burden of proving defense (North Carolina) · Go Syfert
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burden of proving defense in North Carolina

29 North Carolina opinions name it 3 courts 1970–2026 2 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 (6)

CaseFollowedCited
State v. Grahamgreen
ncctapp · 2009 · cited in 6 North Carolina opinions naming this issue, 2014–2025
2 sentences

2025Once error is shown, the State bears the burden of proving the error was harmless beyond a reasonable doubt.” State v. Graham, 200 N.C.

2018Once error is shown, the State bears the burden of proving the error was harmless beyond a reasonable doubt." State v. Graham , 200 N.C.

36
State v. Wallacegreen
nc · 1957 · cited in 2 North Carolina opinions naming this issue, 2020–2020
2 sentences

2020See State v. Wallace, 246 N.C. 445, 447 , 98 S.E.2d 473, 474 (1957) (“The law of entrapment is that it not only may, but it does constitute a defense.”) Defendants have the burden of proving the defense of entrapment “to the satisfaction of the jury” and the burden does not shift to the prosecution to prove predisposition beyond a reasonable doubt.

2020See State v. Wallace, 246 N.C. 445, 447 , 98 S.E.2d 473, 474 (1957) (“The law of entrapment is that it not only may, but it does constitute a defense.”) Defendants have the burden of proving the defense of entrapment “to the satisfaction of the jury” and the burden does not shift to the prosecution to prove predisposition beyond a reasonable doubt.

22
In Re the Appeal From the Denial of the Application to Dredgegreen
nc · 1980 · cited in 2 North Carolina opinions naming this issue, 2011–2011
2 sentences

2011As the Department correctly noted, in light of the fact that ECIM bore the burden of proving error in the CON Section’s decision, there is a presumption that “an administrative agency has properly performed its official duties.” In re Community Association, 300 N.C. 267, 280 , 266 S.E.2d 645, 654 (1980).

2011As the Department correctly noted, in light of the fact that ECIM bore the burden of proving error in the CON Section’s decision, there is a presumption that “an administrative agency has properly performed its official duties.” In re Community Association, 300 N.C. 267, 280 , 266 S.E.2d 645, 654 (1980).

22
State v. Autrygreen
nc · 1988 · cited in 2 North Carolina opinions naming this issue, 2004–2004
2 sentences

2004Id. “[T]he presence of overwhelming evidence of guilt may render error of constitutional dimension harmless beyond a reasonable doubt.” State v. Autry, 321 N.C. 392, 400 , 364 S.E.2d 341, 346 (1988).

2004Id. “[T]he presence of overwhelming evidence of guilt may render error of constitutional dimension harmless beyond a reasonable doubt.” State v. Autry, 321 N.C. 392, 400 , 364 S.E.2d 341, 346 (1988).

12
Roach v. Estate of Ravensteingreen
iasd · 1971 · cited in 1 North Carolina opinions naming this issue, 1994–1994
1 sentence

1994Roach v. Estate of Ravenstein, 326 F. Supp. 830, 834 (S.D.

11
State v. McGuiregreen
ncctapp · 1985 · cited in 1 North Carolina opinions naming this issue, 1988–1988
2 sentences

1988A defendant has the burden of proving factors in mitigation “by a preponderance of the evidence, and the trial court has the discretion to assess the credibility of defendant’s evidence and either accept or reject it.” State v. McGuire, 78 N.C.

1988App. 285, 294 , 337 S.E. 2d 620, 626 (1985). *607 The only evidence below of defendant’s good character was statements by his employment supervisor of three months and his employer of two years.

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 (21)

CaseCitedYears
State v. Hageman green
· 1982
2 sentences

2020Hageman, 307 N.C. at 28 ; 296 S.E.2d at 448 .

2020Hageman, 307 N.C. at 28 ; 296 S.E.2d at 448 .

22020–2020
Price v. Conley green
ncctapp · 1974
1 sentence

2026AMV HOLDINGS, LLC Opinion of the Court It is well established that with regard to “an affirmative defense, the burden of proof lies with the defendant.” Price v. Conley, 21 N.C.

12026–2026
State v. Knight green
ncctapp · 1981
1 sentence

2017"In determining whether error is harmless beyond a reasonable doubt, ... the rule is that if there is a reasonable possibility that the evidence complained of might have contributed to the conviction, it is not harmless beyond a reasonable doubt." State v. Knight , 53 N.C.

12017–2017
Evans v. United Services Automobile Ass'n green
ncctapp · 2001
1 sentence

2014Evans, 142 N.C.

12014–2014
State v. Tate green
ncctapp · 2007
1 sentence

2014App. 204, 214 , 683 S.E.2d 437, 444 (2009) (citing State v. Tate, 187 N.C.

