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22 North Carolina opinions name it 3 courts 1981–2025 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.
| Case | Followed | Cited |
|---|---|---|
Willis v. Duke Power Co.green2 sentences2018See State v. Buckner, 351 N.C. 401 , 411–12, 527 S.E.2d 307, 314 (2000) (trial court must conduct in camera review when there is a dispute as to the scope of a defendant’s waiver of the attorney-client privilege, such as would be the case when a defendant has asserted an ineffective assistance of counsel claim); . . . see also Willis v. Duke Power Co., 291 N.C. 19, 36 , 229 S.E.2d 191, 201 (1976) (trial court may require in camera inspection of documents to determine if they are work-product). 2018See State v. Buckner, 351 N.C. 401 , 411–12, 527 S.E.2d 307, 314 (2000) (trial court must conduct in camera review when there is a dispute as to the scope of a defendant’s waiver of the attorney-client privilege, such as would be the case when a defendant has asserted an ineffective assistance of counsel claim); . . . see also Willis v. Duke Power Co., 291 N.C. 19, 36 , 229 S.E.2d 191, 201 (1976) (trial court may require in camera inspection of documents to determine if they are work-product). | 3 | 3 |
State v. Bucknergreen2 sentences2018See State v. Buckner, 351 N.C. 401 , 411–12, 527 S.E.2d 307, 314 (2000) (trial court must conduct in camera review when there is a dispute as to the scope of a defendant’s waiver of the attorney-client privilege, such as would be the case when a defendant has asserted an ineffective assistance of counsel claim); . . . see also Willis v. Duke Power Co., 291 N.C. 19, 36 , 229 S.E.2d 191, 201 (1976) (trial court may require in camera inspection of documents to determine if they are work-product). 2018See State v. Buckner, 351 N.C. 401 , 411–12, 527 S.E.2d 307, 314 (2000) (trial court must conduct in camera review when there is a dispute as to the scope of a defendant’s waiver of the attorney-client privilege, such as would be the case when a defendant has asserted an ineffective assistance of counsel claim); . . . see also Willis v. Duke Power Co., 291 N.C. 19, 36 , 229 S.E.2d 191, 201 (1976) (trial court may require in camera inspection of documents to determine if they are work-product). | 3 | 3 |
State v. Blackgreen2 sentences2009“The trial court is then required to conduct an in camera hearing ... to consider the proponent’s offer of proof and the argument of counsel....’” State v. Black, 111 N.C. 1995The trial court is then required to “conduct an in camera hearing ... to consider the proponent’s offer of proof and the argument of counsel. . . .” Id. at 289 , 432 S.E.2d at 714 (citations omitted). | 2 | 4 |
In Re Albemarle Mental Health Centergreen2 sentences2020Stat. § 8-53.3 , requesting an in camera hearing “to determine: (1) whether [the requested] information . . . constituted privileged information; (2) whether such information was relevant to an alleged homicide . . . , and; (3) whether disclosure of such information to law enforcement officers was necessary to a proper administration of justice.” Id. at 293 , 256 S.E.2d at 819 . 2020Stat. § 8-53.3 , requesting an in camera hearing “to determine: (1) whether [the requested] information . . . constituted privileged information; (2) whether such information was relevant to an alleged homicide . . . , and; (3) whether disclosure of such information to law enforcement officers was necessary to a proper administration of justice.” Id. at 293, 256 S.E.2d at 819 . | 2 | 2 |
State v. Cookgreen2 sentences2015Cook, 195 N.C.App. at 238 , 672 S.E.2d at 31 (the in camera hearing "occurred during [the *608 complainant's] cross-examination and related to whether defense counsel would be allowed to ask [the complainant] certain questions"). 2015Cook, 195 N.C.App. at 238 , 672 S.E.2d at 31 (the in camera hearing "occurred during [the *608 complainant's] cross-examination and related to whether defense counsel would be allowed to ask [the complainant] certain questions"). | 1 | 2 |
State v. Ginyardgreen1 sentence2025See Ginyard, 122 N.C. App. at 34 . | 1 | 1 |
