State v. Shelman

Police arrested David Shelman and Cesar Rivera (defendants) after observing the two men transporting a parcel that, due to the parcel’s prior interception by postal inspectors, was known to contain 1,700 grams of illegal methamphetamine (meth). While in police custody, Shelman admitted having known that the parcel contained meth and that Rivera was a meth trafficker. Shelman and Rivera were charged with knowingly possessing meth and trafficking the meth in a quantity of at least 28 grams. Rivera pleaded guilty in return for a light sentence. Near the beginning of Shelman’s trial, the court ruled that Shelman failed to establish a prima facie Batson challenge to the state’s peremptory juror strikes. During the trial, the court admitted the meth parcel seized at the time of Shelman’s arrest into evidence. Near the trial’s end, the court instructed the jury on the law regarding defendant confessions. Shelman was found guilty and given the statutory minimum penalty. Shelman based his appeal to the North Carolina Court of Appeals on five arguments: (1) the meth parcel’s chain of custody was so weak as to make the parcel inadmissible as evidence; (2) prosecutors failed to prove Shelman’s knowing possession of at least 28 grams of meth; (3) the trial court erred in dismissing Shelman’s Batson challenge; (4) the trial court’s confession instruction was improper because Shelman’s police statement did not admit the elements of the charged offense; and (5) Shelman’s sentence was unconstitutionally severe and disproportionate to Rivera’s relatively light sentence.