State v. Edmonds, 212 N.C. App. 575

Defendant Kennedy Edmonds was convicted by jury of statutory rape of a fifteen-year-old and indecent liberties with a child.
Indictment charged statutory rape of a person 13–15 and indecent liberties with a child; sentencing was consecutive terms totaling 336–413 months and 21–26 months.
State trial evidence showed Carolyn, age 15, identified Edmonds as attacker after he lured her inside, assaulted her, and told her not to tell anyone.
DNA evidence indicated Edmonds could not be excluded as a contributor to samples from Carolyn.
Defendant testified he knew Carolyn, claimed she attempted to leave unpaid for a camera, and claimed another person caused the torn pants and assault.
Defense challenged cross-examination limits on Carolyn's sexual history, admission of unredacted medical records, and limitations on closing arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether cross-examination on victim's sexual history was properly limited	Edmonds contends Rule 412 barred critical impeachment.	Edmonds argues broader cross-examination is admissible for impeachment.	Trial court properly limited cross-examination under Rule 412; no reversible error.
Whether unredacted medical records should have been admitted	Redacted vs. unredacted records affect probative value.	Unredacted records could impeach credibility about prior sexual history.	Court correctly excluded unredacted records; not prejudicial given lack of sworn history and trial context.
Whether closing arguments were improperly limited	Edmonds could argue that someone else committed the assault.	Limitation prevented proper defense theory.	Trial court's closing-argument limitations upheld; no error shown due to lack of record of specific disputed phrases.

State v. Herring, 322 N.C. 733 (1988) (scope of cross-examination to be within trial court's discretion)
State v. Coffey, 326 N.C. 268 (1990) (cross-examination rights balanced with evidentiary rules)
State v. Pallas, 144 N.C.App. 277 (2001) (limits on cross-examination consistent with evidence rules)
State v. Oliver, 159 N.C.App. 451 (2003) (cross-examination versus rape-shield considerations)
Fortney, 301 N.C. 31 (1980) (rape-shield rationale regarding relevance of prior acts)
State v. Younger, 306 N.C. 692 (1982) (admissibility vs. probative value of prior sexual history for impeachment)
State v. Autry, 321 N.C. 392 (1988) (rape-shield rule does not violate confrontation rights)
State v. Dorton, 172 N.C.App. 759 (2005) (admission of impeachment evidence evaluated for probative value)
State v. Bass, 121 N.C.App. 306 (1996) (prior inconsistent statements may be admitted for impeachment outside Rule 412 exceptions)
State v. McCain, 39 N.C.App. 213 (1978) (appellate review strictness on record for closing-argument issues)