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No. COA09-1096 ELEVEN-B DISTRICT NORTH CAROLINA COURT OF APPEALS **************************************************** STATE OF NORTH CAROLINA) ) v. ) From Johnston ) DENNIS SHAW ) **************************************************** DEFENDANT-APPELLANT’S BRIEF ****************************************************

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Page 1: Bank/Briefs/Shaw, Dennis.doc  · Web viewOne of the two had sulfuric acid and both were burned during the ensuing physical struggle. Also during the struggle, Mr. Shaw hit Ronda’s

No. COA09-1096 ELEVEN-B DISTRICT

NORTH CAROLINA COURT OF APPEALS

****************************************************

STATE OF NORTH CAROLINA ))

v. ) From Johnston)

DENNIS SHAW )

****************************************************

DEFENDANT-APPELLANT’S BRIEF

****************************************************

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INDEX

TABLE OF AUTHORITIES...................................................................................III

QUESTIONS PRESENTED.....................................................................................1

STATEMENT OF THE CASE.................................................................................2

STATEMENT OF GROUNDS FOR APPELLATE REVIEW................................2

STATEMENT OF THE FACTS...............................................................................2

A. Summary................................................................2

B. Mr. Shaw Pleads Guilty to Second-Degree Murder and Stipulates to an Aggravating Factor................3

C. The Sentencing Hearing.........................................8

ARGUMENT...........................................................................................................22

I. THE TRIAL COURT ERRED WHEN IT TOOK INTO ACCOUNT DURING SENTENCING AN AGGRAVATING FACTOR WHICH WAS NEITHER STIPULATED TO NOR FOUND BY A JURY BEYOND A REASONABLE DOUBT, AND WHICH WAS NOT ALLEGED IN A CHARGING DOCUMENT............................................................................22

CONCLUSION.......................................................................................................34

CERTIFICATION OF COMPLIANCE WITH RULE 28(J)(2)(A)(2)...................36

CERTIFICATE OF FILING AND SERVICE........................................................36

ii

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TABLE OF AUTHORITIES

CASES

Apprendi v. New Jersey, 530 U.S. 466, 147 L. Ed. 2d 435 (2000).......................................................25

Blakely v. Washington, 542 U.S. 296, 159 L. Ed. 2d 403 (2004).......................................................25

N.C. Department of Environment & Natural Resources v. Carroll, 358 N.C. 649, 599 S.E.2d 888 (2004)...........................................................23

State v. Ahearn, 307 N.C. 584, 300 S.E.2d 689 (1983)...........................................................32

State v. Ashe, 314 N.C. 28, 331 S.E.2d 652 (1985).......................................................23, 34

State v. Barden, 356 N.C. 316, 572 S.E.2d 108 (2002)...........................................................28

State v. Beck, 163 N.C. App. 469, 594 S.E.2d 94 (2004), rev’d in part on other grounds, 359 N.C. 611, 614 S.E.2d 274 (2005)..................................30

State v. Blackwell, 361 N.C. 41, 638 S.E.2d 452 (2006).............................................................28

State v. Boone, 293 N.C. 702, 239 S.E.2d 459 (1977)...........................................................25

State v. Byrd, 164 N.C. App. 522, 596 S.E.2d 860 (2004)..................................................27

State v. Canady, 330 N.C. 398, 410 S.E.2d 875 (1991)...........................................................34

State v. Curmon, 171 N.C. App. 697, 615 S.E.2d 417 (2005)..................................................33

State v. Everette, 361 N.C. 646, 652 S.E.2d 241 (2007)...........................................................31

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State v. Hueto, ___ N.C. App. ___, 671 S.E.2d 62 (2009)..............................................26, 27

State v. Hurt, 361 N.C. 325, 643 S.E.2d 915 (2007).....................................................26, 33

State v. McBane, 276 N.C. 60, 170 S.E.2d 913 (1969).............................................................31

State v. Melton, 307 N.C. 370, 298 S.E.2d 673 (1983)...........................................................27

State v. Prevatte, 356 N.C. 178, 570 S.E.2d 440 (2002)...........................................................22

State v. Rollins, 131 N.C. App. 601, 508 S.E.2d 554 (1998)..................................................33

State v. Westbrooks, 345 N.C. 43, 478 S.E.2d 483 (1996).............................................................30

State v. Whitehead, 174 N.C. App. 165, 620 S.E.2d 272 (2005)..................................................33

State v. Williams, 144 N.C. App. 526, 548 S.E.2d 802 (2001)..................................................30

State v. Wilson, 338 N.C. 244, 449 S.E.2d 391 (1994)...........................................................32

Washington v. Recuenco, 548 U.S. 212, 165 L. Ed. 2d 466 (2006).......................................................28

STATUTES

G.S. §15A-1340.16..................................................................................................23

G.S. §15A-1340.16(a).............................................................................................26

G.S. §15A-1340.16(a1)...........................................................................................26

G.S. §15A-1340.16(a3).....................................................................................26, 34

G.S. §15A-1340.16(a4).....................................................................................26, 34

G.S. §15A-1443(a)............................................................................................28, 30

iv

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G.S. §7A-27(b)..........................................................................................................2

OTHER AUTHORITI ES

N.C. R. App. P. 10(b)(1).........................................................................................33

CONSTITUTIONAL PROVISIONS

N.C. Const. art. I, § 19.............................................................................................23

N.C. Const. art. I, § 22.............................................................................................23

N.C. Const. art. I, § 23.............................................................................................23

N.C. Const. art. I, § 24.............................................................................................23

U.S. Const. amend. VI.............................................................................................23

U.S. Const. amend. XIV..........................................................................................23

v

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No. COA09-1096 ELEVEN-B DISTRICT

NORTH CAROLINA COURT OF APPEALS

****************************************************

STATE OF NORTH CAROLINA ))

v. ) From Johnston)

DENNIS SHAW )

****************************************************

DEFENDANT-APPELLANT’S BRIEF

****************************************************

QUESTIONS PRESENTED

I. WHETHER THE TRIAL COURT ERRED WHEN IT TOOK INTO ACCOUNT DURING SENTENCING AN AGGRAVATING FACTOR WHICH WAS NEITHER STIPULATED TO NOR FOUND BY A JURY BEYOND A REASONABLE DOUBT, AND WHICH WAS NOT ALLEGED IN A CHARGING DOCUMENT?

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STATEMENT OF THE CASE

On June 6, 2006, the Johnston County Grand Jury indicted Defendant-

appellant Dennis Shaw for first-degree murder. (Rp. 4) Defendant entered an

Alford plea to second-degree murder at the February 2, 2009 Criminal Session of

Johnston County Superior Court before Judge Henry W. Hight, Jr. (Rpp. 1, 9-12)

On February 3, 2009, Judge Hight entered Judgment and Commitment, and

sentenced Defendant to 196 to 245 months imprisonment. (Rpp. 15-18) Defendant

appealed. (Rpp. 19-20)

STATEMENT OF GROUNDS FOR APPELLATE REVIEW

Defendant appeals pursuant to G.S. §7A-27(b) from a final judgment of

Johnston County Superior Court.

