Criminal Practice – Juvenile – Self-Incrimination – Failure to Warn – Harmless Error

In re J.R.V. (Lawyers Weekly No. 12-06-0108, 1 p.) (Per Curiam) Appealed from Rockingham & Stokes Counties District Courts. (James A Grogan & William F. Southern, JJ.) On discretionary review from the Court of Appeals. N.C. S. Ct. Click here for full-text opinion.

Holding: Where our Court of Appeals held, Even though, before the juvenile testified, the trial court failed to warn him of his privilege against self-incrimination, the error was harmless. The juvenile’s testimony echoed that of the state’s witness in some respects; otherwise, it was exculpatory,” discretionary review was improvidently allowed.