State v. WilliamsÂ
2017 N.C. App. LEXIS 132
N.C. Ct. App.2017Background
- Defendant Teon Jamell Williams entered an Alford plea to PWIMSD and habitual felon status; reserved appeal of suppression denial.
- In 2013 probation search found a bag containing methylone and 4-Methylethcathinone, both Schedule I substances.
- Defendant was indicted for PWIMSD Methylethcathinone (omitting the 4) and PWIMSD Methylone; first suppression motion denied; convicted on both, with consecutive sentences.
- On direct appeal, methylone conviction affirmed; methylethcathinone conviction vacated due to defective indictment named.
- In 2015 an indictment for PWIMSD 4-Methylethcathinone was issued; second suppression motion denied on collateral estoppel grounds; Defendant was convicted for PWIMSD 4-Methylethcathinone and appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether sentencing on two Schedule I substances was proper | Williams argues the same mixture should yield a single offense | Williams suggests a single Schedule I substance should be charged | Two separate offenses valid; each listed substance supports a conviction. |
| Whether denial of the second suppression motion was proper under collateral estoppel | State relied on same issues from first suppression | Collateral estoppel should bar relitigation of suppression issues | Collateral estoppel properly applied; denial of second motion affirmed. |
Key Cases Cited
- State v. Hall, 203 N.C. App. 712 (2010) (two separate offenses may be charged for multiple substances in same material; lack of quantity does not merge offenses)
- King v. Grindstaff, 284 N.C. 348 (1973) (definition and application of collateral estoppel in criminal matters)
- Sealfon v. United States, 332 U.S. 575 (1948) (collateral estoppel applicable to criminal actions)
- Dial v. State, 122 N.C. App. 298 (1996) (proper application of collateral estoppel factors)
- State v. Williams, State v. Williams, N.C. App. , _, 774 S.E.2d 880 (2015) (vacated conviction due to improper indictment naming)