STATEMENT OF THE FACTS

A. Summary.

Dennis Shaw [“Mr. Shaw”] and his former girlfriend, Ronda Barnes

[“Ronda”], had a child together, Myka Shaw [“Myka”]. Mr. Shaw had custody of

Myka during the school year. She lived with him in Washington, D.C., while Ronda

lived in Clayton, North Carolina. Mr. Shaw also sometimes cared for Ronda’s other

two children, Marcus and Trey, although they were not his children. The three

children were the focus of Mr. Shaw’s life and he worked hard to provide for them

and raise them properly, especially Myka. Mr. Shaw and Ronda often disagreed

about the children’s care.

2

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On April 18, 2006, Mr. Shaw and Ronda got into a physical altercation at

Ronda’s home in Clayton. One of the two had sulfuric acid and both were burned

during the ensuing physical struggle. Also during the struggle, Mr. Shaw hit

Ronda’s head multiple times with his knee, causing her death.

Mr. Shaw entered an Alford plea to second-degree murder and stipulated to a

nonstatutory aggravating factor, that Ronda suffered greatly prior to her death. In

sentencing Mr. Shaw, the trial court remarked that the State had given Mr. Shaw a

“concession” in allowing him to plead to second-degree murder because the State

could have tried him for first-degree premeditated and deliberate murder. (IIpp.

242, 244)1 The trial court sentenced Mr. Shaw at the top of the aggravated range.

B. Mr. Shaw Pleads Guilty to Second-Degree Murder and Stipulates to an Aggravating Factor.

Mr. Shaw entered into a plea arrangement with the State in which he agreed

to enter an Alford plea to second-degree murder and stipulate to the nonstatutory

aggravating factor that the victim suffered greatly prior to her death. The trial court

was to determine his sentence after the parties presented evidence at a sentencing

hearing. (Rp. 11) With regard to the factual basis of the plea, the defense stated that

it was “prepared to let [the State] state what they contend the evidence would have

been had we went to trial in this case.” (Ip. 12)

1. The State’s Factual Basis.

The State recited the factual basis as follows:

1 For transcript references, the roman numeral refers to the volume of the transcript.

3

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Ronda left work early on Tuesday, April 18, 2006. Ronda worked at Talecris

Biotherapeutics in Clayton. (Ip. 14) At 3:48 p.m., she made a transaction at a

convenience store a quarter of a mile from her residence. (Ipp. 25-26)

Ronda was found dead in her home on April 19 by her mother. There was

evidence of “a very large struggle throughout the home”: furniture was overturned

and bloodstains were found in the living room and kitchen, where Ronda’s body lay.

Additionally, a black liquid substance, later found to be sulfuric acid, was in large

quantities on the living room floor and on and around the body. Ronda’s clothing

and body appeared to have been burned by the substance. The sulfuric acid “could

be purchased at most hardware and plumbing supply stores.” There were footprints

and a skid mark in the liquid on the living room floor showing that the liquid was

present during the struggle. A mark on top of an overturned table in the living room

indicated that the container holding the acid may have been on the table and spilled

when the table was overturned. A HASMAT team applied lime to the spilled

substance to soak it up. (Ipp. 12-15, 33)

One of Ronda’ neighbors, Patricia Brown, told police that between 4:00 and

5:00 p.m. on the previous day, she had heard screams and heavy thuds coming from

Ronda’s house. A few minutes later, she saw a black male athletically jump over a

six-foot tall fence into Ronda’s backyard and go to her back door. Brown stated that

the man looked at her, then ran back to the fence, jumped over, and ran into the

woods. A few minutes later, the man got into Ronda’s truck and drove quickly in

4

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the direction of a church where the truck was later found, located about 400 yards

from Ronda’s house. Brown said the man had a medium complexion, was about

5’5” tall, and was dressed all in white. He had on a blue baseball cap and white

gloves with blue palms. (Ipp. 16-17)

Ms. Brown’s boyfriend Reggie Barnes told police that after the man jumped

over the fence, he laid down as if to hide. Barnes stated that the man was wearing

white jogging pants and weighed about 160 to 170 pounds. (Ipp. 17-18)

Mr. Shaw lived in Washington, D.C. On April 21, police contacted him and

determined he was not at work on April 18. He told police he was home sick and

had stayed home the next day as well because Myka was sick. (Ip. 19)

On April 24, investigators went back to Ronda’s house. They saw a key on

the living room floor that they had not seen previously. The investigators believed

that the key had been covered with acid, but was revealed because the lime soaked

up the acid. The key fit the back door of the residence. It was unclear where the

key came from because all known keys to Ronda’s house were accounted for.

Investigators speculated that Myka had made or gotten a duplicate key when she had

stayed with her mother a few days before. (Ipp. 20-21)

Also on April 24, SBI Agent Tart interviewed Myka. She told Agent Tart

that her father had been at their home in Washington, D.C. when she got home from

school on April 18. When asked again, Myka became nervous, but still said Mr.

Shaw was at home. She also stated that she was not aware that her father was sick,

5

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except that he had burned himself in the shower with drain cleaner on the morning

of April 19. She had seen burns on his face, hands, and feet. (Ipp. 21-22)

On April 25, Agent Tart contacted Mr. Shaw and asked him about the burns.

Mr. Shaw said he had been burned by drain cleaner in the shower. Law

enforcement officers met Mr. Shaw at a relative’s home in Baltimore and confirmed

that he had burns over a large portion of his body. A doctor had treated Mr. Shaw

for the burns on his face, but was unaware that he had burns on the rest of his body.

(Ipp. 22-23)

April 25 was also the day of Ronda’s funeral. Myka was supposed to be

interviewed by law enforcement, but her grandmother called and said Myka was too

upset. Later, an attorney told law enforcement that Myka would give no further

interviews. (Ipp. 23-24)

Investigators showed a single photograph of Mr. Shaw to Patricia Brown.

She said it was the man she had seen jumping over the fence. She also stated that

she had seen a suspicious white Ford Escort in the area earlier in the year and it

appeared to be watching Ronda’s home. Investigators learned that Mr. Shaw owned

a white Ford Escort. (Ipp. 24-25)

On April 28, investigators searched Mr. Shaw’s residence pursuant to a

warrant. They seized white jogging pants with a black stain. The material

“appeared to be eaten through as if exposed to some type of acid.” A computer was

also seized. It showed that the day after Ronda’ death, Mr. Shaw had done a search

6

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for acid burns to the body. Mr. Shaw was arrested in May, 2006 for Ronda’s

murder. (Ipp. 25-27; Rp. 2)

The autopsy showed that Ronda had sustained blunt force trauma to the head,

which was the cause of death. There were lacerations to the upper and lower lips, a

fractured nose, extensive subscapular bruising, and a subarachnoid hemorrhage of

the brain. She had extensive chemical burns to the face, head, upper chest, and legs.

