Smith's Criminal Case Compendium
Table of Contents
State v. Crump, ___ N.C. App. ___, 815 S.E.2d 415 (Apr. 17, 2018)
In a case involving charges of assault on a law enforcement officer, the trial court did not err by allowing the State to present evidence that an internal police department investigation of the involved officers resulted in no disciplinary actions or demotions. The defendant asserted that this evidence constituted inadmissible hearsay. During a pretrial hearing on the defendant’s motion in limine to exclude this evidence, the defendant noted his intent to open the door during cross-examination and question the officers about their knowledge of the inner workings of such investigations and whether they had conferred with an attorney prior to making their official statements. The trial court noted that this proposed line of questioning would open the door to the State’s introduction of the results of the investigation. However, the defendant maintained his intent to proceed with his line of questioning, and the trial court denied the motion in limine. When the defendant cross-examined the officers about these matters at trial, he opened the door to the evidence at issue.