State v. StroessenreutherÂ
250 N.C. App. 772
| N.C. Ct. App. | 2016Background
- Defendant Joshua Stroessenreuther pled guilty (Alford plea) to indecent liberties with a child and a sex offense with a child; sentenced to 300–420 months and lifetime sex-offender registration.
- At sentencing the State sought lifetime satellite-based monitoring under N.C. Gen. Stat. § 14‑208.40A based on the convictions and recidivist status.
- Stroessenreuther invoked Grady v. North Carolina and argued the monitoring violated the Fourth Amendment, raising both facial and as‑applied constitutional challenges.
- The trial court imposed lifetime satellite monitoring without conducting any Fourth Amendment reasonableness inquiry, concluding the statute required imposition.
- On appeal the Court of Appeals rejected the facial challenge but agreed the as‑applied challenge merited relief because the trial court failed to assess reasonableness under Grady; the monitoring order was vacated and remanded for a Grady‑compliant hearing.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Stroessenreuther) | Held |
|---|---|---|---|
| Whether the satellite‑based monitoring statute is facially unconstitutional for failing to provide a procedure to assess Fourth Amendment reasonableness | The statute mandates monitoring for qualifying offenders; no separate reasonableness hearing is required | The statute is facially invalid because it does not permit courts to consider Fourth Amendment reasonableness after Grady | Facial challenge rejected: statute’s silence does not bar courts from considering Fourth Amendment claims, so it is not facially invalid |
| Whether imposition of lifetime satellite monitoring on Stroessenreuther without a Fourth Amendment reasonableness inquiry was unconstitutional as applied | Imposition was required by statute; no additional reasonableness inquiry necessary | Imposition violated his Fourth Amendment rights because the court failed to evaluate reasonableness after he raised a Grady challenge | As‑applied relief granted: court vacated monitoring and remanded for the required Grady‑style reasonableness hearing |
Key Cases Cited
- Grady v. North Carolina, 135 S. Ct. 1368 (2015) (satellite‑based monitoring implicates the Fourth Amendment)
- State v. Blue, 783 S.E.2d 524 (N.C. Ct. App. 2016) (explains procedures trial courts must use under Grady)
- State v. Morris, 783 S.E.2d 528 (N.C. Ct. App. 2016) (same; remand for Fourth Amendment reasonableness inquiry)
- State v. Collins, 783 S.E.2d 9 (N.C. Ct. App. 2016) (vacated and remanded for Grady‑based analysis)