(Ipp. 26-27)

Investigators learned that during 2005 and 2006, someone had committed

various malicious acts of vandalism against Ronda, including flattening her tires,

putting an unknown substance in her gas tank, spray painting her car, and leaving

derogatory flyers at her workplace and church. In one instance, on February 28,

2005, someone broke into her house, painted graffiti on the walls, and set her

clothes on fire on her bed. Ronda “felt [Mr.] Shaw was responsible.” He was not

charged in connection with any of the crimes. (Ip. 18-19) A handwriting analyst

compared the handwriting in the February 28, 2005 graffiti with Mr. Shaw’s

handwriting and concluded that Mr. Shaw “probably” wrote the graffiti. (Ip. 32)

The most recent vandalism, spray painting of Ronda’s car and home, was on

April 11, 2006. The next weekend, Ronda left a message for a Clayton Police

officer that she was afraid Mr. Shaw was going to come down and do something

bad. (Ip. 18)

7

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Regarding the stipulated aggravating factor – that the victim suffered greatly

prior to her death – the State stated that “both the victim and the Mr. Shaw were

exposed to the acid causing severe burns to both their bodies.” The fact that the acid

appeared to have spread around by the struggle showed that the burns occurred prior

to death. The State also stated that although investigators at some point thought that

the acid had been intentionally poured on Ronda’ body, the crime scene photos and

Dr. Butts’ autopsy results showed that Ronda was only exposed to the acid during

the struggle. (Ipp. 33-34)

2. The Trial Court Accepts the Plea.

The trial court found that there was a factual basis for the plea and for the

stipulated aggravating factor; found that the plea was made freely, voluntarily, and

understandingly; and accepted Mr. Shaw’s Alford plea to second-degree murder.

(Ip. 36)

C. The Sentencing Hearing.

1. The State’s Evidence.

The State presented victim impact evidence from Ronda’s mother, her aunt,

and a childhood friend. (IIpp. 40-65)

8

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2. The Mr. Shaw’s Evidence.

a. Defense Contentions.

The trial court allowed the defense to give a summary of what it contended

the evidence would have shown at trial. (IIp. 66) The defense summarized its

contentions as follows:

Mr. Shaw met Ronda, his first serious girlfriend, while working at

McDonald’s while both were in high school in Johnston County. They eventually

moved in with Ronda’s family in Washington, D.C. Within a few years, Myka was

born. Mr. Shaw and Ronda got their own residence in D.C. Mr. Shaw worked two

jobs to provide for the family. Over the years, the couple separated several times

because of financial issues and disagreements about the proper care of Myka. Mr.

Shaw got a degree in computer science while working multiple jobs. Eventually,

the couple separated permanently, and there was a several-year custody battle over

Myka. Mr. Shaw got custody of Myka during the school year, and Myka went to

live with Ronda in Clayton during holidays and summer vacation. (IIpp. 66-69)

Ronda later had two more children, Trey and Marcus, by other men. Mr.

Shaw took a very active part in raising them, and many people believed they were

his children because he treated them like they were his own. Until late 2005 or early

2006, Mr. Shaw saw the boys on a regular basis. Mr. Shaw visited his grandmother

in Kenly, North Carolina, about twice a month to help her with shopping and home

maintainance. As soon as Mr. Shaw arrived in Kenly, Ronda would drop off the

9

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boys at Mr. Shaw’s grandmother’s house. Mr. Shaw also often brought the boys to

D.C. with him. (IIpp. 70-72)

Myka was the most important thing in Mr. Shaw’s life. He worked hard to

get Myka into the best magnet schools in the D.C. area and prepare her for college.

(IIpp. 72-73)

Myka visited Ronda a week before her death. At that time there were issues

between Mr. Shaw and Ronda, including whether Ronda should start contributing to

Myka’s support. Ronda had never supported Myka financially except when Myka

was staying in North Carolina. Mr. Shaw also raised concerns about Ronda’s care

of Trey and Marcus. Mr. Shaw believed Ronda was spending too much time with

her boyfriends and not enough time with the boys. (IIpp. 76-77)

When Mr. Shaw dropped Myka off in D.C., Ronda came to the car and said

there were things that they needed to talk about. Mr. Shaw said they would talk

later. Myka stayed a week with Ronda. Mr. Shaw picked her up on April 16. On

the way back to D.C., Mr. Shaw asked Myka what she did during the week. Myka

said she hardly saw Ronda and that she mostly babysat for her brothers and cleaned

the house. (IIpp. 77-78)

Mr. Shaw was upset because he felt that it was important for Myka to have

contact with Ronda. Myka and Mr. Shaw spent the night of April 16 with relatives

in Baltimore. Mr. Shaw spoke to Ronda on the phone on April 17 and said he

would come see her because they needed to talk. (IIp. 78)

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On April 18, Mr. Shaw took a sick day from work and drove back to Ronda’s

house. Mr. Shaw was wearing khaki pants and a dark long sleeve shirt. Ronda left

work early and was waiting for him. She admitted him to the house. The two soon

got into an argument and then a physical altercation. Mr. Shaw went in the

bathroom because he thought he had gotten cut. When he emerged, Ronda had a

dark glass container in her hand and threw something toward his groin. Mr. Shaw

turned sideways, something hit him in the buttocks, and he felt immediate pain, like

he was on fire. Mr. Shaw grabbed Ronda’s forearms to keep her from getting any

more of the substance on him. Ronda’s head came down toward him and he “lost

it.” Mr. Shaw was in a rage and started striking Ronda’s face with his right knee.

Mr. Shaw was not sure how many times. (IIpp. 79-80)

At this point, Mr. Shaw was in a panic. All he could later remember was

“running after this thing and … very vaguely that they were all over [the] living

room … and … kitchen ….” Although the crime scene photos depicted a scene in

which there was a lot of sliding in the acid, Mr. Shaw could not remember this. As

he was running out of the house he noticed that his clothes had disintegrated and he

grabbed a towel. He couldn’t find his keys and he grabbed Ronda’s keys off the

counter and drove away in her car. He found his keys and parked Ronda’s car and

got into his own car. Mr. Shaw had little memory of the ride back to D.C. He was

in shock and just wanted to get home. (IIpp. 81-82)

11

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When Mr. Shaw got back to D.C., he looked on the computer to find out what

to do about his injuries. When he later found out that Ronda was dead, he was

consumed with guilt because he knew his actions led to her death. (IIp. 82)

The defense pointed out that police were unable to link the acid to Mr. Shaw

through his computer or credit card records. Police did not look in Ronda’s home to

determine if she had any household products that contained sulfuric acid. Further, a

Lowe’s bag was found in Ronda’s home, but there was no follow-up to determine

what she bought at Lowe’s. Additionally, Ronda’s employer had sulfuric acid in its

laboratory. (IIpp. 84-86)

The defense further pointed out with regard to the identification of Mr. Shaw

by the neighbors based on the single photo, that Patricia Brown was first unsure if

the photo depicted the same person who had climbed the fence. Brown’s boyfriend

and daughter did not identify Mr. Shaw as the person they saw. The daughter

specifically said that the photo did not depict the man she saw in Ronda’s yard.

