State v. Hunt
365 N.C. 432
| N.C. | 2012Background
- Defendant Hunt was convicted of second-degree sexual offense and crime against nature involving a seventeen-year-old victim with a mental disability.
- State argued expert testimony on the victim's mental capacity to consent was not required; defense sought dismissal for lack of such expert proof.
- Trial evidence included Clara’s own trial testimony and six lay witnesses describing her disabilities and functioning.
- Court of Appeals reversed, holding expert testimony was necessary because Clara’sIQ fell in the ‘mental retardation’ range but she was highly functional in daily life.
- North Carolina Supreme Court held expert testimony is not categorically required; substantial lay and circumstantial evidence can establish mental incapacity.
- Court clarified standard of review for motions to dismiss and reaffirmed that evidence supported convictions under N.C.G.S. §§ 14-27.5(a)(2) and 14-177.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is expert testimony required to prove victim's mental capacity to consent? | State contends expert proof is not mandatory under Rule 702. | Hunt argues lack of expert testimony renders insufficiency of evidence. | Expert testimony not mandatory; substantial evidence suffices. |
| Does the State's non-expert evidence establish Clara's mental disability and defendant's knowledge? | State relied on lay and observational evidence of Clara's disability. | Hunt argues such evidence is insufficient without expert testimony. | Yes, lay and observed evidence properly supported the charges. |
Key Cases Cited
- State v. Abshire, 363 N.C. 322 (2009) (substantial evidence standard for sufficiency of evidence)
- State v. Mayhand, 298 N.C. 418 (1979) (lay observations admissible on mental capacity)
- In re Will of Brown, 203 N.C. 347 (1932) (judicial assessment of mental capacity based on observations)
- Clary's Adm'rs v. Clary, 24 N.C. (2 Ired.) 78 (1841) (admissibility of lay opinions on mental condition)
- Moore v. N.Y. Life Ins. Co., 266 N.C. 440 (1966) (capacity determinations may rely on non-expert testimony)
- State v. Armstrong, 232 N.C. 727 (1950) (credibility and mental condition considerations in contract/criminal context)
- Bryant v. Carrier, 214 N.C. 191 (1938) (permissibility of lay testimony on mental incapacity)
- State v. Whiteley, 172 N.C.App. 772 (2005) (non-expert evidence can support lack of capacity)