North Carolina General Statute 15a-1340.16(A)
Under North Carolina General Statute section 15A-1340.16(a), "the court shall consider evidence of aggravating or mitigating factors present in the offense that make an aggravated or mitigated sentence appropriate . . . . the State bears the burden of proving by a preponderance of the evidence that an aggravating factor exists . . . ." N.C. Gen. Stat. 15A-1340.16(a) (1999).
In State v. Thompson, 328 N.C. 477, 402 S.E.2d 386 (1991), our Supreme Court held that there was no error in the trial court's finding as a nonstatutory aggravating factor that the crimes were planned where such findings were based on "extraordinary planning . . . which exceeded that which is ordinarily present or inherent in the crime." Id. at 493, 402 S.E.2d at 395;
See also State v. Chatman, 308 N.C. 169, 180, 301 S.E.2d 71, 77 (1983) ("We reject defendant's position that in order to find that the offense was planned it was necessary to show that defendant methodically surveyed . . . houses or carefully chose a particular night before entering.").