Brown then looked at the photo and said, “That’s him, that’s him.” When Brown

brought her daughter to the police station thirty minutes later, the daughter stated

that the man in the photo was the one she saw. (IIpp. 88-90)

Further, because the man was seen after Brown heard screams, the man must

have come to the house after the incident. None of the three witnesses said that the

person’s clothes were burned in any way. They said that the person easily climbed

the six-foot fence. As shown by the evidence at the scene and Mr. Shaw’s extensive

12

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burns, Mr. Shaw’s clothes would have been burned and he would not have been able

to easily jump over the fence. Therefore, the defense would have argued at trial that

Mr. Shaw was not the person seen by Brown and the others. (IIpp. 90-92)

The defense additionally noted that the blue and white uniforms worn by

Talecris employees are similar to the clothing described by the witnesses. Further,

the State did not test the black material on the “fringe” of Mr. Shaw’s sweatpants to

determine if it was sulfuric acid. (IIpp. 100-02)

The defense also stated that there were unanswered questions about Ronda’s

movements the night before. Ronda spoke to her boyfriend on the evening of April

17 and the morning of April 18. At 1:30 a.m. on the morning of April 18, Ronda

made a purchase at a convenience store thirty-four miles from her home.

Additionally, during the early morning hours, as shown by a surveillance tape made

by Ronda, it appeared that a woman and a man were together in Ronda’s home.

Ronda’s boyfriend said that he was not there. (IIpp. 92-97)

With regard to the past instances of vandalism, the defense pointed out that

there were many other suspects – including Ronda’s other previous boyfriends.

Further, with regard to the February 2005 arson incident, people noticed that Ronda

still had things that she claimed were destroyed in the fire. Police gave Ronda a

“stress test” and she failed. Additionally, Mr. Shaw’s work records showed that he

was working that day in D.C. (IIpp. 74-76)

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Finally, the defense stated that Mr. Shaw’s burn injuries to his buttocks and

right leg and Ronda’s burns on the left side of her face were consistent with Mr.

Shaw’s version of events – that Ronda threw the acid toward his groin area, that he

turned and the acid hit his buttocks, and that he hit the left side of Ronda’s head with

his right knee as the acid was being thrown around. (IIpp. 104-05)

b. Sentencing Evidence.

Mr. Shaw worked at Source Media, a daily paper. There were a lot of

“tension and stressors” in the workplace as the afternoon deadlines loomed. Two of

Mr. Shaw’s co-workers, Desiree Mitchell and Elizabeth Washington testified that

Mr. Shaw always knew how to calm everyone down; he was “like Switzerland.” He

stayed away from drama and avoided confrontation. He was always calm and

considerate. He was very helpful to his co-workers and expected nothing in return.

(IIpp. 108-12, 118-20)

Mitchell and Washington also testified as to how much Myka, Trey, and

Marcus meant to Mr. Shaw. Myka would visit the office weekly, and the boys every

other month. The last time the boys were at the office was February, 2006. They

called Mr. Shaw “daddy.” Mr. Shaw appeared to adore them, and they adored him

back. Washington thought the boys were Mr. Shaw’s own children. Mr. Shaw

corrected her, but told her, “[A]s far as I’m concerned, they’re my boys.” (IIpp.

112-15, 118-22)

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Mr. Shaw made sacrifices for the children in that he did not spend his money

on his own entertainment. If he wanted to watch a movie, he would rent one and

watch it with the kids. If he wanted a meal, he would cook it with the kids. Mr.

Shaw also provided the boys with gifts on holidays, as well as clothes and school

supplies that they needed. Once Washington asked Mr. Shaw why he bought

clothes for the boys and sent them to Ronda; why not just send her the money so she

could buy the clothes? Mr. Shaw said he “didn’t trust money down there.”

Washington once overheard a phone conversation between Mr. Shaw and Ronda.

Mr. Shaw was asking her why she needed money for winter coats when he had just

bought the boys coats. He told Ronda that if they needed coats, he would come

down and buy them. Other conversations Washington overheard between Mr. Shaw

and Ronda also seemed to be about money. (IIpp. 114, 122-25)

Mr. Shaw also spent a lot of time trying to raise Myka properly. He focused

on her welfare and self-esteem as she started to become a young woman, and asked

women in the office for advice on how to help her with teenage problems. Mr.

Shaw worked hard to get Myka into a magnet school and to find scholarships for her

to go to college. Mr. Shaw worried that Ronda was not a good influence on Myka.

(IIpp. 115-16, 125-26)

Mitchell and Mr. Shaw talked about Ronda sometimes. Mr. Shaw said he

would always have feelings of love for Ronda because she is Myka’s mother, but

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that he couldn’t be with her. Mr. Shaw did not seem jealous or vengeful toward

Ronda. (IIp. 116)

Mr. Shaw’s brother, Andre Shaw, testified that Mr. Shaw was a loving and

concerned father and wanted to provide a stable home for Myka. Mr. Shaw worked

part-time in Andre Shaw’s janitorial business while he was also working at Source

Media. Andre Shaw testified that he did not use dangerous chemicals or drain

cleaner in his business. (IIpp. 127-28, 135-36)

Andre Shaw also testified that Mr. Shaw provided care for Ronda’s other two

children as well as Myka. Andre Shaw reiterated Washington’s and Mitchell’s

testimony that Mr. Shaw bought the boys holiday gifts and things they needed.

Ronda would drop the boys off at Mr. Shaw’s grandmother’s house in Kenly when

Mr. Shaw was going to be there. Mr. Shaw went to his grandmother’s house at least

twice a month to mow the lawn and do routine maintenance. The boys visited with

Mr. Shaw as late as February, 2006. (IIpp. 127-30)

Andre Shaw also testified that on the day of the February 2005 arson, he

stopped by Mr. Shaw’s residence in D.C. Myka was at home and they listened to an

answering machine message from Ronda about the arson. Andre Shaw called his

brother’s landline at work in D.C. and told him what happened. Mr. Shaw came

home in about forty minutes. (IIpp. 132-33)

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Mr. Shaw told his brother what happened on April 18. Mr. Shaw said that he

and Ronda were arguing about the kids and Ronda threw a chemical at him. (IIp.

134)

Myka Shaw testified as to how good a father Mr. Shaw was to her and the

boys. When she went to live with her mother during school vacations, Ronda was

gone a lot. Myka spent a lot of time doing housework. Ronda wasn’t interested in

talking to Myka about mother/daughter things. (IIpp. 137-44)

Myka further testified that there were issues between Mr. Shaw and Ronda

about money and about the boys. Mr. Shaw told Ronda he didn’t like the way she

cared for the boys. Ronda would “get all in his face” and try to start an argument.

