N.C. Gen. Stat. » Chapter 15A
NC General Statutes

N.C. Gen. Stat. § 15A-1214 (2026)

Selection of jurors; procedure

✓ current as of July 2026
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(a) The clerk, under the supervision of the presiding judge, must call jurors from the panel by a system of random selection which precludes advance knowledge of the identity of the next juror to be called. When a juror is called and he is assigned to the jury box, he retains the seat assigned until excused.

(b) The judge must inform the prospective jurors of the case in accordance with G.S. 15A-1213. He may briefly question prospective jurors individually or as a group concerning general fitness and competency to determine whether there is cause why they should not serve as jurors in the case.

(c) The prosecutor and the defense counsel, or the defendant if not represented by counsel, may personally question prospective jurors individually concerning their fitness and competency to serve as jurors in the case to determine whether there is a basis for a challenge for cause or whether to exercise a peremptory challenge. The prosecution or defense is not foreclosed from asking a question merely because the court has previously asked the same or similar question.

(d) The prosecutor must conduct his examination of the first 12 jurors seated and make his challenges for cause and exercise his peremptory challenges. If the judge allows a challenge for cause, or if a peremptory challenge is exercised, the clerk must immediately call a replacement into the box. When the prosecutor is satisfied with the 12 in the box, they must then be tendered to the defendant. Until the prosecutor indicates his satisfaction, he may make a challenge for cause or exercise a peremptory challenge to strike any juror, whether an original or replacement juror.

(e) Each defendant must then conduct his examination of the jurors tendered him, making his challenges for cause and his peremptory challenges. If a juror is excused, no replacement may be called until all defendants have indicated satisfaction with those remaining, at which time the clerk must call replacements for the jurors excused. The judge in his discretion must determine order of examination among multiple defendants.

(f) Upon the calling of replacement jurors, the prosecutor must examine the replacement jurors and indicate satisfaction with a completed panel of 12 before the replacement jurors are tendered to a defendant. Only replacement jurors may be examined and challenged. This procedure is repeated until all parties have accepted 12 jurors.

(g) If at any time after a juror has been accepted by a party, and  before the jury is impaneled, it is discovered that the juror has made an incorrect statement during voir dire or that some other good reason exists:

(1) The judge may examine, or permit counsel to examine, the juror to determine whether there is a basis for challenge for cause.

(2) If the judge determines there is a basis for challenge for cause, he must excuse the juror or sustain any challenge for  cause that has been made.

(3) If the judge determines there is no basis for challenge for cause, any party who has not exhausted his peremptory challenges may challenge the juror.

Any replacement juror called is subject to examination, challenge for cause, and peremptory challenge as any other unaccepted juror.

(h) In order for a defendant to seek reversal of the case on appeal on the ground that the judge refused to allow a challenge made for cause, he must have:

(1) Exhausted the peremptory challenges available to him;

(2) Renewed his challenge as provided in subsection (i) of this section; and

(3) Had his renewal motion denied as to the juror in question.

(i) A party who has exhausted his peremptory challenges may move orally or in writing to renew a challenge for cause previously denied if the party either:

(1) Had peremptorily challenged the juror; or

(2) States in the motion that he would have challenged that juror peremptorily had his challenges not been exhausted.

The judge may reconsider his denial of the challenge for cause, reconsidering facts and arguments previously adduced or taking cognizance of additional facts and arguments presented. If upon reconsideration the judge determines that the juror should have been excused for cause, he must allow the party an additional peremptory challenge.

(j) In capital cases the trial judge for good cause shown may direct that jurors be selected one at a time, in which case each juror must first be passed by the State. These jurors may be sequestered before and after selection. (1977, c. 711, s. 1.)