In Re the Investigation of the Death of Millergreen2 sentences2012In re Investigation of the Death of Miller, 357 N.C. 316, 336 , 584 S.E.2d 772, 787 (2003) (italics of Latin phrase removed). {47} In conducting such an inquiry, a court must apply a five-part test to determine whether a particular communication is privileged: (1) the relation of attorney and client existed at the time the communication was made, (2) the communication was made in confidence, (3) the communication relates to a matter about which the attorney is being professionally consulted, (4) the communication was made in the course of giving or seeking legal advice for a proper purpose alt 2012In re Investigation of the Death of Miller, 357 N.C. 316, 336 , 584 S.E.2d 772, 787 (2003) (italics of Latin phrase removed). {47} In conducting such an inquiry, a court must apply a five-part test to determine whether a particular communication is privileged: (1) the relation of attorney and client existed at the time the communication was made, (2) the communication was made in confidence, (3) the communication relates to a matter about which the attorney is being professionally consulted, (4) the communication was made in the course of giving or seeking legal advice for a proper purpose alt | 1 | 1 |
State v. Harrisgreen2 sentences2009See State v. Harris, 360 N.C. 145, 153 , 622 S.E.2d 615, 620 (2005) (“No evidence proffered at the in camera hearing supports an inference that the victim’s prior sexual activity was forced or caused any injuries.”). 2009See State v. Harris, 360 N.C. 145, 153 , 622 S.E.2d 615, 620 (2005) (“No evidence proffered at the in camera hearing supports an inference that the victim’s prior sexual activity was forced or caused any injuries.”). | 1 | 1 |
State v. Taylorgreen2 sentences2003See State v. Buckner, 351 N.C. 401, 411-12 , 527 S.E.2d 307, 314 (2000) (trial court must conduct in camera review when there is a dispute as to the scope of a defendant’s waiver of the attorney-client privilege, such as would be the case when a defendant has asserted an ineffective assistance of counsel claim); State v. Taylor, 327 N.C. at 155, 393 S.E.2d at 807 (same); see also Willis v. Duke Power Co., 291 N.C. 19, 36 , 229 S.E.2d 191, 201 (1976) (trial court may require in camera inspection of documents to determine if they are work-product). *337 We note that the United States Supreme Cou 2003See State v. Buckner, 351 N.C. 401, 411-12 , 527 S.E.2d 307, 314 (2000) (trial court must conduct in camera review when there is a dispute as to the scope of a defendant’s waiver of the attorney-client privilege, such as would be the case when a defendant has asserted an ineffective assistance of counsel claim); State v. Taylor, 327 N.C. at 155, 393 S.E.2d at 807 (same); see also Willis v. Duke Power Co., 291 N.C. 19, 36 , 229 S.E.2d 191, 201 (1976) (trial court may require in camera inspection of documents to determine if they are work-product). *337 We note that the United States Supreme Cou | 1 | 1 |
State v. Clontzgreen2 sentences1993See State v. Clontz, 305 N.C. 116, 122-23 , 286 S.E.2d 793, 796-97 (1982) (construing former N.C.G.S. § 58.6). 1993See State v. Clontz, 305 N.C. 116, 122-23 , 286 S.E.2d 793, 796-97 (1982) (construing former N.C.G.S. § 58.6). | 1 | 1 |
State v. . Geegreen2 sentences1987State v. Gee, 92 N.C. 756, 763 (1885). 1987State v. Gee, 92 N.C. 756, 763 (1885). | 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. Hardy
green
2 sentences1984He cites to State v. Hardy, 293 N.C. 105 , 235 S.E. 2d 828 (1977), which held that G.S. § 15A-904(a) does not bar discovery of prosecution witnesses’ statements at trial and that the appropriate procedure for disclosure once a request has been made is for the trial judge to order an in camera inspection of the statement to determine its relevance for, as an example, impeachment purposes. 1984He cites to State v. Hardy, 293 N.C. 105 , 235 S.E. 2d 828 (1977), which held that G.S. § 15A-904(a) does not bar discovery of prosecution witnesses’ statements at trial and that the appropriate procedure for disclosure once a request has been made is for the trial judge to order an in camera inspection of the statement to determine its relevance for, as an example, impeachment purposes. | 2 | 1981–1984 |
State v. Fowler
neutral