Mr. Shaw would try to walk away and not escalate the argument. Myka never saw

Mr. Shaw confront Ronda physically, threaten Ronda, or say that he wanted to harm

her. Myka believed Mr. Shaw could not hurt Ronda under normal everyday

circumstances. (IIpp. 145-47)

Myka also testified that although she told police that her father was home in

D.C. on April 18, she meant that she saw someone outside walking down the street

that she believed to be her father. (IIp. 154)

Janet Adams, a mitigation specialist with the Capital Defender’s Office,

interviewed some of Mr. Shaw’s relatives and Ronda’s relatives. They all stated

that Mr. Shaw was a loving and devoted grandson to his grandmother in Kenly and a

good father to Myka, and that he cared for Ronda’s boys as if they were his own.

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They told Adams that Ronda would drop the boys off in Kenly for Mr. Shaw to

watch, sometimes dropping them off before Mr. Shaw even arrived. (IIpp. 164-69)

Ronda’s brother-in-law told Adams that Mr. Shaw always treated Ronda well,

and that he was very surprised when he heard what happened. Trey’s grandmother

said that she had never heard Mr. Shaw say anything negative about Ronda. None

of the others interviewed said anything inconsistent with this. No one said that Mr.

Shaw was jealous of Ronda. Instead, Mr. Shaw was concerned about the effect that

Ronda’s lifestyle would have on Myka and the boys. He didn’t like the idea of

Myka seeing Ronda’s boyfriends coming and going. (IIpp. 169-72)

Adams also interviewed Mr. Shaw’s former jailer Joe Best. Officer Best

described Mr. Shaw as a “superior person” who went out of his way to help other

inmates. Mr. Shaw would clean up after inmates with HIV, and had given up his

bunk for sick inmates numerous times. No one had to ask; he did it on his own.

Once, Officer Best slipped and fell in the jail. Best told Adams that he was in a very

vulnerable position that the other inmates could have taken advantage of. But Mr.

Shaw was the first person who got to him. Mr. Shaw helped him up and asked if he

was okay. (IIpp. 170-71)

Forensic psychiatrist Dr. James Hilkey testified that he interviewed Mr. Shaw

about ten times over two years, for a total of twenty-five hours, that he reviewed

materials related to the case. Mr. Shaw was initially not very forthcoming during

the interviews, but became moreso as time went on. It was important to Mr. Shaw

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to project himself as a capable, competent person. He kept unacceptable feelings

from other people and from his own awareness. One way he kept his own emotions

out of his awareness was to avoid conflict and to view himself as a peacemaker.

(IIpp. 175-81, 191-92)

Nevertheless, Mr. Shaw became emotional twice during his time with Dr.

Hilkey – when describing how he and Ronda met in high school at McDonald’s and

when talking about what happened on April 18. Mr. Shaw admitted that he

snapped, but had a hard time accepting it. It was difficult for him to accept that he

was responsible for the death of someone he cared for. It was difficult for him to

talk about himself in terms of inadequacies. (IIpp. 181-82, 191-92, 200)

Mr. Shaw was abandoned early by his biological father. His mother married

again, but his stepfather was in the military and often absent. Dr. Hilkey believed

that the absence of father figures had an impact on Mr. Shaw’s early development.

Because his own home was somewhat fractured, providing a stable family became

the driving force in Mr. Shaw’s life. (IIpp. 184, 186-87, 212)

While he was growing up, Mr. Shaw had a thyroid disorder that caused him to

grow large breasts. Until they were removed, this was a source of embarrassment

for him. Other children made fun of him and he couldn’t fit in. He was not a

particularly good student and his intelligence is in the low average range. He felt

inadequate. Dr. Hilkey observed that Mr. Shaw likely had to work very hard to get

his degree in computer science. (IIpp. 184-86, 190, 195)

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Mr. Shaw told Dr. Hilkey what happened on April 18. Mr. Shaw went to

Ronda’s home to talk about Myka. Their conversation started civilly, but Ronda

became enraged and a fight ensued. Ronda threw a substance on him, they fought

some more, and he grabbed Ronda’s arms and struck her head with his knee many

times. Mr. Shaw’s memory of the incident was not entirely clear. Dr. Hilkey

explained that this is not uncommon for someone under extreme physical or

emotional pain. Mr. Shaw remembered that he completely lost it, became

frightened, and left the scene. Dr. Hilkey explained that when a person feels more

stress than he can bear, he can lose control and behave in ways that are not typical.

Here, not only was there a physical altercation, but Mr. Shaw was in acute pain from

the sulfuric acid burning his body. This created a “perfect storm” and Mr. Shaw lost

control. Mr. Shaw told Dr. Hilkey he wished he had stayed and done something for

Ronda. Dr. Hilkey said that Mr. Shaw’s flight was a result of being overwhelmed

and being in extreme pain. (IIpp. 197-200)

3. Sentencing.

The defense asserted that Mr. Shaw did not come to North Carolina to do any

harm to Ronda. He did not bring any acid. When Ronda threw acid on him, he

became enraged and lost it. There were unanswered questions concerning where the

acid was from, why Ronda left her house in the middle of the night, who was there

with her in the early morning, the identity of the man who climbed the fence, and

who left the key in Ronda’s living room and when it was left there. Allowing Mr.

Shaw to plead to second-degree murder was not a “great concession” for the State.

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The defense also disputed that Mr. Shaw was responsible for the prior vandalism

incidents, or that Ronda believed that he was involved. Indeed, Ronda had

continued to leave her children with him until February, 2006. (IIpp. 214-25)

The trial court stated that it appeared from viewing photos of the body that

acid was poured on Ronda as she lay on the floor. The defense reiterated the State’s

earlier statement, (Ip. 34), that the autopsy and other evidence showed that acid was

not poured on Ronda. (IIpp. 226-27) The trial court again stated that it looked like

the acid was poured. (IIp. 228)

The State argued that Mr. Shaw did not tell Ronda he was coming to visit.

The State maintained that Mr. Shaw was responsible for the prior acts of vandalism

and that on April 18 he showed up at her house with the acid in order to vandalize it.

