State v. BradfordÂ, 252 N.C. App. 371

At a Raleigh Exxon on July 14, 2015, Breyon Bradford (defendant) rode as a passenger in a burgundy Volkswagen Passat; occupants of a nearby Buick (Najee and James Cunningham) alleged Bradford pointed a handgun at them.
As the Passat sped away from the station onto New Bern Avenue, Bradford leaned out the passenger window and fired multiple shots toward the Buick and nearby buildings.
Bullets struck Najee (front passenger) and a hotel occupant (Wylie Mendicino); Bradford exited the Passat at Rodgers Lane, fled on foot, and later disposed of the handgun.
Holden (the Passat’s driver) identified Bradford as the shooter; Bradford testified he acted in self‑defense and admitted disposing of the gun.
A jury convicted Bradford of multiple counts (assault with a deadly weapon with intent to kill inflicting serious injury; discharging a firearm into occupied property; and assault with a deadly weapon with intent to kill), acquitted him of one count involving a child, and the trial court imposed consecutive and suspended sentences.
On appeal Bradford argued the trial court erred by instructing the jury on flight (he was a passenger, not the driver) and that clerical errors (wrong file numbers on verdict/judgment documents) required correction.

Issue	State's Argument	Bradford's Argument	Held
Whether jury instruction on flight was proper	Evidence (defendant fled on foot, told driver to stop at Rodgers Lane, disposed of gun) supported a flight instruction showing consciousness of guilt	Instruction improper because Bradford was a passenger, not driver, so State lacked evidence he fled to avoid apprehension	Instruction proper — flight instruction supported by evidence (disposing gun, abandoning vehicle, leaving on foot), passenger status not dispositive
Whether clerical errors in documents require correction	Clerical errors on face of records should be corrected	Asked correction of incorrect file numbers on verdict sheets, final judgment forms, appellate entries	Remand limited to correcting clerical errors; conviction and sentences otherwise affirmed

State v. Allen, 193 N.C. App. 375 (discussion that flight instruction review is for abuse of discretion and that atypical conduct may show steps to avoid apprehension)
State v. Lloyd, 354 N.C. 76 (flight instruction allowable where evidence shows steps to avoid apprehension)
State v. Nixon, 117 N.C. App. 141 (flight instruction proper where defendant left scene and disposed of gun)
State v. Smith, 188 N.C. App. 842 (clerical errors discovered on appeal warrant remand for correction)
State v. Gillespie, 771 S.E.2d 785 (errors on judgment forms that do not affect sentence are clerical and remandable)