State v. Oates, 366 N.C. 264

State sought to appeal suppression ruling after oral in-court decision.
Written order suppressing issued later (nunc pro tunc) and filed a few months after oral ruling.
Written notice of appeal filed 22 December 2009, before written order was entered.
Trial court’s written order entered 22 March 2010; no subsequent new notice filed.
Court of Appeals sua sponte dismissed for lack of timely notice under Rule 4(a).
North Carolina Supreme Court overruled misinterpretation of Rule 4 and held two modes of appeal exist; timing runs from rendition to 14 days after entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 4(a)(2) window governs written appeals from criminal orders.	State contends window runs from rendition to 14 days after entry.	Oates held two separate windows create untimely notice if not within either.	Rule 4 allows written notice within 13-day window; but the State’s notice was timely within the correct window.
Whether the suppression order’s rendition and entry dates establish timely notice.	State argues order rendered 15 December 2009; notice timely under Rule 4.	Court of Appeals misread entry timing as dispositive.	Notice filed 22 December 2009 within the permissible window (15 Dec 2009 to 5 Apr 2010).

State v. Boone, 310 N.C. 284, 311 S.E.2d 552 (1984) (entry of judgment aligned with civil procedure rules; companion to Rule 4 interpretation)
Dogwood Dev. & Mgmt. Co. v. White Oak Transp. Co., 362 N.C. 191, 657 S.E.2d 361 (2008) (jurisdictional nature of notice requirements)
Horner v. Horner, 310 N.C. 274, 311 S.E.2d 281 (1984) (statutory finding requirements not strictly in writing)
Seip v. Wright, 173 N.C. 55, 91 S.E. 359 (1917) (definition of judgment and its entry)
Kirby Bldg. Sys., Inc. v. McNiel, 327 N.C. 234, 393 S.E.2d 827 (1990) (definition of judgment; ministerial act of recording judgment)
Stachlowski v. Stach, 328 N.C. 276, 401 S.E.2d 638 (1991) (entry of order defined; Rule 4 applicability)