The State further maintained that although Mr. Shaw “may not have premeditated”

the killing, (IIp. 234), “there was absolute premeditation and deliberation on

multiple times to vandalize [Ronda’s] house.” (IIp. 236) The State additionally

contended that on April 18, Mr. Shaw entered Ronda’s home with a key. Ronda

came home early, an argument ensued, and eventually there was “a huge struggle”

during which both suffered their injuries. (IIpp. 234-36) The State opined, “We

think second-degree is an appropriate theory in this case, an appropriate charge,” but

that it was “one of the most heinous second-degree cases we’ve seen.” The State

asked for a maximum aggravated range sentence. (IIp. 240)

The trial court stated:

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I don’t know, but I suspect if this had actually been tried as first-degree murder, the State would have argued under a theory of first-degree murder on the basis of premeditation and deliberation, that those can develop during a very short time even during the assault. I think the instruction would be given to the jury of that being the law. So as it relates to the State giving the Mr. Shaw no concession, I think that had it been tried before a jury, that that would have been an appropriate charge and been submitted to the jury under these facts and with that instruction. (IIp. 242)

The trial court told Mr. Shaw, “I do believe that the State of North Carolina

has made a significant concession for you by allowing you to plead to second-

degree murder.” (IIp. 244)

The trial court found several mitigating factors. The trial court found that the

stipulated aggravating factor outweighed the mitigating factors and that Mr. Shaw

had zero prior record points. The trial court sentenced Mr. Shaw to the maximum

aggravated sentence, 196 to 245 months. (IIpp. 244-46)

ARGUMENT

I. THE TRIAL COURT ERRED WHEN IT TOOK INTO ACCOUNT DURING SENTENCING AN AGGRAVATING FACTOR WHICH WAS NEITHER STIPULATED TO NOR FOUND BY A JURY BEYOND A REASONABLE DOUBT, AND WHICH WAS NOT ALLEGED IN A CHARGING DOCUMENT.

Assignments of Error Nos. 8-10, Rp. 27 & Addendum to Record on Appeal

Standard of Review: De novo review applies to issues concerning the

denial of a constitutional right, State v. Prevatte, 356 N.C. 178, 218, 570 S.E.2d 440,

462 (2002), the trial court’s consideration of an improper factor during sentencing,

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State v. Person, 187 N.C. App. 512, 525-28, 653 S.E.2d 560, 569 (2007), and the

violation of a statutory mandate. State v. Ashe, 314 N.C. 28, 331 S.E.2d 652 (1985).

Under the de novo standard, the reviewing court considers the matter anew and

freely substitutes its own judgment for that of the lower court. N.C. Department of

Environment & Natural Resources v. Carroll, 358 N.C. 649, 660, 599 S.E.2d 888,

895 (2004).

Argument:

In determining Mr. Shaw’s sentence, the trial court took into account that Mr.

Shaw could have been tried for first-degree premeditated murder, but the State made

a “significant concession” by allowing him to plead to second-degree murder. The

trial court erred because this nonstatutory aggravating factor was neither stipulated

to nor found by a jury beyond a reasonable doubt. In addition, the aggravating

factor was not alleged in a charging document. These errors violated Mr. Shaw’s

rights under the Sixth and Fourteenth Amendments to the United States

Constitution, Article I, Sections 19, 22, 23, and 24 of the North Carolina

Constitution, and G.S. §15A-1340.16.

The terms of Mr. Shaw’s plea were as follows:

The defendant will plead guilty to second-degree murder. The Mr. Shaw will also stipulate to the aggravating factor [that the victim suffered greatly prior to her death]. After presentation of evidence to the court at a sentencing hearing, both sides will argue as to the appropriate sentence. (Rpp. 10-11)

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Mr. Shaw entered an Alford plea to second-degree murder and stipulated to

the aggravating factor. (Rpp. 9-12; Ipp. 4-11) After the presentation of evidence at

the sentencing hearing, the defense asserted that Mr. Shaw did not intend to harm to

Ronda and he did not bring any acid. When Ronda threw acid on him, he became

enraged and lost it. Therefore, allowing Mr. Shaw to plead to second-degree murder

was not a “great concession” for the State. (IIpp. 224-25)

Although the State maintained that Mr. Shaw brought the acid to Ronda’s

home, the State also stated that he brought the acid to vandalize the home, not to

harm her. The State further stated that Ronda’s death occurred during “a huge

struggle” in the living room. The State opined, “We think second-degree is an

appropriate theory in this case, an appropriate charge.” (IIpp. 234-36, 240)

The trial court stated:

I don’t know, but I suspect if this had actually been tried as first-degree murder, the State would have argued under a theory of first-degree murder on the basis of premeditation and deliberation, that those can develop during a very short time even during the assault. I think the instruction would be given to the jury of that being the law. So as it relates to the State giving the defendant no concession, I think that had it been tried before a jury, that that would have been an appropriate charge and been submitted to the jury under these facts and with that instruction. (IIp. 242)

Additionally, the trial court told Mr. Shaw immediately before sentencing

him, “I do believe that the State of North Carolina has made a significant concession

for you by allowing you to plead to second-degree murder.” (IIp. 244)

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The trial court found the nonstatutory aggravating factor to which Mr. Shaw

stipulated, that the victim suffered greatly prior to her death, and found several

mitigating factors. The trial court found that the aggravating factor outweighed the

mitigating factors and sentenced Mr. Shaw to the maximum aggravated sentence,

196 to 245 months. (IIpp. 244-46)

Even though “[a] sentence within the statutory limit will be presumed regular

and valid[,] . . . such a presumption is not conclusive.” State v. Boone, 293 N.C.

702, 712, 239 S.E.2d 459, 465 (1977). “If the record discloses that the court

considered irrelevant and improper matter in determining the severity of the

sentence, the presumption of regularity is overcome, and the sentence is in violation

of defendant’s rights.”  Id.

Under Apprendi v. New Jersey, “[o]ther than the fact of a prior conviction,

any fact that increases the penalty for a crime beyond the prescribed statutory

maximum must be submitted to a jury, and proved beyond a reasonable doubt.”

Apprendi v. New Jersey, 530 U.S. 466, 490, 147 L. Ed. 2d 435, 455 (2000). “The

‘statutory maximum’ for Apprendi purposes is the maximum sentence a judge may

impose solely on the basis of the facts reflected in the jury verdict or admitted by the

Mr. Shaw.” Blakely v. Washington, 542 U.S. 296, 303, 159 L. Ed. 2d 403, 413

(2004). “Thus, while a trial court may impose an aggravated sentence on the basis

of admissions made by a defendant, error occurs when a judge aggravates a criminal

sentence on the basis of findings made by the judge that are in addition to or in lieu

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of findings made by a jury.” State v. Hurt, 361 N.C. 325, 329, 643 S.E.2d 915, 917

(2007).

In response to the decision in Blakely, our legislature amended our sentencing

statutes. Accordingly, if a defendant does not admit to an aggravating factor, “only

a jury may determine if an aggravating factor is present in an offense,” §15A-

1340.16(a1), and “[t]he State bears the burden of proving beyond a reasonable doubt

that an aggravating factor exists.” §15A-1340.16(a). “If the defendant pleads guilty

to the felony, but contests the existence of one or more aggravating factors, a jury

shall be impaneled to determine if the aggravating factor or factors exist.” §15A-

1340.16(a3). Further, “[a]ny [nonstatutory] aggravating factor … shall be included

in an indictment or other charging instrument ….” §15A-1340.16(a4).

