continuous transaction doctrine in North Carolina

6 North Carolina opinions name it 2 courts 1991–2022 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 (8)

Case	Followed	Cited
State v. Thomasgreen nc · 1991 · cited in 4 North Carolina opinions naming this issue, 1992–2022 2 sentences 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002). 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002).	3	4
State v. Olsongreen · 1992 · cited in 4 North Carolina opinions naming this issue, 1992–2022 2 sentences 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002). 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002).	3	4
State v. Trullgreen nc · 1998 · cited in 3 North Carolina opinions naming this issue, 2001–2022 2 sentences 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002). 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002).	3	3
State v. Campbellgreen nc · 1992 · cited in 3 North Carolina opinions naming this issue, 2001–2022 2 sentences 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002). 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002).	3	3
State v. Wootengreen nc · 1978 · cited in 2 North Carolina opinions naming this issue, 2022–2022 2 sentences 2022See Wooten, 295 N.C. at 385–86. 2022See Wooten, 295 N.C. at 385–86.	2	2
State v. Manngreen nc · 2002 · cited in 2 North Carolina opinions naming this issue, 2022–2022 2 sentences 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002). 2022We have applied the continuous transaction doctrine in cases in which the defendant has committed murder and, within the same time frame, also committed another crime such as arson, see State v. Campbell, 332 N.C. 116, 120 (1992); armed robbery, see State v. Olson, 330 N.C. 557, 566 (1992); sexual offense, see State v. Thomas, 329 N.C. 423, 434 (1991); rape, see State v. Trull, 349 N.C. 428, 449 (1998); and kidnapping, see State v. Mann, 355 N.C. 294, 305 (2002).	2	2
Trull v. North Carolinagreen scotus · 1999 · cited in 1 North Carolina opinions naming this issue, 2001–2001 2 sentences 2001See State v. Campbell, 332 N.C. 116, 120 , 418 S.E.2d 476, 478 (1992) (holding the doctrine of continuous transaction applies to murder/arson cases); State v. Olson, 330 N.C. 557, 566 , 411 S.E.2d 592, 597 (1992) (armed robbery and murder); State v. Thomas, 329 N.C. 423, 434 , 407 S.E.2d 141, 149 (1991) (applying continuous doctrine to felony murder and sexual offense where court held whether victim was alive or dead when sexual offense occurred is immaterial because “the sexual act was committed during a continuous transaction that began when the victim was alive.”); State v. Trull, 349 N.C. 2001See State v. Campbell, 332 N.C. 116, 120 , 418 S.E.2d 476, 478 (1992) (holding the doctrine of continuous transaction applies to murder/arson cases); State v. Olson, 330 N.C. 557, 566 , 411 S.E.2d 592, 597 (1992) (armed robbery and murder); State v. Thomas, 329 N.C. 423, 434 , 407 S.E.2d 141, 149 (1991) (applying continuous doctrine to felony murder and sexual offense where court held whether victim was alive or dead when sexual offense occurred is immaterial because "the sexual act was committed during a continuous transaction that began when the victim was alive."); State v. Trull, 349 N.C.	1	1
Zigmund v. Norkogreen scotus · 1999 · cited in 1 North Carolina opinions naming this issue, 2001–2001 1 sentence 2001See State v. Campbell, 332 N.C. 116, 120 , 418 S.E.2d 476, 478 (1992) (holding the doctrine of continuous transaction applies to murder/arson cases); State v. Olson, 330 N.C. 557, 566 , 411 S.E.2d 592, 597 (1992) (armed robbery and murder); State v. Thomas, 329 N.C. 423, 434 , 407 S.E.2d 141, 149 (1991) (applying continuous doctrine to felony murder and sexual offense where court held whether victim was alive or dead when sexual offense occurred is immaterial because "the sexual act was committed during a continuous transaction that began when the victim was alive."); State v. Trull, 349 N.C.	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

