State v. Williams
208 N.C. App. 422
| N.C. Ct. App. | 2010Background
- Defendant Jarvis Williams was charged with possession with intent to sell or deliver cocaine and with being an habitual felon.
- An informant told CMPD that a black male named Jarvis was selling cocaine from the front porch at 429 Heflin Street, with the cocaine allegedly in a hanging flower pot.
- Police observed Williams on the porch and a hanging flower pot; a baggie protruding from the pot led to his detention and a search yielding $195 and a bag believed to contain crack cocaine.
- At the station, Williams admitted the cocaine was not his and that another individual named Chris placed it there to sell; he claimed he sold some today on Chris’s instruction.
- Chemistry testimony described the testing process (color tests and GC–Mass Spec) and summarized the procedure used by Johnson, who conducted the tests, with Charlesworth performing a peer review of Johnson’s results.
- The trial court admitted Charlesworth’s testimony over objection; the jury found Williams guilty of possession with intent and he pled guilty to habitual felon status, leading to a lengthy sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Charlesworth's testimony violated confrontation | State: peer review testimony is admissible under controlling precedent | Williams: Charlesworth’s testimony was mere summary of Johnson’s report, violating Confrontation Clause | Reversal; erroneous admission requiring new trial |
Key Cases Cited
- State v. Brewington, 693 S.E.2d 189 (N.C. App. 2010) (confrontation and cross-examination needed for peer-reviewed forensic testimony)
- State v. Mobley, 684 S.E.2d 508 (N.C. App. 2009) (no error where testifying expert provides independent analysis based on underlying data)
- State v. Hough, 690 S.E.2d 291 (N.C. App. 2010) (peer review can suffice to show expert-based testimony without lapse into Confrontation Clause error)
- State v. Brennan, 692 S.E.2d 427 (N.C. App. 2010) (distinguishes when non-testing expert’s testimony is error or harmless)
- State v. Nabors, 700 S.E.2d 153 (N.C. App. 2010) (lay opinion insufficient to prove controlled substances without chemical analysis)
- Melendez‑Diaz v. Massachusetts, 129 S. Ct. 2527 (U.S. 2009) (testimonial nature of laboratory reports under Confrontation Clause)