12014–2014
Ehrenhaus v. Baker green
ncctapp · 2011
1 sentence

2014Id.

12014–2014
State v. Clark green
ncctapp · 2004
2 sentences

2005As defendant’s constitutional right was violated through the admission of Dr. Lidonicci’s deposition, “the State has the burden of proving the error was harmless beyond a reasonable doubt to sustain defendant’s conviction.” Clark, 165 N.C.

2005App. at 289 , 598 S.E.2d at 220 .

12005–2005
Phillips v. U.S. Air, Inc. green
ncctapp · 1995
2 sentences

2004Plaintiff has the burden of proving his claim by the "greater weight of the evidence" or by a "preponderance of the evidence." Phillips v. U.S. Air, 120 N.C.App. 538 , 541, 463 S.E.2d 259 , 261 (1995).

2004Plaintiff has the burden of proving his claim by the "greater weight of the evidence" or by a "preponderance of the evidence." Phillips v. U.S. Air, 120 N.C.App. 538 , 541, 463 S.E.2d 259 , 261 (1995).

12004–2004
State v. Williams green
ncctapp · 1983
1 sentence

2004State v. Williams, 65 N.C.

12004–2004
State v. Taylor green
nc · 1983
2 sentences

1985State v. Taylor, 309 N.C. 570 , 308 S.E. 2d 302 (1983).

1985State v. Taylor, 309 N.C. 570 , 308 S.E. 2d 302 (1983).

11985–1985
State v. Braun green
ncctapp · 1976
1 sentence

1980State v. Braun, 31 N.C.

11980–1980
Henry v. A. C. Lawrence Leather Co. green
nc · 1950
2 sentences

1980Henry v. Leather Co., 231 N.C. 477 , 57 S.E. 2d 760 (1950).

1980Henry v. Leather Co., 231 N.C. 477 , 57 S.E. 2d 760 (1950).

11980–1980
State v. Leonard green
nc · 1980
2 sentences

1980Defendant recognizes that this assignment runs counter to a long line of decisions by this Court including the recent case of State v. Leonard, 300 N.C. 223 , 266 S.E. 2d 631 (1980).

1980Defendant recognizes that this assignment runs counter to a long line of decisions by this Court including the recent case of State v. Leonard, 300 N.C. 223 , 266 S.E. 2d 631 (1980).

11980–1980
State v. Cook green
nc · 1965
2 sentences

1976State v. Cook, 263 N.C. 730 , 140 S.E. 2d 305 (1965) ; 2 Stansbury, N. C.

1976State v. Cook, 263 N.C. 730 , 140 S.E. 2d 305 (1965) ; 2 Stansbury, N. C.

11976–1976
State v. Mercer green
nc · 1969
2 sentences

1975State v. Caddell, 287 N.C. 266 , 215 S.E.2d 348 (1975), which overruled, on this point, State v. Mercer, 275 N.C. 108 , 165 S.E.2d 328 , cited in the majority opinion upon a different point.

1975State v. Caddell, 287 N.C. 266 , 215 S.E.2d 348 (1975), which overruled, on this point, State v. Mercer, 275 N.C. 108 , 165 S.E.2d 328 , cited in the majority opinion upon a different point.

11975–1975
State v. Caddell green
nc · 1975
2 sentences

1975State v. Caddell, 287 N.C. 266 , 215 S.E.2d 348 (1975), which overruled, on this point, State v. Mercer, 275 N.C. 108 , 165 S.E.2d 328 , cited in the majority opinion upon a different point.

1975State v. Caddell, 287 N.C. 266 , 215 S.E.2d 348 (1975), which overruled, on this point, State v. Mercer, 275 N.C. 108 , 165 S.E.2d 328 , cited in the majority opinion upon a different point.

11975–1975
State v. Freeman green
nc · 1969
1 sentence

1974In Freeman the court held that “ ‘ [T] he accepted formula and the one that should be used if risk of error is to be avoided, is that the defendant has the burden of proving his defense (or mitigation) “to the satisfaction of the jury — not by the greater weight of the evidence nor beyond a reasonable doubt — but simply to the satisfaction of the jury.” ’ ” 275 N.C. at 666 .

11974–1974
Gibson v. Central Manufacturers' Mutual Insurance green
nc · 1950
2 sentences

1970In Gibson v. Insurance Co., 232 N.C. 712 , 62 S.E. 2d 320 , the court stated the general principle which governs us: “* * * [JJudgment of nonsuit will not be granted in favor of one on whom rests the burden of proof.” Nonsuit is proper, nevertheless, where plaintiffs’ own evidence establishes an affirmative defense as a matter of law.

