State v. English case brief

State v. English case brief summary
159 S.E. 318 (N.C. 1931)

CASE SYNOPSIS

Defendant sought review of a judgment from the trial court (North Carolina), which entered a jury's verdict convicting defendant of murder in the second degree, and sentenced him to a term of imprisonment of not less than 20 years and not more than 30 years.

CASE FACTS
Defendant's wife was bludgeoned to death with a fire poker while in their home. Another person confessed to the crime and described defendant's home, the murder, and the general area with accuracy. That person was discharged from custody and was not seen again. Defendant was later charged with murdering his wife. A witness testified that defendant tried to hire him to kill defendant's wife and later confessed to him that he had killed her himself. Defendant was found guilty of murder in the second degree.

ISSUE
Defendant appealed his conviction, contending that the trial court erred in refusing to admit into evidence the confession of the person who admitted to killing defendant's wife.

DISCUSSION

• The court disagreed, holding that the trial court properly followed the majority rule, which was in effect in North Carolina. 
• The majority rule excluded from evidence any confession made by a third party. 
• Such a confession was excluded because it constituted hearsay evidence. 
• As such, the trial court did not err in refusing to admit that person's confession.

CONCLUSION
The court affirmed the trial court's judgment, which convicted defendant of murder in the second degree and sentenced him to a term of imprisonment of not less than 20 years and not more than 30 years.

Suggested law school study materials

Shop Amazon for the best prices on Law School Course Materials.