State v. PetersÂ, 255 N.C. App. 382

At Wal‑Mart, loss prevention observed a scheme where one woman returned two blenders for a refund and gave the receipt to Peters, who then used it to take identical vacuums and toys through the garden center exit without paying.
Peters was stopped outside the garden center by loss prevention and held for police; Officer Parker Phillips asked for Peters’ ID.
Peters produced a North Carolina ID with an altered license number; she affirmed the number when asked even though it was incorrect or missing digits.
Dispatch searches by the provided license number returned a different name; a subsequent search by name and DOB identified Peters and outstanding warrants, delaying the investigation.
Peters was indicted for attempted obtaining by false pretense, possessing an altered license, and resisting/delaying/obstructing a public officer (G.S. § 14‑223); convicted by a jury and sentenced as an habitual felon. On appeal she challenged sufficiency of evidence for the § 14‑223 conviction (delay and intent).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Peters)	Held
Whether evidence was sufficient to prove Peters delayed a public officer (element 4 of G.S. § 14‑223)	The altered ID and Peters’ affirmation caused Officer Phillips to spend extra time identifying her, so her conduct delayed the officer	Officer Phillips could have used other search methods (e.g., name/DOB) so his delay was not caused by Peters’ conduct	Held: Sufficient. Producing and affirming an altered ID caused the delay and supports submission to the jury
Whether evidence proved Peters acted willfully/with intent to delay (element 5 of G.S. § 14‑223)	Circumstantial evidence (altered ID, knowledge from training that suspects scratch numbers) permits an inference Peters intentionally provided false info to impede ID checks	Peters lacked requisite willful intent; any delay was inadvertent or due to officer procedure	Held: Sufficient. Jury could reasonably infer willfulness from circumstances (altered ID + affirmation)

State v. Fritsch, 351 N.C. 373 (standard for motion to dismiss and circumstantial‑evidence inferences)
State v. Rose, 339 N.C. 172 (view evidence in light most favorable to State)
State v. Washington, 193 N.C. App. 670 (elements of resisting/delaying/obstructing charge under G.S. § 14‑223)
State v. Friend, 237 N.C. App. 490 (statute covers failure to provide identity but recognizes possible excuses)
State v. Arnold, 264 N.C. 348 (definition of willfulness in criminal statutes)
State v. Crockett, 238 N.C. App. 96 (willfulness often inferred from surrounding circumstances)
State v. Brackett, 306 N.C. 138 (intent as essential element must be proved)