jury charge instruction (North Carolina) · Go Syfert
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jury charge instruction in North Carolina

7 North Carolina opinions name it 2 courts 1980–2025 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 (4)

CaseFollowedCited
State v. Reidgreen
nc · 1993 · cited in 3 North Carolina opinions naming this issue, 2023–2025
2 sentences

2025Reid, 334 N.C. at 556 .

2024“When the State directly comments on a defendant’s failure to testify, the improper comment is not cured by subsequent inclusion in the jury charge of an instruction on a defendant’s right not to testify.” Id. at 556 , 434 S.E.2d at 197 (citations omitted).

13
State v. Monkgreen
· 1975 · cited in 2 North Carolina opinions naming this issue, 1993–2002
2 sentences

2002Ed. 2d 315 (1998); State v. Monk, 286 N.C. 509, 516-17 , 212 S.E.2d 125, 131-32 (1975) (requiring instruction to be “prompt and explicit”).

2002Ed. 2d 315 (1998); State v. Monk, 286 N.C. 509, 516-17 , 212 S.E.2d 125, 131-32 (1975) (requiring instruction to be “prompt and explicit”).

12
State v. Billingsgreen
ncctapp · 1991 · cited in 1 North Carolina opinions naming this issue, 1993–1993
2 sentences

1993Monk, 286 N.C. at 516-17 , 212 S.E.2d at 131-32 ; State v. Billings, 104 N.C.App. 362, 374 , 409 S.E.2d 707, 714 (1991).

1993Monk, 286 N.C. at 516-17 , 212 S.E.2d at 131-32 ; State v. Billings, 104 N.C.App. 362, 374 , 409 S.E.2d 707, 714 (1991).

11
State v. Banksgreen
nc · 1988 · cited in 1 North Carolina opinions naming this issue, 1993–1993
2 sentences

1993Cf. State v. Banks, 322 N.C. 753 , 370 S.E.2d 398 (1988) ("The mere reading of [authoritative legal texts such as the Fifth Amendment], which, if they are material to the case, ought to be permitted, is not the same as `comment or explanation,' which, in the case of a defendant's election not to testify, is prohibited.") When the State directly comments on a defendant's failure to testify, the improper comment is not cured by subsequent inclusion in the jury charge of an instruction on a defendant's right not to testify.

1993Cf. State v. Banks, 322 N.C. 753 , 370 S.E.2d 398 (1988) ("The mere reading of [authoritative legal texts such as the Fifth Amendment], which, if they are material to the case, ought to be permitted, is not the same as `comment or explanation,' which, in the case of a defendant's election not to testify, is prohibited.") When the State directly comments on a defendant's failure to testify, the improper comment is not cured by subsequent inclusion in the jury charge of an instruction on a defendant's right not to testify.

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 (6)

CaseCitedYears
State v. McCall green
nc · 1975
1 sentence

2024“When the State directly comments on a defendant’s failure to testify, the improper comment is not cured by subsequent inclusion in the jury charge of an instruction on a defendant’s right not to testify.” Id. at 556 , 434 S.E.2d at 197 (citations omitted).

12024–2024
State v. Bennett green
· 1983
2 sentences

2019Consistent with the Court of Appeals’ emphasis in Hill regarding the importance of defense counsel’s opportunity at a trial’s sentencing phase to be heard following the trial court’s jury charge instruction on an aggravating factor in order to prevent a trial court’s failure to comply fully with the provisions of N.C.G.S. § 15A- 1231(b) from reaching a level of material prejudice to a defendant’s case, and our recognition of this essential common trait which Hill shares with the instant case, this Court has likewise determined the cases of State v. Bennett, 308 N.C. 530 , 302 S.E.2d 786 (1983)

2019Consistent with the Court of Appeals’ emphasis in Hill regarding the importance of defense counsel’s opportunity at a trial’s sentencing phase to be heard following the trial court’s jury charge instruction on an aggravating factor in order to prevent a trial court’s failure to comply fully with the provisions of N.C.G.S. § 15A- 1231(b) from reaching a level of material prejudice to a defendant’s case, and our recognition of this essential common trait which Hill shares with the instant case, this Court has likewise determined the cases of State v. Bennett, 308 N.C. 530 , 302 S.E.2d 786 (1983)

