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NC Supreme Court Divided on Juror Substitution Law Ruling

North Carolina Supreme Court Upholds Juror Substitution Law

RALEIGH—In a significant ruling on Friday, the North Carolina Supreme Court upheld a state law allowing for the substitution of jurors after deliberations have commenced, reversing a previous unanimous decision by the state Appeals Court.

The landmark decision impacts the case of Eric Ramond Chambers, sentenced in 2022 to life without parole for first-degree murder stemming from a fatal shooting at a Raleigh motel. Chambers’ lawyers argued against the inclusion of a substitute juror who replaced a juror after just 30 minutes of deliberation. The 12-member jury, now with the substitute, deliberated for approximately three hours before returning a guilty verdict.

Chief Justice Paul Newby, writing for the majority, affirmed that the law does not violate North Carolina’s constitutional requirement for a unanimous jury of twelve. He noted that the statute mandates juries to restart their deliberations when a juror is substituted, thus protecting the integrity of the twelve-member requirement.

Originally enacted in 1977, the law allowed juror substitutions only before jury deliberations began but was amended in 2021 to permit changes at any time before a verdict is rendered. The Supreme Court’s majority emphasized that the trial judge appropriately instructed the jury to disregard prior deliberations and begin anew with the twelve jurors present.

In dissent, Justices Allison Riggs and her colleague voiced concerns over the constitutionality of the law, arguing that the brief participation of the original juror could sway the deliberations of the substitute juror. Riggs expressed that allowing a juror substitution after deliberations start undermines the foundational right to a unanimous verdict.

This ruling marks a pivotal moment for juror rights and procedural regulations in North Carolina’s judicial system.

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