State v. Arrington, 371 N.C. 518

In 2015 Arrington pled guilty to new offenses; as part of the plea he stipulated on a sentencing worksheet to multiple prior convictions, including a 1994 second-degree murder, and agreed it was classified as Class B1 for prior-record scoring.
The State and defense stipulated to the sentencing worksheet at the sentencing hearing; the court accepted the plea and sentenced Arrington in the mitigated range as an habitual felon.
The Court of Appeals vacated the judgment and plea, holding the B1/B2 classification was a question of law and thus an improper subject of party stipulation after the 2012 statutory split of second-degree murder into B1 (default) and B2 (two factual exceptions).
The North Carolina Supreme Court granted review to resolve whether a defendant may stipulate to a prior conviction’s classification (B1 vs B2) on a worksheet when classification depends on the facts underlying the prior conviction.
The Supreme Court reversed the Court of Appeals: it held that stipulating to a prior conviction and its worksheet classification is a permissible factual stipulation to the underlying conduct, which enables the trial judge to make the legal classification and score prior-record points.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a defendant may stipulate, on a sentencing worksheet, that a prior second-degree murder conviction is B1 rather than B2	Stipulations to prior convictions may include the facts supporting classification; Arrington’s stipulation was a factual admission that his prior conduct fell outside the B2 exceptions, so classification as B1 was proper	The B1/B2 classification is a legal determination created by the 2012 statute; parties cannot bind the court on questions of law by stipulation, so the stipulation was improper	Court held stipulation to the prior conviction and its B1 designation was permissible as a factual stipulation to the underlying conduct; reversed the Court of Appeals

State v. Sanders, 367 N.C. 716 (2014) (addresses limits on stipulating to legal questions when comparing out-of-state elements)
State v. Wingate, 213 N.C. App. 419 (2011) (upheld stipulation to a prior conviction’s felony class where statutory text permitted factual characterization)
State v. Pickens, 335 N.C. 717 (1994) (recited facts of the underlying homicide relevant to Arrington/Pickens convictions)
State v. Coble, 351 N.C. 448 (2000) (defines second-degree murder elements)
State v. Reynolds, 307 N.C. 184 (1982) (describes forms of malice relevant to murder classification)