Request for Jury Instruction–Vicarious Liability with Regard to N.C. Gen. Stat. 15A-2000(e)(9)
Request for Jury Instruction–Residual Mitigating Circumstances
Request for Jury Instruction–Residual Doubt
Request for Jury Instruction–Life Without Parole (II)
Request for Jury Instruction–Life Without Parole (I)
Request for Jury Instruction Re Sympathy and Mercy
Request for Jury Instruction on Personal Viewpoints
Request for Jury Instruction Definition of Mitigating Circumstance
Objection to Use of NCGS 15A-2000e9 (vague & broad)
Objection to Use of NCGS 15A-2000e5 (fairness, double jeopardy, cruel & unusal)
Motion to Restrict Prosecutor’s Argument
Motion to Preclude State from Using any Juvenile Conviction as an Aggravating Factor
Motion to Instruct the Jury on Age as a Statutory Mitigating Factor
Motion to Instruct Jury on Satisfactory Prison Adjustment
Motion to Instruct Jury on Evidence of Low I.Q.
Motion to Instruct Jury on Emotionally Troubled Youth as a Mitigating Circumstance
Motion to Instruct Jury On Defendant’s Burden of Proof On Mitigating Circumstances
Motion for Peremptory Instructions on Mitigating Circumstances
Motion for Jury Instruction under Enmund v. Florida and Tison v. Arizona
Motion for Court to Give Understandable Jury Instructions
Jury Instructions. Penalty Phase Revised 3-2000 Version
Discretion in Capital Sentencing Instructions
Motion to Limit Victim-Impact Evidence