1 sentence2025On 18 September 2018, this Court filed an unpublished opinion reversing the trial court’s order denying Defendant’s motion for post-conviction discovery and remanding the case to the trial court to conduct an in camera hearing “to determine whether the evidence was material, and whether its exclusion prejudiced [D]efendant’s case.” State v. Cataldo, 261 N.C. App. 538 (2018) (unpublished) (Cataldo II). | 1 | 2025–2025 |
State v. Younger
green
2 sentences2017A proper determination of the probative and prejudicial effect of certain evidence entails "an in-camera hearing in which the court can hear and evaluate the arguments of counsel before making a ruling." Younger , 306 N.C. at 697 , 295 S.E.2d at 456 . *167 Here, when considering whether to admit the evidence of D.S.'s prior sexual conduct, the trial court properly held an in camera hearing. 2017A proper determination of the probative and prejudicial effect of certain evidence entails "an in-camera hearing in which the court can hear and evaluate the arguments of counsel before making a ruling." Younger , 306 N.C. at 697 , 295 S.E.2d at 456 . *167 Here, when considering whether to admit the evidence of D.S.'s prior sexual conduct, the trial court properly held an in camera hearing. | 1 | 2017–2017 |
State v. Seaberry
green
1 sentence1995Article I, Section 23 of the North Carolina Constitution provides that “[i]n all criminal prosecutions, every person charged with crime has the right ... to confront the accusers and witnesses with other testimony . . . .” Under the section, “ ‘[t]he appropriate question is whether there has been any interference with defendant’s opportunity for effective cross-examination.’ ” State v. Seaberry, 97 N.C. | 1 | 1995–1995 |
State v. Williams
green
2 sentences1993In State v. Williams, 322 N.C. 452 , 368 S.E.2d 624 (1988), our Supreme Court set out the basic principles of this rather complex area of evidence: A witness may be cross-examined by confronting him with prior statements inconsistent with any part of his testimony, but where such questions concern matters collateral to the issues, the witness’s answers on cross-examination are conclusive, and the party who draws out such answers will not be permitted to contradict them by other testimony. 1993In State v. Williams, 322 N.C. 452 , 368 S.E.2d 624 (1988), our Supreme Court set out the basic principles of this rather complex area of evidence: A witness may be cross-examined by confronting him with prior statements inconsistent with any part of his testimony, but where such questions concern matters collateral to the issues, the witness’s answers on cross-examination are conclusive, and the party who draws out such answers will not be permitted to contradict them by other testimony. | 1 | 1993–1993 |
State v. Payne
green
2 sentences1989There being “no indication of record to the contrary, we must assume that the trial court caused the record to speak the complete truth in this regard.” Payne, 320 N.C. at 139 , 357 S.E.2d at 612 . 1989There being “no indication of record to the contrary, we must assume that the trial court caused the record to speak the complete truth in this regard.” Payne, 320 N.C. at 139 , 357 S.E.2d at 612 . | 1 | 1989–1989 |
United States v. Alicia Davis (85-1153), Duane Davis (85-1178), Kenneth Davis (85-1288), Howard Ransom (85-1366)
green
2 sentences1988United States v. Tucker, 836 F.2d 334 (7th Cir.1988); and United States v. Davis, 809 F.2d 1194 (6th Cir.), cert. denied, ___ U.S. ___, 107 S.Ct. 3234 , 97 L.Ed.2d 740 (1987). 1988United States v. Tucker, 836 F. 2d 334 (7th Cir. 1988); and United States v. Davis, 809 F. 2d 1194 (6th Cir.), cert. denied, — U.S. —, 97 L.Ed. 2d 740 (1987). | 1 | 1988–1988 |
United States v. Robert L. Tucker and Deborah Bell
green
2 sentences1988United States v. Tucker, 836 F.2d 334 (7th Cir.1988); and United States v. Davis, 809 F.2d 1194 (6th Cir.), cert. denied, ___ U.S. ___, 107 S.Ct. 3234 , 97 L.Ed.2d 740 (1987). 1988United States v. Tucker, 836 F. 2d 334 (7th Cir. 1988); and United States v. Davis, 809 F. 2d 1194 (6th Cir.), cert. denied, — U.S. —, 97 L.Ed. 2d 740 (1987). | 1 | 1988–1988 |
State v. Davis
green
2 sentences1987State v. Davis, 290 N.C. 511 , 227 S.E. 2d 97 (1976). 1987State v. Davis, 290 N.C. 511 , 227 S.E. 2d 97 (1976). | 1 | 1987–1987 |
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.