State v. Hague,, 225A24

Blaine Dale Hague shot and killed Thomas Cass on 7 September 2020 after a confrontation in a cornfield where Cass and others were dove hunting with permission. 1
Hague claimed self-defense, testifying that Cass pushed him down, then reached into his vest as if for a handgun before Hague shot him once. 2
At trial, Hague sought to introduce Cass's prior felony convictions to show his fear was reasonable because he knew Cass illegally carried firearms. 3
The trial court excluded the felony-conviction evidence under Rules 404(a)(2) and 404(b) and redacted Hague's 911 call to remove references to Cass's felon status. 4
The jury convicted Hague of first-degree murder and life without parole; the Court of Appeals ordered a new trial, and the State appealed while Hague sought review of the jury-instruction ruling. 5
The Supreme Court held the felony-conviction evidence was wrongly excluded and prejudicial, dismissed the stand-your-ground issue as improvidently allowed, and did not reach sufficiency of the evidence. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were Cass's prior felony convictions admissible under Rule 404(b)? 7	State said convictions were improper propensity evidence.	Hague said they showed his state of mind and reasonable fear.	Yes; exclusion was error. 8
Was exclusion of the felony-conviction evidence prejudicial? 9	State said any error was harmless.	Hague said the exclusion undermined self-defense and credibility.	Yes; the error was prejudicial. 10
Should the court decide the Rule 403 issue? 11	State argued the evidence also failed Rule 403.	Hague said Rule 403 was not properly preserved or decided.	No; left for retrial court. 12
Was the stand-your-ground instruction properly denied? 13	Hague challenged the instruction ruling.	State defended the trial court.	Review dismissed as improvidently allowed. 14
Was there enough evidence of premeditation and deliberation? 15	State supported first-degree murder.	Hague moved to dismiss for insufficient evidence.	Not reached because a new trial was ordered. 16

State v. Beckelheimer, 366 N.C. 127 (N.C. 2012) (Rule 404(b) review is de novo; Rule 403 is abuse of discretion 17)
State v. Pabon, 380 N.C. 241 (N.C. 2022) (erroneous 404(b) rulings are reviewed for prejudice 18)
State v. Coffey, 326 N.C. 268 (N.C. 1990) (Rule 404(b) is a rule of inclusion for relevant other-acts evidence 19)
State v. Jacobs, 363 N.C. 815 (N.C. 2010) (victim bad acts may be admissible when relevant to defendant's state of mind 20)
State v. Smith, 337 N.C. 658 (N.C. 1994) (victim convictions are irrelevant absent defendant's awareness of them 21)
State v. Strickland, 346 N.C. 443 (N.C. 1997) (defendant must know of prior act and its connection to the killing 22)
State v. Gillard, 386 N.C. 797 (N.C. 2024) (Rule 403 balancing follows a proper 404(b) determination 23)
State v. Bell, 338 N.C. 363 (N.C. 1994) (premeditation may be shown by weapon preparation tied to the killing 24)
State v. Lee, 370 N.C. 671 (N.C. 2018) (reasonableness of defendant's force is central to self-defense 25)
State v. Morgan, 315 N.C. 626 (N.C. 1986) (self-defense focuses on the reasonableness of the defendant's belief 26)