The trial court erred by taking into account the aggravating factor that the

State could have submitted the charge of first-degree premeditated murder to a jury.

Initially, here “it can reasonably be inferred from the trial court’s … remarks” that

in sentencing Mr. Shaw, it took into account the extra aggravating factor. See State

v. Hueto, ___ N.C. App. ___, 671 S.E.2d 62, 68 (2009) (granting new sentencing

hearing where it could reasonably be inferred from trial court’s remarks that court

took improper considerations into account in sentencing). That the trial court took

the extra factor into account is shown by the fact that it stated twice that Mr. Shaw

was being given a concession by being allowed to plead to second-degree murder,

the second time personally addressing the defendant; that the second remark

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occurred immediately before the trial court pronounced sentence; and that the trial

court seemed to believe that Mr. Shaw poured the acid on Ronda. (IIp. 226-28, 242-

44) These facts lead to “a clear inference that a greater sentence was imposed

because” the trial court believed Mr. Shaw premeditated and deliberated the crime.

See Hueto, ___ N.C. App. at ___, 671 S.E.2d at 69 (2009).

The trial court erred by taking this factor into account. It is true that our

appellate courts have found that it is proper to aggravate the defendant’s sentence

based on a finding of an element or elements not included in the charge to which the

defendant pled guilty. State v. Melton, 307 N.C. 370, 375-77, 298 S.E.2d 673, 677-

78 (1983) (premeditation and deliberation as aggravating factor where defendant

pled guilty to second-degree murder); State v. Byrd, 164 N.C. App. 522, 527-29, 596

S.E.2d 860, 863-65 (2004) (that “the defendant could have been, but was not

charged with shooting into occupied property” as aggravating factor). However,

such an aggravating factor must comport with the requirements of Blakely and our

sentencing statutes – it must be alleged in an indictment, and found by a jury beyond

a reasonable doubt.

Here, the aggravating factor that Mr. Shaw could have been tried for first-

degree premeditated murder was not submitted to a jury and found beyond a

reasonable doubt. Additionally, Mr. Shaw’s indictment did not allege any

aggravating factors. (Rp. 4) Therefore, the trial court erred by taking this

aggravating factor into account in sentencing Mr. Shaw.

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A violation of the requirements of Apprendi and Blakely that a jury determine

which aggravating factors apply to a particular offense is subject to constitutional

harmless error analysis. Washington v. Recuenco, 548 U.S. 212, 165 L. Ed. 2d 466

(2006). The error is harmless only if the State can show that the evidence was “so

‘overwhelming’ and ‘uncontroverted’ that any rational fact-finder would have found

the disputed aggravating factor beyond a reasonable doubt.” State v. Blackwell, 361

N.C. 41, 49, 638 S.E.2d 452, 458 (2006) (citations omitted). The statutory errors

require reversal if there is a reasonable possibility that, but for the errors, a different

result would have been reached. §15A-1443(a).

Here, the State cannot show that the trial court’s consideration of the

nonstatutory aggravating factor that Mr. Shaw could have been tried for

premeditated murder was harmless beyond a reasonable doubt. Further, but for this

error, there is a reasonable possibility that the trial court would have reached a

different sentencing result.

First, the error requires a new sentencing hearing because it does not appear

that the aggravating factor – that Mr. Shaw could have been tried for first-degree

premeditated murder – is something that a jury could properly determine. Whether

the evidence is sufficient to sustain a charge is a question of law and is only properly

determined by a judge. State v. Barden, 356 N.C. 316, 251, 572 S.E.2d 108, 131

(2002) (citation omitted). The trial court did not determine that Mr. Shaw

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premeditated and deliberated the crime, only that he could have been tried for doing

so. (IIpp. 241-42)

Second, even if the aggravating factor were that Mr. Shaw premeditated and

deliberated the crime, the State cannot show that the evidence of premeditation was

“so ‘overwhelming’ and ‘uncontroverted’ that any rational fact-finder would have

found the disputed aggravating factor beyond a reasonable doubt.”

As shown above, Mr. Shaw treated Ronda well and had not had any past

physical altercations with her. When they would argue about money or the children,

Mr. Shaw would try to diffuse the argument. According to his coworkers, Mr. Shaw

was nonconfrontational and “a peacemaker.” The State could not show the source

of the acid and the evidence was equivocal as to who brought the acid to Ronda’s

home. Further, even if, as contended by the State (IIp. 235), Mr. Shaw brought the

acid to Ronda’s home in order to vandalize it, Mr. Shaw’s and Ronda’s injuries

match his version of events: that Ronda threw the acid toward his groin, that he

turned and the acid hit his buttocks, and that he hit the left side of Ronda’s head with

his right knee. The evidence showed, and both parties agreed (Ip. 34; IIpp. 227-29),

that Mr. Shaw did not pour the acid on Ronda. Instead, there was a “very large

struggle throughout the home” (Ip. 33), during which both parties were severely

burned. Therefore, the evidence was not “so ‘overwhelming’ and ‘uncontroverted’

that any rational fact-finder would have found [premeditation and deliberation]

beyond a reasonable doubt.” See State v. Beck, 163 N.C. App. 469, 474, 594 S.E.2d

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94, 97 (2004) (second-degree murder verdict properly submitted based on evidence

that defendant and victim argued and victim assaulted defendant prior to killing),

rev’d in part on other grounds, 359 N.C. 611, 614 S.E.2d 274 (2005). See also

State v. Williams, 144 N.C. App. 526, 531, 548 S.E.2d 802, 805 (2001) (insufficient

evidence of premeditation and deliberation where no evidence of animosity or that

defendant had made threatening remarks to victim, defendant was provoked by

victim’s assault, and defendant’s actions before and after the shooting did not show

planning or forethought on his part).

Even the State was uncertain as to whether the killing was premeditated and

deliberate or not. The State asserted that Mr. Shaw “premeditated” vandalizing

Ronda’s house, (IIp. 236), but that he “may not have premeditated” the killing. (IIp.

234) The State further stated that Ronda’s death occurred during “a huge struggle”

in the living room. (IIp. 236) Accordingly, the State asserted that “second degree is

an appropriate theory in this case.” (IIp. 240)

Therefore, the State cannot show that there was overwhelming evidence of

premeditation and deliberation. Further, because the evidence of premeditation was

so equivocal, there is a reasonable possibility that a jury would not have found this

fact beyond a reasonable doubt. §15A-1443(a). Additionally, because the extra

aggravating factor was not alleged in a charging document, Mr. Shaw did not have

notice of the factor and the trial court did not have jurisdiction to rely on the factor

in sentencing. State v. Westbrooks, 345 N.C. 43, 58, 478 S.E.2d 483, 492 (1996)

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(citation omitted) (one “purpose[ ] of an indictment include[s] giving a defendant

notice of the charge against him so that he may prepare his defense”); State v.

