State v. Patterson

In State v. Patterson, 335 N.C. 437, 454, 439 S.E.2d 578, 588 (1994), the Supreme Court of North Carolina held the State failed to comply with the discovery statutes by not disclosing some of the statements defendant made while responding to police questioning that were later introduced as evidence at trial. However, the trial court's error in admitting the testimony was harmless error. The Court pointed out that defendant could not have been unfairly surprised by the same testimony defendant had elicited himself from another witness. Id., 335 N.C. at 455-56, 439 S.E.2d at 589.