State of North Carolina v. Iziah Barden

Summary

The Supreme Court of North Carolina rejected defendant's challenges to his capital conviction and death sentence, holding that he was not 'in custody' during either police interview so that Miranda warnings were unnecessary, that both statements were voluntary, and that the warrantless seizure of his shoes was a valid consensual seizure; it also upheld the sufficiency of the armed-robbery evidence supporting the felony-murder conviction and the sentencing proceedings, including submission of the especially heinous, atrocious, or cruel aggravator and the no-significant-history mitigator and the refusal of peremptory instructions on mitigating circumstances. The court did hold that the trial court erred in finding no prima facie Batson showing where the prosecutor's strikes of two African-American prospective jurors produced a 28.6% minority acceptance rate, and it remanded for a limited hearing on whether those strikes were race-neutral. The supplied opinion is truncated before the formal disposition paragraph; on the visible text the judgment was otherwise free of prejudicial error.