two aggravating factors (North Carolina) · Go Syfert
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two aggravating factors in North Carolina

9 North Carolina opinions name it 2 courts 1983–2021 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 (4)

CaseFollowedCited
State v. Ahearngreen
nc · 1983 · cited in 5 North Carolina opinions naming this issue, 1983–2021
2 sentences

2021Nonetheless, our Supreme Court has held that “in every case in which it is found that the judge erred in a finding or findings in aggravation and imposed a sentence beyond the presumptive term, the case must be remanded for a new sentencing hearing.” State v. Ahearn, 307 N.C. 584 , STATE V.

2021Nonetheless, our Supreme Court has held that “in every case in which it is found that the judge erred in a finding or findings in aggravation and imposed a sentence beyond the presumptive term, the case must be remanded for a new sentencing hearing.” State v. Ahearn, 307 N.C. 584 , STATE V.

15
State v. Barnesgreen
· 1993 · cited in 1 North Carolina opinions naming this issue, 1995–1995
2 sentences

1995In support of his argument defendant first cites State v. Barnes, 333 N.C. 666, 687 , 430 S.E.2d 223, 234 (1993) and State v. Westmoreland, 314 N.C. 442, 449 , 334 S.E.2d 223, 228 (1986) for the proposition that, “a conviction for which the defendant is being sentenced may not be aggravated by the defendant’s acts which form the gravamen of contemporaneous convictions of joined offenses.” However, unlike Barnes and Westmoreland , the court here arrested judgment in Counts II and III, and these convictions were not joined with Counts I and IV for sentencing purposes.

1995In support of his argument defendant first cites State v. Barnes, 333 N.C. 666, 687 , 430 S.E.2d 223, 234 (1993) and State v. Westmoreland, 314 N.C. 442, 449 , 334 S.E.2d 223, 228 (1986) for the proposition that, “a conviction for which the defendant is being sentenced may not be aggravated by the defendant’s acts which form the gravamen of contemporaneous convictions of joined offenses.” However, unlike Barnes and Westmoreland , the court here arrested judgment in Counts II and III, and these convictions were not joined with Counts I and IV for sentencing purposes.

11
State v. Westmorelandgreen
nc · 1985 · cited in 1 North Carolina opinions naming this issue, 1995–1995
2 sentences

1995In support of his argument defendant first cites State v. Barnes, 333 N.C. 666, 687 , 430 S.E.2d 223, 234 (1993) and State v. Westmoreland, 314 N.C. 442, 449 , 334 S.E.2d 223, 228 (1986) for the proposition that, “a conviction for which the defendant is being sentenced may not be aggravated by the defendant’s acts which form the gravamen of contemporaneous convictions of joined offenses.” However, unlike Barnes and Westmoreland , the court here arrested judgment in Counts II and III, and these convictions were not joined with Counts I and IV for sentencing purposes.

1995In support of his argument defendant first cites State v. Barnes, 333 N.C. 666, 687 , 430 S.E.2d 223, 234 (1993) and State v. Westmoreland, 314 N.C. 442, 449 , 334 S.E.2d 223, 228 (1986) for the proposition that, “a conviction for which the defendant is being sentenced may not be aggravated by the defendant’s acts which form the gravamen of contemporaneous convictions of joined offenses.” However, unlike Barnes and Westmoreland , the court here arrested judgment in Counts II and III, and these convictions were not joined with Counts I and IV for sentencing purposes.

11
State v. Penleygreen
nc · 1986 · cited in 1 North Carolina opinions naming this issue, 1987–1987
2 sentences

1987See State v. Penley, 318 N.C. 30 , 347 S.E. 2d 783 (1986); State v. Ahearn, 307 N.C. 584 , 300 S.E. 2d 689 (1983); and State v. Davis, 58 N.C.

1987See State v. Penley, 318 N.C. 30 , 347 S.E. 2d 783 (1986); State v. Ahearn, 307 N.C. 584 , 300 S.E. 2d 689 (1983); and State v. Davis, 58 N.C.

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 (5)

CaseCitedYears
State v. Green green
ncctapp · 2011
1 sentence

2014Id.

12014–2014
State v. Banks neutral
nc · 1984
1 sentence

1994App. 223 , 313 S.E.2d 183 , appeal dismissed and disc. review denied, 311 N.C. 764 , 321 S.E.2d 147 (1984).

11994–1994
State v. Brown green
ncctapp · 1984
2 sentences

1994However, this Court addressed the same argument as applied to the same two aggravating factors in State v. Brown, 67 N.C.

1994App. 223 , 313 S.E.2d 183 , appeal dismissed and disc. review denied, 311 N.C. 764 , 321 S.E.2d 147 (1984).

11994–1994
State v. Davis green
ncctapp · 1982
1 sentence

1987See State v. Penley, 318 N.C. 30 , 347 S.E. 2d 783 (1986); State v. Ahearn, 307 N.C. 584 , 300 S.E. 2d 689 (1983); and State v. Davis, 58 N.C.

11987–1987
State v. Thompson green
nc · 1983
2 sentences

1985The two aggravating factors are not elements of second degree murder, see State v. Thompson, 309 N.C. 421 , 422 n. 1, 307 S.E. 2d 156 , 158 n. *72 1 (1983), and they are based on separate evidence —evidence of the victim’s age and evidence of the caretaker position held by defendant.

1985The two aggravating factors are not elements of second degree murder, see State v. Thompson, 309 N.C. 421 , 422 n. 1, 307 S.E. 2d 156 , 158 n. *72 1 (1983), and they are based on separate evidence —evidence of the victim’s age and evidence of the caretaker position held by defendant.

11985–1985

Statutes the citing opinions construe

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

FL 23 (1982–2023) IN 9 (1997–2019) NC 9 (1983–2021) AZ 8 (2001–2013) NJ 7 (1991–2009) IL 7 (1987–2023) WA 6 (2006–2016) MS 5 (1996–2007) VA 5 (2000–2010) OR 3 (1993–2007) UT 3 (2012–2019) CA 2 (2015–2025) TX 2 (2000–2000) KS 2 (1998–2005)

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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