McBane, 276 N.C. 60, 65, 170 S.E.2d 913, 916 (1969) (“A valid warrant or

indictment is an essential of jurisdiction. … The warrant or indictment must charge

all the essential elements of the alleged criminal offense.”).

The fact that Mr. Shaw stipulated to the aggravating factor that the victim

suffered greatly prior to her death does not mean that the trial court’s error in relying

on the improper aggravating factor was harmless.

Our Supreme Court has held that where an aggravating factor is erroneous,

but where one or more other aggravating factors are properly found, there is no

prejudicial error if the trial court announces that each of the aggravating factors

independently justified the aggravated sentence imposed. State v. Everette, 361

N.C. 646, 657-58, 652 S.E.2d 241, 248-49 (2007). However, in Everette, the trial

court did not, through its remarks, appear to be relying on an extra aggravating

factor as well as on the properly found aggravating factors. In Mr. Shaw’s case,

while the trial court announced that the aggravated sentence was based on a

weighing of the stipulated aggravating factor against the mitigating factors, the trial

court also indicated through its remarks that it was taking into account that the State

could have tried Mr. Shaw for premeditated murder. Therefore, Everette does not

apply. Accordingly, the trial court’s proper finding of one aggravating circumstance

does not mean that the error here is harmless.

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Mr. Shaw must be granted a new sentencing hearing. “When the trial judge

errs in finding an aggravating factor and imposes a sentence in excess of the

presumptive term, the case must be remanded for a new sentencing hearing.” State

v. Wilson, 338 N.C. 244, 259, 449 S.E.2d 391, 400 (1994). Resentencing is required

even if a single factor in aggravation is improperly applied. State v. Ahearn, 307

N.C. 584, 602, 300 S.E.2d 689, 701 (1983).

In State v. Ahearn, supra, the trial court found several aggravating and

mitigating factors and gave the defendant an aggravated sentence. On appeal, the

Supreme Court determined that one of the aggravating factors was unsupported.

The Court concluded that the error was not harmless because there was no way to

know how much weight was afforded to each aggravating factor: “Reliance on a

factor in aggravation determined to be erroneous may or may not have affected the

balancing process which resulted in the decision to deviate from the presumptive

sentence.” Id. at 602, 300 S.E.2d at 700. Indeed, “it must be assumed that every

factor in aggravation measured against every factor in mitigation, with concomitant

weight attached to each, contributes to the severity of the sentence.” Id. at 602, 300

S.E.2d at 701. For this reason, “our appellate courts should not attempt to second

guess the sentencing judge with respect to the weight given to any particular factor

… [or] engage in numerical balancing in order to determine whether a sufficient

number of aggravating factors remain to ‘tip the scales.’” Id.

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In this case, like Ahearn, there is no way to know how much weight the trial

court gave the extra nonstatutory aggravating factor. Therefore, the error was not

harmless and Mr. Shaw must be granted a new sentencing hearing. See State v.

Hurt, 361 N.C. 325, 332, 643 S.E.2d 915, 919 (2007) (where one of three

aggravating factors that was not submitted to jury in violation of Blakely was not

supported by overwhelming and uncontroverted evidence, our Supreme Court

remanded case for a new sentencing hearing, noting, “Having concluded that the

trial court’s finding of the HAC aggravating factor was not harmless error, we need

not consider the other two aggravating factors”); State v. Rollins, 131 N.C. App.

601, 508 S.E.2d 554 (1998) (relying on Ahearn and remanding for new sentencing

hearing where one of three aggravating factors improperly found).

This error is properly before this Court and is preserved for review. A

defendant who pleads guilty has a right to appeal the issue of whether the trial court

erred by finding an aggravating factor not admitted by the defendant nor found by a

jury beyond a reasonable doubt. E.g., State v. Whitehead, 174 N.C. App. 165, 620

S.E.2d 272 (2005). Further, “‘[a]n error at sentencing is not considered an error at

trial for the purpose of Rule 10(b)(1) because this rule is ‘directed to matters which

occur at trial and upon which the trial court must be given an opportunity to rule in

order to preserve the question for appeal.’” State v. Curmon, 171 N.C. App. 697,

703, 615 S.E.2d 417, 422 (2005) (citations omitted). Therefore, our courts do not

“require that after a trial is completed and a judge is preparing a judgment or making

findings of aggravating factors in a criminal case, that a party object as each fact or

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factor is found in order to preserve the question for appeal.” State v. Canady, 330

N.C. 398, 403, 410 S.E.2d 875, 878 (1991).

Certainly, no defendant wishes for a trial court to find additional aggravation

and sentence him to the highest possible sentence, especially in a way that violates

procedures set out in our statutes. Here, Mr. Shaw’s attorney specifically requested

that the trial court not sentence Mr. Shaw at the top of the aggravated range. (IIpp.

241-42) Accordingly, “[t]he defendant did not want the court to find the

aggravating factor and the court knew or should have known it. This is sufficient to

support an assignment of error.” 330 N.C. at 402, 410 S.E.2d at 878. In addition,

the statutory errors are preserved as violations of statutory mandates. Ashe, supra.

See §§15A-1340.16(a3) (“a jury shall be impaneled to determine if the aggravating

factor or factors exist), -1340.16(a4) (nonstatutory aggravating factors “shall be

included in an indictment or other charging instrument”) (emphasis added).

In summary, the trial court erred by considering the aggravating factor that

Mr. Shaw could have been tried for first-degree premeditated murder. Mr. Shaw

must be granted a new sentencing hearing.

CONCLUSION

For all the foregoing reasons, Mr. Shaw respectfully contends he must be

granted a new sentencing hearing.

Respectfully submitted this the 30th day of October, 2009.

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______________________________Anne M. GomezAssistant Appellate [email protected]

Staples S. HughesAppellate [email protected]

Office of the Appellate Defender123 West Main Street, Suite 500Durham, North Carolina 27701(919)560-3334

ATTORNEYS FOR DEFENDANT

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CERTIFICATION OF COMPLIANCE WITH RULE 28( j )(2)(A)(2)

I hereby certify that the foregoing Defendant -Appellant’s brief complies with Appellate Rule 29(j)(2)(A)(2) in that, according to the word processing program used to produce this brief (Microsoft Word), the document does not exceed 8,750 words, exclusive of cover, index, table of authorities, certificate of compliance, certificate of service, and addendum.

This the 30th day of October, 2009.

____________________________Anne M. GomezAssistant Appellate Defender

CERTIFICATE OF FILING AND SERVICE

I hereby certify that the original Defendant-Appellant’s Brief has been filed pursuant to Rule 26 by electronic means with the Clerk of the North Carolina Court of Appeals.

I further hereby certify that a copy of the above and foregoing Defendant-Appellant’s Brief has been duly served upon Daniel P. O’Brien, Assistant Attorney General, [email protected], by electronic means.

This the 30th day of October, 2009.

____________________________Anne M. GomezAssistant Appellate Defender

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