State of North Carolina v. Theodore Jerry Williams

Summary

The Supreme Court of North Carolina affirmed the Court of Appeals and upheld a trial court's pretrial dismissal, under N.C.G.S. § 15A-954(a)(4), of a felony assault charge against Theodore Jerry Williams. Prosecutor's office staff had created and displayed a poster mocking Williams with 'before' and 'after' booking photographs, and after Williams repeatedly sought the poster and underlying photographs, the State admitted at a pretrial hearing that they had been destroyed and could not be produced. Holding the destroyed evidence material and favorable (impeachment and self-defense value), the court concluded the State flagrantly violated Williams's due process rights and irreparably prejudiced his defense preparation, and that a due process violation may be declared pretrial when the State admits destruction and impossibility of production. No separate opinions were filed.