State v. Mumma, 372 N.C. 226

Defendant Willoughby Mumma stabbed his wife, Amy Chapman, to death; before the killing he sent texts saying he was "goin 2 kil her."
At trial the State introduced 179 photographs (41 depicting the body); all but one were admitted without objection and shown to the jury during trial.
During deliberations the jury requested “ALL PHOTOS PLEASE”; the trial court allowed the jury to take the admitted photographs into the jury room over Mumma's objection.
The jury initially reported an 11–1 deadlock; after an Allen charge it convicted Mumma of second-degree murder and he was sentenced to 180–225 months.
On appeal Mumma argued (1) allowing the jury to review the photos in the jury room without the parties’ consent was prejudicial error, and (2) the trial court committed plain error by instructing on the "aggressor" doctrine in relation to his self-defense claim.
The North Carolina Supreme Court affirmed the Court of Appeals: it held the jury-room error (statutory consent violation) was not prejudicial under the reasonable-possibility standard and the aggressor instruction did not amount to plain error.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Mumma)	Held
Whether sending admitted exhibits (photographs) to the jury room without consent prejudiced defendant	Any error was harmless given overwhelming evidence of guilt (texts, severe victim injuries, minor defendant injuries); photos were relevant and non-inflammatory	Jury access to graphic photos in private likely inflamed jurors and was qualitatively different from courtroom inspection; statutory consent required	Court: Sending photos to jury room without consent was error but not prejudicial under N.C.G.S. §15A-1443(a); affirm conviction
Whether inclusion of "aggressor" doctrine in self-defense instruction was plain error	Record supported aggressor instruction (defendant had control of knife; texts indicating homicidal intent; pathology showing defensive and rear-inflicted wounds); even if error, not plain error	No evidence defendant was the aggressor; instructions impermissibly undermined self-defense; defendant preserved right to object to self-defense instruction	Court: Defendant forfeited ordinary review by failing to object; on plain-error review, any error did not have a probable impact on verdict and so did not warrant relief

Allen v. United States, 164 U.S. 492 (holding permissive instruction to a deadlocked jury encouraging further deliberation)
State v. Cunningham, 344 N.C. 341 (court held sending exhibits to jury room without consent is error; harmless where overwhelming evidence)
State v. Cannon, 341 N.C. 79 (same: sending evidence to jury room without consent is error; defendant failed to show prejudice)
State v. Huffstetler, 312 N.C. 92 (addressing harmless-error analysis when exhibits taken to jury room)
State v. Lawrence, 365 N.C. 506 (plain-error standard requires showing probable impact on verdict)
State v. Juarez, 369 N.C. 351 (declining to reverse on aggressor-instruction claim where record supported rejection of self-defense)
State v. Odom, 307 N.C. 655 (plain-error framework explanation)