State v. Saddler, COA22-989, ___ N.C. App. ___ (Jun. 18, 2024)

In this Scotland County case, defendant appealed his conviction for second-degree murder, arguing error in admitting several jailhouse phone calls, and appealed the denial of his motion for appropriate relief (MAR) based on prosecutorial misconduct in withholding exculpatory evidence. The Court of Appeals found no error with the conviction and denied defendant's MAR. 

In October of 2017, a victim at a party in Laurinburg was shot from a car parked on the street. Eyewitness testimony put defendant in the car, and defendant was subsequently convicted of second-degree murder. After his conviction but prior to the current appeal, defendant filed an MAR arguing the prosecutor withheld evidence that a law enforcement officer who testified at defendant’s trial was under investigation for embezzlement at the time of the trial. The Court of Appeals remanded the case to the trial court for a hearing on the MAR, and the trial court conducted a hearing and made findings on the MAR. Both matters form the basis of the current case.  

Considering defendant’s arguments regarding the jailhouse calls, the Court of Appeals explained that under Rule of Evidence 401, the calls were relevant because they showed defendant discussing the circumstances around the shooting and a possible motivation for defendant to kill the victim. The court also pointed out that “[defendant’s] silence when told by the female caller that others in the neighborhood were saying that he fired the fatal shot is some evidence of guilt.” Slip Op. at 4-5. Applying Rule of Evidence 403, the court did not see the calls as unfairly prejudicial, especially in light of the limiting instruction given by the trial court regarding hearsay statements in the calls. The court also dispensed with defendant’s constitutional arguments as his “silence was not in response to questions by State actors” and the jury was free to make reasonable inferences from defendant’s statements and silence. Id. at 7. 

Moving to the MAR, the court explained that while a former district attorney in the office was aware of the investigation into the officer, those working on defendant’s case were not aware until after the trial. Although the court acknowledged U.S. Supreme Court precedent that knowledge from the former district attorney was likely imputed to those working the case, the court did not find any prejudicial effect from the failure to disclose the investigation. To support this conclusion the court pointed out the abundance of evidence supporting defendant’s guilt outside of the officer’s testimony, such as the jailhouse calls and eyewitness testimony. This led the court to deny defendant's MAR.