State v. King
468 S.E.2d 232, 1996 N.C. LEXIS 153, 343 N.C. 29 (1996)
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Rule of Law:
Evidence of a defendant's flight is admissible to show consciousness of guilt, even if it occurs months after the crime, involves the commission of other offenses, and the defendant is unaware that formal charges have been filed.
Facts:
- Ernest A. King operated a drug-selling organization, and Meredith Mark Peaks was known in the area for robbing drug dealers.
- A few days before the killing, Peaks robbed one of King's lieutenants, prompting King to state that 'nobody was going to take nothing' from him.
- On February 20, 1992, upon seeing Peaks in a housing project, King said, 'I’m going to make him a ghost.'
- King and an armed associate, 'Face,' approached Peaks as he was trying to open the door of a blue car.
- King and 'Face' shot at Peaks multiple times, killing him, and also fired shots into the blue car.
- Earl Green was later discovered inside the blue car, alive but with several serious gunshot wounds.
- That same night, King fled Durham, drove to New York, and disposed of the 9-millimeter handgun he used in the shooting.
Procedural Posture:
- Ernest A. King was tried in a North Carolina trial court for the first-degree murder of Meredith Mark Peaks and assault with a deadly weapon with intent to kill inflicting serious injury upon Earl Green.
- A jury found King guilty of first-degree murder and guilty of assault with a deadly weapon inflicting serious injury.
- The trial court sentenced King to life imprisonment for the murder and a consecutive ten-year sentence for the assault.
- King (appellant) appealed his convictions to the Supreme Court of North Carolina, asserting seven assignments of error against the State (appellee).
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Issue:
Does evidence of a defendant's high-speed car chase from police, occurring four months after the alleged crime and before the defendant was formally charged, constitute admissible evidence of flight to show consciousness of guilt?
Opinions:
Majority - Lake, Justice.
Yes, such evidence is admissible as evidence of flight. The court held that a defendant's flight following the commission of a crime may be considered by a jury as evidence of consciousness of guilt. The court rejected the defendant's arguments that the four-month time lapse between the crime and the car chase rendered the evidence irrelevant, citing State v. McDougald for the principle that a significant delay does not destroy the evidence's probative value. Furthermore, the court declined to require that a defendant be aware of formal charges for flight evidence to be admissible, stating the key factor is a 'guilty conscience' which influences conduct, not knowledge of the legal process. The court also held that even if the defendant had other reasons for fleeing, such as other recent crimes, this does not render the flight instruction improper, so long as there is some evidence supporting the theory that he fled from the crime charged. Finally, citing State v. Jones, the court affirmed that evidence of flight is admissible even if it discloses the commission of a separate crime, such as a reckless high-speed chase.
Analysis:
This decision reinforces a broad interpretation of what constitutes admissible evidence of flight in North Carolina. It clarifies that factors that might weaken the inference of guilt, such as a significant time lapse or the existence of alternative reasons for flight, do not make the evidence inadmissible but are instead matters for the jury to weigh. By detaching the admissibility of flight evidence from the defendant's knowledge of formal charges, the court centers the inquiry on the defendant's subjective 'consciousness of guilt.' This precedent strengthens the prosecution's ability to introduce a defendant's subsequent bad acts as circumstantial evidence of guilt for a prior, charged offense.