12019–2019
State v. Wiley green
nc · 2002
2 sentences

2019Consistent with the Court of Appeals’ emphasis in Hill regarding the importance of defense counsel’s opportunity at a trial’s sentencing phase to be heard following the trial court’s jury charge instruction on an aggravating factor in order to prevent a trial court’s failure to comply fully with the provisions of N.C.G.S. § 15A- 1231(b) from reaching a level of material prejudice to a defendant’s case, and our recognition of this essential common trait which Hill shares with the instant case, this Court has likewise determined the cases of State v. Bennett, 308 N.C. 530 , 302 S.E.2d 786 (1983)

2019Consistent with the Court of Appeals’ emphasis in Hill regarding the importance of defense counsel’s opportunity at a trial’s sentencing phase to be heard following the trial court’s jury charge instruction on an aggravating factor in order to prevent a trial court’s failure to comply fully with the provisions of N.C.G.S. § 15A- 1231(b) from reaching a level of material prejudice to a defendant’s case, and our recognition of this essential common trait which Hill shares with the instant case, this Court has likewise determined the cases of State v. Bennett, 308 N.C. 530 , 302 S.E.2d 786 (1983)

12019–2019
Granberry v. Baptist Memorial Hospital green
scotus · 1998
2 sentences

2002State v. Gregory, 348 N.C. 203, 210 , 499 S.E.2d 753, 758 , (holding that prosecutor’s direct comments on a defendant’s failure to testify were not cured by subsequent inclusion in the jury charge of an instruction regarding the defendant’s right not to testify), cert. denied, 525 U.S. 952 , 142 L.

2002State v. Gregory, 348 N.C. 203, 210 , 499 S.E.2d 753, 758 , (holding that prosecutor’s direct comments on a defendant’s failure to testify were not cured by subsequent inclusion in the jury charge of an instruction regarding the defendant’s right not to testify), cert. denied, 525 U.S. 952 , 142 L.

12002–2002
State v. Gregory green
nc · 1998
2 sentences

2002State v. Gregory, 348 N.C. 203, 210 , 499 S.E.2d 753, 758 , (holding that prosecutor’s direct comments on a defendant’s failure to testify were not cured by subsequent inclusion in the jury charge of an instruction regarding the defendant’s right not to testify), cert. denied, 525 U.S. 952 , 142 L.

2002State v. Gregory, 348 N.C. 203, 210 , 499 S.E.2d 753, 758 , (holding that prosecutor’s direct comments on a defendant’s failure to testify were not cured by subsequent inclusion in the jury charge of an instruction regarding the defendant’s right not to testify), cert. denied, 525 U.S. 952 , 142 L.

12002–2002
Board of Transportation v. Jones green
· 1979
2 sentences

1980While it is true that in the absence of a special request on benefits, the judge is not required to fully *484 define the meaning of general or special benefits or to distinguish between them, Board of Transportation v. Jones, 297 N.C. 436 , 255 S.E. 2d 185 (1979), it is equally true that the case does not involve, as the situation sub judice does, a total omission in the jury charge of an instruction on the law of benefits.

1980While it is true that in the absence of a special request on benefits, the judge is not required to fully *484 define the meaning of general or special benefits or to distinguish between them, Board of Transportation v. Jones, 297 N.C. 436 , 255 S.E. 2d 185 (1979), it is equally true that the case does not involve, as the situation sub judice does, a total omission in the jury charge of an instruction on the law of benefits.

11980–1980

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 8-54 (5) NC § N.C. Gen. Stat. § 15A-1443 (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 927 (1976–2026) GA 51 (1984–2025) NY 27 (1987–2025) SC 21 (1981–2026) PA 16 (1988–2024) LA 13 (1980–2025) NJ 10 (1985–2026) NC 7 (1980–2025) AL 5 (1995–2018) TN 4 (1994–2007) CT 3 (1990–2020) WV 2 (2019–2019) ME 2 (1985–2002)

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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