Supreme Court of North Carolina

State v. Lail

October 17, 2025

Summary

The Supreme Court of North Carolina affirmed the Court of Appeals, holding that the trial court abused its discretion in excluding a handwritten note under Rule 403, that the issue was properly preserved for review, and that the error was prejudicial requiring a new trial. The Court also clarified that abuse‑of‑discretion review, not plain‑error review, governs Rule 403 determinations.