 

Notes of Decisions
Cited in 160 cases (13 in the last 5 years), 1979–2026 · leading case: State v. Garcia, 597 S.E.2d 724 (N.C. 2004).
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State v. Garcia, 597 S.E.2d 724 (N.C. 2004). · cites it 54× “The General Assembly codified the method by which juries are to be selected in North Carolina in N.C.G.S. § 15A-1214. N.C.G.S. § 15A-1214 (2003).”
In re E.D., 827 S.E.2d 450 (N.C. 2019). · cites it 43× “Unlike the cases involving the requirement that jurors be selected from the panel at random under N.C.G.S. § 15A-1214(a), our cases, such **120 as Lawrence , which concern the requirement that a prosecutor tender a full panel of jurors to the defendant under N.”
State v. Roache, 595 S.E.2d 381 (N.C. 2004). · cites it 18× “Jury selection in criminal cases is controlled by N.C.G.S. § 15A-1214. Subsections (d) through (f) set forth a procedure to be *273 followed in the majority of cases.”
State v. Stroud, 557 S.E.2d 544 (N.C. Ct. App. 2001). · cites it 14× “Edwards contends this process violated the provisions of N.C. Gen.Stat. § 15A-1214 and entitles her to a new trial.”
State v. Tirado, 599 S.E.2d 515 (N.C. 2004). · cites it 12× “Although we do not determine whether the court's action violated N.C.G.S. § 15A-1214, even if there was a violation, neither defendant can demonstrate prejudice.”
State v. Fleming, 512 S.E.2d 720 (N.C. 1999). · cites it 21× “N.C.G.S. § 15A-1214 provides, in pertinent part: (d) The prosecutor must conduct his examination of the first 12 jurors seated and make his challenges for cause and exercise his peremptory challenges.”
State v. Conaway, 453 S.E.2d 824 (N.C. 1995). · cites it 17× “As the trial court acted in compliance with the jury selection procedure set forth in N.C.G.S. § 15A-1214 and reasonably interpreted defendant’s comment to be an expression of confusion about the jury selection procedure, the trial court’s action was not error, and this…”
State v. Anderson, 558 S.E.2d 87 (N.C. 2002). · cites it 18× “Defendant further argues that the trial court committed reversible error by employing the method of jury selection mandated by N.C.G.S. § 15A-1214. Under the statute, the State has the first opportunity to question prospective jurors and exercise its challenges.”
State v. Golphin, 533 S.E.2d 168 (N.C. 2000). · cites it 12× “JURY SELECTION ISSUES By assignments of error, both defendants argue, pursuant to N.C.G.S. § 15A-1214(a), the trial court violated its statutory duty to ensure jury selection was conducted in a random manner.”
State v. Smith, 607 S.E.2d 607 (N.C. 2005). · cites it 20× “Next, defendant contends the trial court failed to comply with the N.C.G.S. § 15A-1214(a) requirement for random jury selection when it placed a prospective juror in a specific seat after that juror was randomly called to fill another seat.”
State v. Wiley, 565 S.E.2d 22 (N.C. 2002). · cites it 9× “Defendant asserts that when only one prospective juror remains, all parties know the identity of the next person called into the jury box.”
State v. Clemmons, 639 S.E.2d 110 (N.C. Ct. App. 2007). · cites it 35× “Because I believe that defendant has preserved his right to bring forward this assignment of error pursuant to N.C. Gen.Stat. § 15A-1214(h) (2004), I respectfully dissent.”
Show all 160 citing cases →
— N.C. Gen. Stat. § 15A-1214(J) — 1 case
State v. Roache, 595 S.E.2d 381 (N.C. 2004). “Jury selection in criminal cases is controlled by N.C.G.S. § 15A-1214. Subsections (d) through (f) set forth a procedure to be *273 followed in the majority of cases.”
— N.C. Gen. Stat. § 15A-1214(a) — 23 cases