1970In Gibson v. Insurance Co., 232 N.C. 712 , 62 S.E. 2d 320 , the court stated the general principle which governs us: “* * * [JJudgment of nonsuit will not be granted in favor of one on whom rests the burden of proof.” Nonsuit is proper, nevertheless, where plaintiffs’ own evidence establishes an affirmative defense as a matter of law.

11970–1970
State v. . Sheffield green
nc · 1934
2 sentences

1970The doctrine of contextual interpretation of a charge has been applied in proving inexact charges on alibi (State v. Sheffield, 206 N.C. 374 , 174 S.E. 105 , State v. Bridgers, 233 N.C. 577 , 64 S.E. 2d 867 ), but only in cases where the court “expressly or substantially states that the burden of proving an alibi does not rest on the defendant.” State v. Allison, 256 N.C. 240 , 123 S.E. 2d 465 .

1970The doctrine of contextual interpretation of a charge has been applied in proving inexact charges on alibi (State v. Sheffield, 206 N.C. 374 , 174 S.E. 105 , State v. Bridgers, 233 N.C. 577 , 64 S.E. 2d 867 ), but only in cases where the court “expressly or substantially states that the burden of proving an alibi does not rest on the defendant.” State v. Allison, 256 N.C. 240 , 123 S.E. 2d 465 .

11970–1970
State v. Allison green
nc · 1962
2 sentences

1970The doctrine of contextual interpretation of a charge has been applied in proving inexact charges on alibi (State v. Sheffield, 206 N.C. 374 , 174 S.E. 105 , State v. Bridgers, 233 N.C. 577 , 64 S.E. 2d 867 ), but only in cases where the court “expressly or substantially states that the burden of proving an alibi does not rest on the defendant.” State v. Allison, 256 N.C. 240 , 123 S.E. 2d 465 .

1970The doctrine of contextual interpretation of a charge has been applied in proving inexact charges on alibi (State v. Sheffield, 206 N.C. 374 , 174 S.E. 105 , State v. Bridgers, 233 N.C. 577 , 64 S.E. 2d 867 ), but only in cases where the court “expressly or substantially states that the burden of proving an alibi does not rest on the defendant.” State v. Allison, 256 N.C. 240 , 123 S.E. 2d 465 .

11970–1970
State v. Bridgers green
nc · 1951
2 sentences

1970The doctrine of contextual interpretation of a charge has been applied in proving inexact charges on alibi (State v. Sheffield, 206 N.C. 374 , 174 S.E. 105 , State v. Bridgers, 233 N.C. 577 , 64 S.E. 2d 867 ), but only in cases where the court “expressly or substantially states that the burden of proving an alibi does not rest on the defendant.” State v. Allison, 256 N.C. 240 , 123 S.E. 2d 465 .

1970The doctrine of contextual interpretation of a charge has been applied in proving inexact charges on alibi (State v. Sheffield, 206 N.C. 374 , 174 S.E. 105 , State v. Bridgers, 233 N.C. 577 , 64 S.E. 2d 867 ), but only in cases where the court “expressly or substantially states that the burden of proving an alibi does not rest on the defendant.” State v. Allison, 256 N.C. 240 , 123 S.E. 2d 465 .

11970–1970

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 15A-1443 (8) NC § N.C. Gen. Stat. § 8C-1 (4)

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

TX 223 (1908–2026) CA 185 (1920–2026) LA 167 (1939–2025) PA 140 (1919–2026) IN 101 (1922–2024) IL 94 (1907–2026) WA 86 (1942–2025) GA 81 (1940–2026) OH 79 (1957–2025) MO 66 (1929–2025) TN 61 (1985–2025) MI 57 (1948–2025) VA 54 (1918–2024) CT 53 (1982–2026) NY 46 (1882–2025) CO 46 (1938–2026) FL 37 (1944–2025) WV 37 (1919–2026) IA 34 (1902–2025) AZ 31 (1957–2023) NC 29 (1970–2026) AR 29 (1966–2023) WI 28 (1959–2025) MD 27 (2005–2024) AL 25 (1902–2016) MS 24 (1922–2023) NJ 23 (1951–2025) MA 22 (1908–2026) MN 21 (1979–2018) OR 21 (1896–2024) ID 18 (1944–2026) KS 17 (1918–2026) NM 17 (1971–2025) ND 17 (1915–2023) ME 14 (1969–2025) SC 12 (1917–2019) MT 12 (1969–2022) NE 11 (1876–2013) RI 11 (1978–2022) SD 10 (1929–2017) DE 10 (1977–2026) UT 10 (1896–2025) KY 9 (1951–2024) VT 8 (1960–2020) OK 7 (1912–1971) NH 6 (1967–2009) WY 6 (2004–2024) DC 5 (1990–2020) HI 5 (1981–2020) AK 4 (1983–1996) NV 3 (1982–2020) VI 2 (1977–2014)

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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