial possibility that the defendant was unaware of his constitutional rights at the time of the subsequent interrogation in question.

1982In State v. McZorn, 288 N.C. 417 , 219 S.E. 2d 201 (1975), death penalty vacated, 428 U.S. 904 , 49 L.Ed. 2d 1210 , 96 S.Ct. 3210 (1976), this Court speaking through Chief Justice Sharp set forth five factors to be considered among others as part of the totality of circumstances which determine whether initial warnings to a defendant have become so stale and remote as to raise a substantial possibility that the defendant was unaware of his constitutional rights at the time of the subsequent interrogation in question.

11982–1982
State v. Sanders green
ncctapp · 1977
11982–1982
McZorn v. North Carolina green
scotus · 1976
11982–1982
Griffin v. North Carolina green
scotus · 1976
11982–1982
Avery v. North Carolina green
scotus · 1976
11982–1982
Kirby v. Illinois green
scotus · 1972
11977–1977

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 15A-1242 (16) NC § N.C. Gen. Stat. § 15A-1443 (7) NC § N.C. Gen. Stat. § 15A-1243 (6) NC § N.C. Gen. Stat. § 14-17 (3) NC § N.C. Gen. Stat. § 15A-1201 (3) NC § N.C. Gen. Stat. § 15A-1340.16 (3)

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.

Where else courts name it

NY 139 (1974–2026) CA 118 (1980–2026) LA 110 (1981–2025) IL 85 (1975–2026) GA 77 (1979–2023) IN 65 (1972–2020) PA 55 (1969–2025) MD 54 (1965–2026) TX 54 (1979–2026) NJ 53 (1988–2026) FL 50 (1978–2025) SC 43 (1992–2025) MS 43 (1984–2025) OH 41 (1989–2026) WA 40 (1977–2025) OR 38 (1978–2026) TN 37 (1993–2026) CT 32 (1972–2025) MA 32 (1973–2024) NC 30 (1977–2024) KS 25 (1992–2026) WI 25 (1979–2026) HI 23 (1992–2025) MO 22 (1980–2023) OK 21 (1982–2023) UT 20 (1989–2024) VA 19 (1991–2024) ID 19 (2000–2022) IA 18 (2002–2024) MI 17 (1982–2025) NM 16 (1981–2020) AR 13 (2002–2015) SD 12 (1987–2019) DC 11 (1978–2024) AL 11 (1972–2013) AZ 11 (1973–2023) DE 10 (1978–2026) KY 9 (1995–2026) NE 9 (1999–2025) MT 8 (1995–2025) NV 7 (1987–2025) WY 7 (1986–2021) VT 7 (1994–2021) AK 6 (1987–2020) RI 6 (1974–2011) MN 6 (1988–2015) ME 5 (1979–2003) NH 5 (2001–2018) CO 4 (1995–2014) ND 4 (1997–2021) WV 3 (1982–1993)

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.

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