State v. Beam, 232 N.C. App. 56

Defendant Namath Beam was convicted on 28 September 2012 of possession of heroin and trafficking in opium or heroin by transportation after being the driver in a drug transaction involving Ponce on 13 April 2011.
Officers, following a search warrant at Sprinkle’s home, relied on Sprinkle’s cooperation to identify a heroin source, leading to the transaction where heroin was dropped from the truck driven by Beam with Ponce as a passenger.
A total of 20.2 grams of heroin were recovered from the truck Beam drove, forming the basis for the possession and trafficking by transportation charges.
Beam challenged jury instructions, arguing the court should have given a knowledge-of-identity instruction related to Footnote 4 of pattern instructions for cases where the defendant contends he did not know the substance involved.
Beam also challenged testimony about prior drug dealings involving Beam as improper, and sought examination of sealed records for potential impeaching or exculpatory material, which the court denied.
The trial court denied Beam’s requested instruction, held there was no plain error in the testimony, and found no basis for granting a new trial based on sealed records; the convictions and sentence were affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by not giving the knowledge instruction	Beam contends Coleman requires the extra instruction on knowledge of identity.	Beam contends the court should have instructed that he knew the substance was heroin.	No error; instruction not required given the defense did not claim confusion about substance identity.
Whether the testimony about Beam driving on prior occasions was plain error	Beam asserts the testimony was irrelevant and prejudicial and not properly curbed.	Beam argues the testimony could influence the jury improperly despite limiting instruction.	No plain error; limiting instruction and other evidence mitigated potential prejudice.
Whether the sealed records warrant a new trial	Beam seeks new trial if the sealed records contain relevant exculpatory or impeaching material.	Beam claims the envelope could reveal discoverable material.	No error; sealed envelope contained nothing warranting relief.

State v. Coleman, 742 S.E.2d 346 (N.C. App. 2013) (required instruction when defendant claims not to know identity of contraband; distinguishable here)