State v. Langley, 371 N.C. 389

On Sept. 24, 2014, defendant Willie Langley (passenger) fired an AK47/SKS at a fleeing vehicle, injuring a passenger; he was indicted on multiple charges including attempted first-degree murder, possession of a firearm by a felon, discharging a weapon into an occupied vehicle, and as an habitual felon.
The habitual felon bill alleged three prior felonies with both alleged offense dates (dates committed) and conviction dates, but identified two prior convictions as "Common Law Robbery" while the alleged underlying offenses were listed as "Robbery with a Dangerous Weapon."
At trial the jury convicted Langley on all charges; the trial court imposed sentences including an habitual-felon enhancement.
On appeal Langley argued the habitual felon indictment was facially defective because it did not allege matching offense and conviction dates for the same offenses (i.e., the indictment seemed to show different offense names than convictions), potentially allowing impermissible overlap of the three prior felonies.
The Court of Appeals vacated the habitual felon judgment, holding § 14-7.3 requires that for each prior conviction the indictment list both the date the felony was committed and the date the defendant was convicted of that same felony.
The Supreme Court of North Carolina granted discretionary review and reversed: it held the indictment satisfied § 14-7.3 and was not fatally defective, in part because an indictment charging a greater offense includes lesser-included offenses.

Issue	State's Argument	Langley's Argument	Held
Whether the habitual-felon indictment was fatally defective for failing to allege the same offense name for both the commission date and the conviction date	§ 14-7.3 does not require naming the specific prior offense beyond alleging it was a felony; the indictment included required dates, sovereign, conviction dates, and court — names are surplusage	The indictment must allege the date the felony was committed and the date the defendant was convicted of that same felony so the three prior felonies cannot overlap	The indictment complied with § 14-7.3 and was not fatally defective; reversal of Court of Appeals and remand for remaining issues

State v. Cheek, 339 N.C. 725 (1995) (describing § 14-7.3 content for habitual-felon indictment)
State v. Freeman, 314 N.C. 432 (1985) (courts should not engraft unnecessary pleading burdens)
State v. McBane, 276 N.C. 60 (1969) (valid indictment is essential to jurisdiction)
State v. Williams, 368 N.C. 620 (2016) (modern, less formal pleading standards)
State v. Baker, 369 N.C. 586 (2017) (an indictment includes lesser-included offenses)
State v. Russell, 282 N.C. 240 (1972) (indictment purpose: notice and enable judgment)
State v. Thomas, 325 N.C. 583 (1989) (conviction of lesser included offense when elements are subsumed)