State v. LangleyÂ, 254 N.C. App. 186

Defendant Willie James Langley was tried for multiple offenses arising from a shooting; jury convicted him of several felonies including attempted first-degree murder and assault with a deadly weapon.
During deliberations the jury sent notes asking for clarification about intent and whether attempted-murder counts had to have the same verdict; the court reread instructions and provided written copies.
The next morning the jury foreperson reported that one juror had used Google to research “intent to kill” outside the jury room; the court orally admonished the jury, quizzed them collectively about following only the court’s law, and received affirmative responses from all jurors.
Defense moved for a mistrial after the admonishment; the court denied the motion (offering but not conducting individual juror interviews).
The State then tried Defendant as a habitual felon; the indictment listed three prior felony convictions but failed on its face to show the offense dates corresponding to two of the convictions (it listed offense dates for robberies with a dangerous weapon but conviction entries for common-law robbery without alleging the matching offense dates).
The jury found Defendant an habitual felon; the Court of Appeals vacated the habitual-felon judgment because the habitual-felon indictment was facially deficient and remanded for resentencing on the underlying felonies without the habitual enhancement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juror misconduct / mistrial	State: Court’s admonition and offer to question jurors sufficed; no prejudice shown	Langley: Internet research by a juror tainted deliberations; mistrial required	Denied: any error was invited by defense because court offered further inquiry and defense declined; no abuse of discretion shown
Constructive amendment of habitual-felon indictment via jury instructions	State: not reached (court deemed indictment issue dispositive)	Langley: jury instructions materially varied from the indictment	Not reached — court did not decide because it resolved case on facial-indictment defect
Facial sufficiency of habitual-felon indictment	State: indictment adequate (implicitly argued compliance)	Langley: indictment failed to allege required offense dates for two prior convictions, violating §14-7.3	Held: indictment facially deficient for failing to list offense dates matching the convictions; habitual-felon conviction vacated and case remanded for resentencing without enhancement

State v. Salentine, 237 N.C. App. 76 (discretionary standard for mistrial review; juror-misconduct principles)
State v. Payne, 280 N.C. 170 (invited error doctrine — party who causes or joins in error may not later complain)
State v. Cheek, 339 N.C. 725 (interpreting §14-7.3; habitual-felon indictment requirements)
State v. Wallace, 351 N.C. 481 (facial-indictment defects may be raised at any time because they implicate jurisdiction)
State v. Petersilie, 334 N.C. 169 (vacatur required where indictment or proceedings fatally defective)