State v. Sasek, 844 S.E.2d 328

Defendant Scott Sasek was on supervised probation (suspended sentence) when a confidential informant allegedly bought methamphetamine from him in a department-store parking lot on Feb. 15, 2017.
The informant returned a clear baggie with crystalline material to officers; Defendant was later indicted on possession/sale-related charges and probation-violation reports were filed.
At trial the State’s drug chemist, Deborah Chancey, testified as an expert and described GCMS testing generally; she did not fully explain how she applied GCMS to this sample on the stand, but her lab report and her opinion that the sample was methamphetamine were admitted without objection.
A jury convicted Sasek of possession with intent to sell/deliver (Schedule II) and sale of methamphetamine; he pleaded habitual felon and the court activated his suspended sentence for a probation violation.
The probation revocation occurred in March 2019, fourteen months after the probation expired (Jan. 2018); the trial court made no express finding of “good cause” for revoking after expiration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of expert drug-test opinion under Rule 702 (gatekeeping/reliability)	State: Chancey was qualified, performed GCMS, produced a lab report, and her opinion identifying methamphetamine was admissible; no trial objection.	Sasek: Chancey never explained how she applied GCMS to this sample (Rule 702(a)(3)); insufficient foundation so opinion should be excluded.	Court: Trial court erred in admitting the expert opinion without requiring application details, but the error did not constitute plain error—no reversible error in convictions.
Revocation of probation after probationary period expired (good-cause finding; delay)	State: (conceded error as to required finding)	Sasek: Revocation after expiration required a finding of good cause; record lacks evidence of reasonable efforts—vacate without remand.	Court: Trial court erred by not finding good cause; because the record contains no evidence of reasonable efforts to hold an earlier hearing, the court vacated the probation-revocation judgments without remand.

State v. Hunt, 250 N.C. App. 238, 792 S.E.2d 552 (2016) (unpreserved challenge to expert gatekeeping reviewed for plain error)
State v. Lawrence, 365 N.C. 506, 723 S.E.2d 326 (2012) (plain-error standard articulated)
State v. Ward, 364 N.C. 133, 694 S.E.2d 738 (2010) (identity of controlled substance ordinarily requires scientifically valid chemical analysis)
State v. McPhaul, 256 N.C. App. 303, 808 S.E.2d 294 (2017) (expert must explain application of methodology to facts; mere conclusion without application is abuse of discretion)
State v. Piland, 822 S.E.2d 876 (2018) (admission error where methodology not shown but testimony not baseless; no plain error)
State v. Morgan, 372 N.C. 609, 831 S.E.2d 254 (2019) (trial court must find good cause to revoke probation after expiration; remand only when record contains evidence supporting reasonable-efforts finding)
State v. Bryant, 361 N.C. 100, 637 S.E.2d 532 (2006) (remand for omitted factual findings unless record precludes such findings)
State v. Camp, 299 N.C. 524, 263 S.E.2d 592 (1980) (vacating revocation where record showed no reasonable efforts to hold earlier hearing)
State v. Osborne, 372 N.C. 619, 831 S.E.2d 328 (2019) (absence of admissible chemical analysis does not always require acquittal when other evidence supports conviction)