Turning State's

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina appellate courtsin August 2026. In State v. Garmon, No. 329A24 (N.C. Aug. 14, 2026), the Supreme Court held the Habitual Felons Act does not prohibit the State from filing an habitual felon indictment before the principal felony indictment. In State v. Moore, No. 285A24 (N.C. Aug. 14, 2026), the Supreme Court found sufficient evidence of restraint beyond that inherent in an associated murder to support a conviction for kidnapping. And in State v. Cuadra, No. COA25-863 (N.C. Ct. App. Aug. 19, 2026), the Court of Appeals concluded the trial court erred by granting the defendant's mid-trial motion to dismiss charges.

What is Turning State's?

Turning State's is a podcast for North Carolina prosecutors and others interested in the criminal justice system in North Carolina. It is hosted by Joseph L. Hyde, prosecutor advisor with the University of North Carolina School of Government, and Jonathan Holbrook, director of training with the North Carolina Conference of District Attorneys. The podcast follows the format of a case update. Each episode features Hyde and Holbrook discussing a few criminal cases recently decided by North Carolina appellate courts. Listeners can expect to stay up to date on relevant criminal caselaw and receive expert advice on how this caselaw can inform and advance other prosecutions.

Turning State's is produced in the recording studio at the University of North Carolina School of Government. The podcast is a collaboration between the School of Government and the Conference of District Attorneys.