Plain error—standard—The holding in State v. Lawrence, 365 N.C. 506 (2012), reaffirmed the legal principle that plain error does not exist where a defendant cannot show that the jury probably would have returned a different verdict absent the error. Lawrence did not hold that plain error is shown unless the evidence against defendant is overwhelming and uncontroverted. State v. Maddux, 371 N.C. 558 (2018) (Author: Justice Robin Hudson)

Continuance—development of inadmissible evidence—The trial court properly denied a motion for a continuance where the motion was for the purpose of further developing evidence that would have been inadmissible at trial. State v. Bass, 371 N.C. 535 (2018) (Author: Justice Cheri Beasley)

Instructions—aiding and abetting—individual guilt—To the extent that the Court of Appeals applied the correct standard for plain error review to a prosecution arising from the discovery of materials used for manufacturing methamphetamine in and around defendant's house, it incorrectly concluded that an erroneous aiding and abetting instruction did not amount to plain error. Given the evidence of defendant's individual guilt (including viewing the items found in context and not in isolation), the erroneous aiding and abetting instruction did not have a probable impact on the jury's finding. State v. Maddux, 371 N.C. 558 (2018) (Author: Justice Robin Hudson)

Instructions—self-defense—stand your ground—The trial court erred by omitting the relevant stand-your-ground language from the jury instructions delivered at a trial in which defendant was convicted of assault with a deadly weapon with intent to kill inflicting serious injury. The trial court concluded that the "no duty to retreat" instruction did not apply because defendant was not in his home or place of residence, workplace, or car. An individual who is lawfully located may stand his ground and defend himself from attack when he reasonably believes such force is necessary to prevent imminent death or great bodily harm to himself or another. A defendant entitled to any self-defense instruction is entitled to a complete self-defense instruction, which includes the stand-your-ground provision. State v. Bass, 371 N.C. 535 (2018) (Author: Justice Cheri Beasley)

Plea agreement—sentencing worksheet—stipulation to classification of prior second-degree murder—Where defendant, as part of a plea agreement, stipulated to a sentencing worksheet showing his prior offenses, including a second-degree murder conviction designated as a B1 offense, the Court of Appeals erred by holding that the stipulation to this type of second-degree murder was an improper legal stipulation. Defendant could properly stipulate to the facts surrounding his offense either by recounting the facts at the hearing or by stipulating to a general second-degree murder conviction that has a B1 classification. Defendant's stipulation was an acknowledgement that that the factual basis of his conviction involved general second-degree murder-a B1 offense-not covered by the B2 exceptions. State v. Arrington, 371 N.C. 518 (2018) (Author: Chief Justice Paul Newby)

Victim's character—violent conduct—specific instances—The trial court did not err in an assault prosecution by excluding specific instances of the victim's violent conduct offered to prove that he was the first aggressor on the night he was shot. Character is not an essential element of self-defense; to show that he acted in self-defense, a defendant must show that his victim was the aggressor but need not prove that the victim was a violent or aggressive person. N.C. Rule of Evidence 405 limits the use of specific instances of past misconduct to cases in which character is an essential element of the charge, claim, or defense. State v. Bass, 371 N.C. 535 (2018) (Author: Justice Cheri Beasley)

Governmental—downtown redevelopment—art center—governmental function—The trial court correctly determined that defendant city was engaged in a governmental function and granted summary judgment for defendant on the basis of governmental immunity in a negligence case arising from a slip and fall at an art center used as a part of a downtown redevelopment. While the legislature has not deemed that all urban redevelopment and downtown revitalization projects are governmental functions that are immune from suit, defendant's activity here in leasing the property to an arts guild to promote the arts for the purpose of redeveloping and revitalizing the downtown area was a governmental function. Meinck v. City of Gastonia, 371 N.C. 497 (2018) (Author: Justice Robin Hudson)

Governmental—downtown redevelopment—art center—negligence claim—The trial court correctly granted summary judgment for defendant city on the basis of governmental immunity in a negligence case arising from a slip and fall at an art center used as a part of a downtown redevelopment. An urban redevelopment project undertaken in accordance with statutes and for the purpose of promoting the health, safety, and welfare of the inhabitants of the State of North Carolina is a governmental function. Meinck v. City of Gastonia, 371 N.C. 497 (2018) (Author: Justice Robin Hudson)

Citation for misdemeanor—sufficient to invoke trial court's subject matter jurisdiction—Defendant's citation for operating a motor vehicle when having an open container of alcohol in the passenger compartment while alcohol remained in his system was sufficient to charge him with the misdemeanor offense and to invoke the trial court's subject matter jurisdiction. The citation included sufficient criminal pleading contents (which are designed to be more relaxed than those of other criminal charging instruments), and defendant chose not to invoke his right through an appropriate motion to have the State charge him in a new pleading while the matter was still pending in its court of original jurisdiction. State v. Jones, 371 N.C. 548 (2018) (Author: Justice Michael Morgan)

Discipline—unreasonably delayed ruling—A district court judge was suspended without pay for thirty days where he delayed issuing a ruling in a domestic matter for years, never made a ruling, and the file on the case went missing. In re Chapman, 371 N.C. 486 (2018) (Author: Justice Per Curiam)