State of North Carolina vs. Tiffany Latoya Jackson (COA25-495), is a case out of Wake County in which the Ms. Jackson raises a Harbison issue and an ineffective assistance of counsel (IAC) issue on appeal. The North Carolina Court of Appeals found no error with respect to either of those issues and the Court’s analysis on those will not be discussed here. However, Ms. Jackson also raised an issue pertaining to the castle doctrine on appeal. Although the Court found no error here as well, the Court’s discussion on this provision of North Carolina law is worth examining.
In late March of 2022, while driving in the parking lot of a shopping center, Ms. Jackson encountered the victim. Prior to the encounter, Ms. Jackson saw the victim driving aggressively ahead of her on a main road. The two ended up turning into the parking lot of the same shopping center. The victim ended up stopping at the entrance causing traffic to become congested. At some point, Ms. Jackson’s vehicle and the victim’s vehicle collided. The State presented evidence that showed when Ms. Jackson attempted to go around the victim’s vehicle, Ms. Jackson’s vehicle hit the victim’s vehicle. However, Ms. Jackson contended that when she tried to go around the victim’s vehicle, the victim hit her vehicle. Shortly afterward, Ms. Jackson fired a gunshot at the victim. The bullet entered the bottom right corner of the victim’s rear windshield, passed through the driver’s seat headrest, and struck the victim in the head. The victim died from the gunshot wound a few days later. A witness for the prosecution stated that Ms. Jackson was outside of her vehicle when she fired the shot, but Ms. Jackson maintained that she was inside her vehicle when she fired the gun.
Ms. Jackson was tried by a jury in July of 2024 for first-degree murder. The jury received an instruction on self-defense, but no instruction on the castle doctrine was requested or given. Ms. Jackson was convicted of first-degree murder under the felony murder rule with the predicate felony being discharging a firearm into occupied property. Ms. Jackson gave notice of appeal with one of the issues she raised on appeal being the trial court’s failure to instruct the jury on the castle doctrine.
Ms. Jackson contended that there was evidence that she fired the shot to prevent the victim from entering her vehicle. Her argument was that her actions were legally justified under the castle doctrine as found in N.C.G.S. §14-51.2. In State v. Jones, 299 N.C. 103,107 (1980), the North Carolina Supreme Court held that the castle doctrine defense “…is a substantial and essential feature of [a] case, [so] the trial [court] must instruct on this defense when it is raised by the evidence even in the absence of any request by the defendant for special instruction.” From the North Carolina Supreme Court case State v. Coley, 375 N.C. 156, 159 (2020), we learn that when considering the applicability of the castle doctrine, the evidence must be considered in the light most favorable to the defendant. Lawful occupants of homes, motor vehicles, and workplaces are afforded protection under castle doctrine when using deadly force under certain circumstances. When a lawful occupant of vehicle uses deadly force to prevent or stop an intruder, there is a presumption that the occupant had a reasonable fear of imminent death or severe bodily harm. However, two conditions must be satisfied in order for the castle doctrine to apply. First, the intruder was either in the process of unlawfully and forcefully entering the vehicle; second, the lawful occupant had a reasonable belief that unlawful and forcible entry was occurring or had occurred.
In its analysis of Ms. Jackson’s appellate claim, the Court focused its attention on when viewed in the light most favorable to Ms. Jackson, was there evidence of an actual or attempted entry into her vehicle. The Court found that there was no evidence that the victim entered or attempted to enter Ms. Jackson’s vehicle. After the shooting, Ms. Jackson and a bystander provided assistance to the victim. The victim’s car doors were closed and the windows to the vehicle were rolled up. A witness also testified that the victim never exited their vehicle. Because the evidence did not show that the victim was in the process of unlawfully and forcefully entering Ms. Jackson’s vehicle or that the victim had unlawfully and forcefully entered Ms. Jackson’s vehicle, the appellate Court determined that the trial court did not err by not instructing the jury on the castle doctrine.
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