State v. Campbell, 368 N.C. 83

Defendant was indicted for felony breaking or entering a place of worship and felony larceny for stealing audio equipment from Manna Baptist Church and Andy Stevens.
Evidence: church doors may have been left unlocked on the night in question; no forced entry; defendant’s wallet was found inside near where equipment had been stored.
Defendant admitted being at the church but said he did not remember what he did; testified he entered for water and sanctuary and denied taking anything.
Detective testimony included a custodial statement by defendant acknowledging presence at the church and not remembering actions; EMT observed defendant disheveled after wandering all night.
Trial court denied motions to dismiss; jury convicted of felony larceny and felony breaking/entering. Court of Appeals reversed larceny conviction (indictment defect) and breaking/entering (insufficient intent) and remanded for misdemeanor entry; State appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an indictment naming a church as a co-owner is fatally defective for failing to allege the church is an entity capable of owning property	Indictment valid because naming a natural person (Andy Stevens) and the church together suffices; the word “church” imports an entity capable of owning property	Indictment defective because it did not expressly allege Manna Baptist Church is a corporation or legal entity capable of owning property	The court held the indictment valid: naming an entity as a “church” imports an association capable of owning property, so no fatal defect
Whether the State presented sufficient evidence of intent to commit larceny to support felony breaking/entering conviction	State argued circumstantial evidence (late-night unauthorized entry, wallet found near missing equipment, defendant’s admissions and memory gaps) permitted inference of intent	Defendant argued lack of direct evidence and his testimony that he entered for water/sanctuary and did not take anything undermined intent	The court held the evidence, viewed in the light most favorable to the State, was sufficient for a jury to infer intent; denial of dismissal was proper

State v. Sturdivant, 304 N.C. 293 (principles on indictment sufficiency and jurisdiction)
McClure v. State, 267 N.C. 212 (conviction must be vacated if indictment invalid)
State v. Jessup, 279 N.C. 108 (larceny indictment must allege ownership in a person or legal entity)
State v. Thornton, 251 N.C. 658 (when entity name must import capacity to own property)
State v. Bell, 285 N.C. 746 (intent for breaking/entering often proven by circumstantial evidence and conduct inside the building)
State v. Sweezy, 291 N.C. 366 (pushing open an unlocked door can constitute a breaking)
State v. Myrick, 306 N.C. 110 (standard for surviving motion to dismiss; substantial evidence of each element required)
State v. Powell, 299 N.C. 95 (court must view evidence in the light most favorable to the State)