History
  • No items yet
midpage
State v. WilliamsÂ
2017 N.C. App. LEXIS 132
N.C. Ct. App.
2017
Read the full case

Background

  • 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)
Read the full case

Case Details

Case Name: State v. WilliamsÂ
Court Name: Court of Appeals of North Carolina
Date Published: Mar 7, 2017
Citation: 2017 N.C. App. LEXIS 132
Docket Number: COA16-592
Court Abbreviation: N.C. Ct. App.