In re E.D., 827 S.E.2d 450 (N.C. 2019). “Unlike the cases involving the requirement that jurors be selected from the panel at random under N.C.G.S. § 15A-1214(a), our cases, such **120 as Lawrence , which concern the requirement that a prosecutor tender a full panel of jurors to the defendant under N.”
State v. Golphin, 533 S.E.2d 168 (N.C. 2000). “JURY SELECTION ISSUES By assignments of error, both defendants argue, pursuant to N.C.G.S. § 15A-1214(a), the trial court violated its statutory duty to ensure jury selection was conducted in a random manner.”
State v. Wiley, 565 S.E.2d 22 (N.C. 2002). “Defendant asserts that when only one prospective juror remains, all parties know the identity of the next person called into the jury box.”
State v. Tirado, 599 S.E.2d 515 (N.C. 2004). “Although we do not determine whether the court's action violated N.C.G.S. § 15A-1214, even if there was a violation, neither defendant can demonstrate prejudice.”
State v. Badgett, 644 S.E.2d 206 (N.C. 2007).
— N.C. Gen. Stat. § 15A-1214(b) — 2 cases
State v. McDowell, 407 S.E.2d 200 (N.C. 1991).
State v. Fessler, 603 S.E.2d 407 (N.C. Ct. App. 2004).
— N.C. Gen. Stat. § 15A-1214(c) — 31 cases
In re E.D., 827 S.E.2d 450 (N.C. 2019). “Unlike the cases involving the requirement that jurors be selected from the panel at random under N.C.G.S. § 15A-1214(a), our cases, such **120 as Lawrence , which concern the requirement that a prosecutor tender a full panel of jurors to the defendant under N.”
State v. Fletcher, 500 S.E.2d 668 (N.C. 1998).
State v. Rodriguez, 814 S.E.2d 11 (N.C. 2018).
State v. Weeks, 367 S.E.2d 895 (N.C. 1988).
State v. Chapman, 611 S.E.2d 794 (N.C. 2005).
— N.C. Gen. Stat. § 15A-1214(d) — 15 cases
In re E.D., 827 S.E.2d 450 (N.C. 2019). “Unlike the cases involving the requirement that jurors be selected from the panel at random under N.C.G.S. § 15A-1214(a), our cases, such **120 as Lawrence , which concern the requirement that a prosecutor tender a full panel of jurors to the defendant under N.”
State v. Garcia, 597 S.E.2d 724 (N.C. 2004). “The General Assembly codified the method by which juries are to be selected in North Carolina in N.C.G.S. § 15A-1214. N.C.G.S. § 15A-1214 (2003).”
State v. Fleming, 512 S.E.2d 720 (N.C. 1999). “N.C.G.S. § 15A-1214 provides, in pertinent part: (d) The prosecutor must conduct his examination of the first 12 jurors seated and make his challenges for cause and exercise his peremptory challenges.”
State v. Roache, 595 S.E.2d 381 (N.C. 2004). “Jury selection in criminal cases is controlled by N.C.G.S. § 15A-1214. Subsections (d) through (f) set forth a procedure to be *273 followed in the majority of cases.”
State v. Lawrence, 530 S.E.2d 807 (N.C. 2000).
— N.C. Gen. Stat. § 15A-1214(e) — 6 cases
State v. Conaway, 453 S.E.2d 824 (N.C. 1995). “As the trial court acted in compliance with the jury selection procedure set forth in N.C.G.S. § 15A-1214 and reasonably interpreted defendant’s comment to be an expression of confusion about the jury selection procedure, the trial court’s action was not error, and this…”
State v. Roache, 595 S.E.2d 381 (N.C. 2004). “Jury selection in criminal cases is controlled by N.C.G.S. § 15A-1214. Subsections (d) through (f) set forth a procedure to be *273 followed in the majority of cases.”
State v. Jaynes, 549 S.E.2d 179 (N.C. 2001).
State v. Anderson, 558 S.E.2d 87 (N.C. 2002). “Defendant further argues that the trial court committed reversible error by employing the method of jury selection mandated by N.C.G.S. § 15A-1214. Under the statute, the State has the first opportunity to question prospective jurors and exercise its challenges.”
