State v. Lane, 365 N.C. 7

Summary

The Supreme Court of North Carolina reviewed Eric Glenn Lane’s convictions and death sentence for the murder of a five-year-old child and related sexual and kidnapping offenses. The opinion addresses, among other issues, Lane’s competency to waive counsel and represent himself under Faretta, Godinez, and Indiana v. Edwards, as well as the sufficiency of the proceedings supporting his convictions and sentence.

Holdings

1. The trial court properly allowed defendant to discharge appointed counsel and proceed pro se because, after finding him competent to stand trial, it adequately determined that he knowingly and voluntarily waived his right to counsel and understood the charges, proceedings, punishments, and consequences of self-representation.
2. The trial court properly excluded Dr. Wilson's proposed testimony during the guilt-innocence phase because he could not offer an opinion about defendant's mental condition at the time of the confession, the truth or falsity of the confession, or any connection between alcohol withdrawal and its reliability.
3. The trial court did not abuse its discretion by excluding Dr. Wilson's testimony as a discovery sanction because the defense failed to provide a complete expert report despite repeated orders and warnings, and the court properly considered the materiality of the testimony and totality of the circumstances.
4. The trial court properly declined to submit the statutory mitigating circumstance under N.C.G.S. section 15A-2000(f)(1) because the evidence of defendant's prior violent criminal activity supported the threshold determination that no rational jury could find his criminal history insignificant.
5. The court declined to revisit its prior holdings rejecting challenges to the unanimity instruction, the instruction that the jury had a duty to impose death after answering the relevant weighing issue affirmatively, and the definition of mitigating circumstances. The death sentence was supported by the aggravating circumstances and was neither excessive nor disproportionate.

Questions Presented

1. Whether the trial court properly permitted defendant to waive appointed counsel and proceed pro se after determining that his waiver was knowing and voluntary.
2. Whether the trial court properly excluded proposed expert testimony concerning defendant's alcohol use and possible withdrawal because the testimony was not relevant or helpful to the jury.
3. Whether the exclusion of the defense expert was an appropriate discovery sanction under North Carolina General Statutes section 15A-910.
4. Whether the trial court erred by failing to submit the statutory mitigating circumstance that defendant had no significant history of prior criminal activity.
5. Whether the court should reconsider prior holdings concerning unanimity on the death-penalty weighing issue, the alleged duty to impose death, and the definition of mitigating circumstances.
6. Whether the death sentence was supported by the aggravating circumstances and was excessive or disproportionate.

Disposition

affirmed