N.C.G.S. 15a-2000(E)(3) Interpretation
In State v. Wiley, 355 N.C. 592, 565 S.E.2d 22 (2002), cert. denied, 537 U.S. 1117, 123 S. Ct. 882, 154 L. Ed. 2d 795 (2003), the Supreme Court of North Carolina held that the admission of a juvenile adjudication as an aggravating circumstance under N.C.G.S. 15A-2000(e)(3) did not violate constitutional prohibitions against ex post facto laws even though the defendant's juvenile adjudication predated the amendment to N.C.G.S. 15A-2000(e)(3) that allowed for the submission of such juvenile adjudications. Id. at 624-27, 565 S.E.2d at 44-46.
Thus, pursuant to Wiley and N.C.G.S. 15A-2000(e)(3), the State may admit certain prior juvenile adjudications as aggravating circumstances.