Sunday, November 17, 2013

State v. Hall case brief

State v. Hall case brief summary
19 S.E. 602 (1894)

Defendants sought review of the judgment of the trial court (North Carolina) entered on a jury verdict convicting them of murder. Defendants argued that the trial court erred in denying their jury instruction to the effect that if the decedent died of wounds received while in Tennessee, the jury was required to find defendants not guilty of his murder, irrespective of whether they were the cause of the injury.

Defendants were charged with killing the decedent; however, the evidence suggested that although the shots were fired while defendants were located in North Carolina, decedent was in Tennessee when hit by the shots and died there. Defendants sought jury instructions to the effect that if the prosecution failed to prove that the decedent was killed in North Carolina, they were entitled to acquittal. The trial court refused such instructions and defendants were convicted.

  • On appeal, the court reversed and granted a new trial, holding that: 
  • 1) the assault on decedent clearly occurred in Tennessee; and 
  • 2) North Carolina had no statute conferring jurisdiction or concurrent jurisdiction in its courts over defendants in such circumstance, or making defendants' acts murder prosecutable in North Carolina; 
  • 3) the fact that all parties were residents of North Carolina was irrelevant to the issue of where defendants were properly prosecuted.

The court reversed the judgment of the trial court on the jury verdict finding defendants guilty of murder, and ordered a new trial.

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