State v. Mangum, 242 N.C. App. 202

Mangum and Daye lived together with Mangum's three children after starting to date in early 2011.
In the early hours after a party, Daye and Mangum argued about money; Daye demanded $700 and a confrontation ensued.
Daye was stabbed with a knife during the altercation in the apartment; he died days later from the wound.
Police found knives, broken glass, bloodstains, and hair throughout the apartment; Mangum was arrested.
Mangum was indicted for first-degree murder; the State sought to present Rule 404(b) evidence about a 2010 Walker incident; pre-trial motions occurred and a voir dire was held.
At trial in 2013, the jury found Mangum guilty of second-degree murder and not guilty of larceny; she was sentenced to 170–216 months.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 404(b) evidence of the Walker incident was admissible	State contends evidence shows motive/intent/plan and is admissible	Mangum argues it is insufficiently similar and unfairly prejudicial	Admissible for motive/intent/plan; no abuse of discretion
Whether the Walker 404(b) evidence was too remote in time	Proponent asserts fourteen-month gap is sufficiently proximate	Mangum argues remoteness undermines probative value	Not too remote; temporal proximity weighs as evidentiary weight for the jury
Whether the trial court properly balanced 404(b) evidence under Rule 403	Evidence is probative and limited by limiting instructions	Evidence is unfairly prejudicial and should have been excluded	No abuse of discretion; limiting instructions given; probative value not substantially outweighed by prejudice
Whether there was sufficient evidence of malice to support second-degree murder	State asserts stabbing with a five-inch knife shows malice	Mangum claims self-defense and inconsistent injuries	Yes; substantial evidence supports second-degree murder absent self-defense

State v. Beckelheimer, 366 N.C. 127 (2012) (review Rule 404(b) admissibility and evidentiary factors)
State v. Coffey, 326 N.C. 268 (1990) (text on Rule 404(b) admissibility with propensity limitations)
State v. Bagley, 321 N.C. 201 (1987) (definition of Rule 404(b) admissibility for purposes other than propensity)
State v. Love, 152 N.C.App. 608 (2002) (similarity and temporal proximity in Rule 404(b) analysis)
State v. Al-Bayyinah, 356 N.C. 150 (2002) (similarity and remoteness considerations in 404(b))
State v. Morgan, 315 N.C. 626 (1986) (trial court must determine admissibility of extrinsic conduct evidence under 404(b))
State v. Parker, 113 N.C.App. 216 (1994) (prior relationship-based motive evidence relevant to 404(b))
State v. Aldridge, 139 N.C.App. 706 (2000) (evidence of violent response to relationship deterioration; relevance to motive)
State v. Barfield, 298 N.C. 306 (1979) (concept of plan or design evidenced by prior acts (concurrence of features))