Case	Cited	Years
State v. Morris green ncctapp · 2001 2 sentences 2022In addition, the majority at the Court of Appeals rejected the State’s invocation of the continuous transaction doctrine on the grounds that “our Courts have not applied the continuous transaction doctrine to instances involving rape and kidnapping like the situation we have before us” and that, “[w]hile these two acts occurred close in time, they were not inseparable or concurrent actions,” with “[a]ll of the elements of the rape [having been] completed before defendant removed the victim to the storage closet.” Id. at 252 . ¶ 29 Finally, the Court of Appeals disagreed with the State’s argume 2022In addition, the majority at the Court of Appeals rejected the State’s invocation of the continuous transaction doctrine on the grounds that “our Courts have not applied the continuous transaction doctrine to instances involving rape and kidnapping like the situation we have before us” and that, “[w]hile these two acts occurred close in time, they were not inseparable or concurrent actions,” with “[a]ll of the elements of the rape [having been] completed before defendant removed the victim to the storage closet.” Id. at 252 . ¶ 29 Finally, the Court of Appeals disagreed with the State’s argume	2	2022–2022
State v. Williams green nc · 1983 2 sentences 1992State v. Olson, 330 N.C. 557 , 411 S.E.2d 592 (1992) (armed robbery); State v. Pakulski, 319 N.C. 562 , 356 S.E.2d 319 (1987) (armed robbery); State v. Fields, 315 N.C. 191 , 337 S.E.2d 518 (1985) (armed robbery); State v. Thomas, 329 N.C. 423 , 407 S.E.2d 141 (1991) (sex offense); State v. Williams, 308 N.C. 47 , 301 S.E.2d 335 (sex offense), cert. denied, 464 U.S. 865 , 78 L. 1992State v. Olson, 330 N.C. 557 , 411 S.E.2d 592 (1992) (armed robbery); State v. Pakulski, 319 N.C. 562 , 356 S.E.2d 319 (1987) (armed robbery); State v. Fields, 315 N.C. 191 , 337 S.E.2d 518 (1985) (armed robbery); State v. Thomas, 329 N.C. 423 , 407 S.E.2d 141 (1991) (sex offense); State v. Williams, 308 N.C. 47 , 301 S.E.2d 335 (sex offense), cert. denied, 464 U.S. 865 , 78 L.	2	1991–1992
State v. Jaynes green nc · 1995 2 sentences 2000The continuous transaction doctrine was subsequently applied in the case State v. Jaynes, 342 N.C. 249 , 464 S.E.2d 448 (1995), cert. denied, 518 U.S. 1024 , 135 L.Ed.2d 1080 (1996), in which the facts are similar in important respects to the facts of the present case. 2000The continuous transaction doctrine was subsequently applied in the case State v. Jaynes, 342 N.C. 249 , 464 S.E.2d 448 (1995), cert. denied, 518 U.S. 1024 , 135 L.Ed.2d 1080 (1996), in which the facts are similar in important respects to the facts of the present case.	1	2000–2000
Dees v. Braddock green scotus · 1996 1 sentence 2000The continuous transaction doctrine was subsequently applied in the case State v. Jaynes, 342 N.C. 249 , 464 S.E.2d 448 (1995), cert. denied, 518 U.S. 1024 , 135 L.Ed.2d 1080 (1996), in which the facts are similar in important respects to the facts of the present case.	1	2000–2000
Fica v. Corrections Corp. of America green scotus · 1996 1 sentence 2000The continuous transaction doctrine was subsequently applied in the case State v. Jaynes, 342 N.C. 249 , 464 S.E.2d 448 (1995), cert. denied, 518 U.S. 1024 , 135 L.Ed.2d 1080 (1996), in which the facts are similar in important respects to the facts of the present case.	1	2000–2000
McDougall v. North Carolina green scotus · 1983 1 sentence 1992State v. Olson, 330 N.C. 557 , 411 S.E.2d 592 (1992) (armed robbery); State v. Pakulski, 319 N.C. 562 , 356 S.E.2d 319 (1987) (armed robbery); State v. Fields, 315 N.C. 191 , 337 S.E.2d 518 (1985) (armed robbery); State v. Thomas, 329 N.C. 423 , 407 S.E.2d 141 (1991) (sex offense); State v. Williams, 308 N.C. 47 , 301 S.E.2d 335 (sex offense), cert. denied, 464 U.S. 865 , 78 L.	1	1992–1992
State v. Fields green · 1985 2 sentences 1992State v. Olson, 330 N.C. 557 , 411 S.E.2d 592 (1992) (armed robbery); State v. Pakulski, 319 N.C. 562 , 356 S.E.2d 319 (1987) (armed robbery); State v. Fields, 315 N.C. 191 , 337 S.E.2d 518 (1985) (armed robbery); State v. Thomas, 329 N.C. 423 , 407 S.E.2d 141 (1991) (sex offense); State v. Williams, 308 N.C. 47 , 301 S.E.2d 335 (sex offense), cert. denied, 464 U.S. 865 , 78 L. 1992State v. Olson, 330 N.C. 557 , 411 S.E.2d 592 (1992) (armed robbery); State v. Pakulski, 319 N.C. 562 , 356 S.E.2d 319 (1987) (armed robbery); State v. Fields, 315 N.C. 191 , 337 S.E.2d 518 (1985) (armed robbery); State v. Thomas, 329 N.C. 423 , 407 S.E.2d 141 (1991) (sex offense); State v. Williams, 308 N.C. 47 , 301 S.E.2d 335 (sex offense), cert. denied, 464 U.S. 865 , 78 L.	1	1992–1992
State v. Pakulski green nc · 1987 2 sentences 1992State v. Olson, 330 N.C. 557 , 411 S.E.2d 592 (1992) (armed robbery); State v. Pakulski, 319 N.C. 562 , 356 S.E.2d 319 (1987) (armed robbery); State v. Fields, 315 N.C. 191 , 337 S.E.2d 518 (1985) (armed robbery); State v. Thomas, 329 N.C. 423 , 407 S.E.2d 141 (1991) (sex offense); State v. Williams, 308 N.C. 47 , 301 S.E.2d 335 (sex offense), cert. denied, 464 U.S. 865 , 78 L. 1992State v. Olson, 330 N.C. 557 , 411 S.E.2d 592 (1992) (armed robbery); State v. Pakulski, 319 N.C. 562 , 356 S.E.2d 319 (1987) (armed robbery); State v. Fields, 315 N.C. 191 , 337 S.E.2d 518 (1985) (armed robbery); State v. Thomas, 329 N.C. 423 , 407 S.E.2d 141 (1991) (sex offense); State v. Williams, 308 N.C. 47 , 301 S.E.2d 335 (sex offense), cert. denied, 464 U.S. 865 , 78 L.	1	1992–1992

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 14-39 (3) NC § N.C. Gen. Stat. § 15A-2000 (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

CA 20 (2001–2025) NC 6 (1991–2022) AL 2 (1989–1999)

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.

← Caselaw search · G Cite Topics · Brief Check

Your account

Appearance