State v. Fleming, 512 S.E.2d 720 (N.C. 1999). “N.C.G.S. § 15A-1214 provides, in pertinent part: (d) The prosecutor must conduct his examination of the first 12 jurors seated and make his challenges for cause and exercise his peremptory challenges.”
— N.C. Gen. Stat. § 15A-1214(f) — 4 cases
State v. Garcia, 597 S.E.2d 724 (N.C. 2004). “The General Assembly codified the method by which juries are to be selected in North Carolina in N.C.G.S. § 15A-1214. N.C.G.S. § 15A-1214 (2003).”
In re E.D., 827 S.E.2d 450 (N.C. 2019). “Unlike the cases involving the requirement that jurors be selected from the panel at random under N.C.G.S. § 15A-1214(a), our cases, such **120 as Lawrence , which concern the requirement that a prosecutor tender a full panel of jurors to the defendant under N.”
State v. Roache, 595 S.E.2d 381 (N.C. 2004). “Jury selection in criminal cases is controlled by N.C.G.S. § 15A-1214. Subsections (d) through (f) set forth a procedure to be *273 followed in the majority of cases.”
State v. Anderson, 558 S.E.2d 87 (N.C. 2002). “Defendant further argues that the trial court committed reversible error by employing the method of jury selection mandated by N.C.G.S. § 15A-1214. Under the statute, the State has the first opportunity to question prospective jurors and exercise its challenges.”
— N.C. Gen. Stat. § 15A-1214(g) — 21 cases
State v. Boggess, 600 S.E.2d 453 (N.C. 2004).
State v. Goss, 651 S.E.2d 867 (N.C. 2007).
State v. Womble, 473 S.E.2d 291 (N.C. 1996).
State v. Charles Phillips Bond, 478 S.E.2d 163 (N.C. 1996).
State v. Rogers, 341 S.E.2d 713 (N.C. 1986).
— N.C. Gen. Stat. § 15A-1214(g)(1) — 3 cases
State v. Freeman, 333 S.E.2d 743 (N.C. 1985).
State v. Gidderon (N.C. Ct. App. 2023).
State v. Crowder (N.C. Ct. App. 2026).
— N.C. Gen. Stat. § 15A-1214(g)(2) — 1 case
State v. Crowder (N.C. Ct. App. 2026).
— N.C. Gen. Stat. § 15A-1214(g)(3) — 1 case
State v. Crowder (N.C. Ct. App. 2026).
— N.C. Gen. Stat. § 15A-1214(g)(l) — 2 cases
State v. Boggess, 600 S.E.2d 453 (N.C. 2004).
State v. Freeman, 333 S.E.2d 743 (N.C. 1985).
— N.C. Gen. Stat. § 15A-1214(h) — 47 cases
State v. Walters, 588 S.E.2d 344 (N.C. 2003).
State v. McNeil, 375 S.E.2d 909 (N.C. 1989).
State v. Quick, 405 S.E.2d 179 (N.C. 1991).
State v. Campbell, 617 S.E.2d 1 (N.C. 2005).
State v. Cummings, 648 S.E.2d 788 (N.C. 2007).
— N.C. Gen. Stat. § 15A-1214(h)(1) — 1 case
State v. Crowder (N.C. Ct. App. 2026).
— N.C. Gen. Stat. § 15A-1214(h)(2) — 3 cases
State v. Morgan, 604 S.E.2d 886 (N.C. 2004).
State v. Lowery, 723 S.E.2d 358 (N.C. Ct. App. 2012).
State v. Morgan, 596 S.E.2d 244 (N.C. 2004).
— N.C. Gen. Stat. § 15A-1214(h)(l) — 1 case
State v. Brown, 358 S.E.2d 1 (N.C. 1987).
— N.C. Gen. Stat. § 15A-1214(i) — 10 cases
State v. Smith, 607 S.E.2d 607 (N.C. 2005). “Next, defendant contends the trial court failed to comply with the N.C.G.S. § 15A-1214(a) requirement for random jury selection when it placed a prospective juror in a specific seat after that juror was randomly called to fill another seat.”
State v. Bonnett, 502 S.E.2d 563 (N.C. 1998).
State v. House, 456 S.E.2d 292 (N.C. 1995).
State v. Clemmons, 639 S.E.2d 110 (N.C. Ct. App. 2007). “Because I believe that defendant has preserved his right to bring forward this assignment of error pursuant to N.C. Gen.Stat. § 15A-1214(h) (2004), I respectfully dissent.”
State v. Lowery, 723 S.E.2d 358 (N.C. Ct. App. 2012).
— N.C. Gen. Stat. § 15A-1214(j) — 24 cases
State v. Holden, 362 S.E.2d 513 (N.C. 1987).
State v. Brown, 337 S.E.2d 808 (N.C. 1985).
State v. Weeks, 367 S.E.2d 895 (N.C. 1988).
State v. McLaughlin, 372 S.E.2d 49 (N.C. 1988).
State v. Hunt, 373 S.E.2d 400 (N.C. 1988).
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