North Carolina Supreme Court Remands Case for a New Trial to Determine Whether Defendant Killed His Grandfather, Relying on Testimony from Mother with Brain Injury

Above: Defendant Jeff Steen at trial — Image Source: Salisbury Post

On December 18, 2020, the North Carolina Supreme Court reversed in part the decision of an appeals court and remanded Jeff David Steen’s case for a new trial to determine if he was guilty of killing his grandfather. During trial, the testimony of his mother, who was attacked at the same time and suffered from a brain injury, was a key piece of evidence against Steen.

Steen was convicted of the 2013 first-degree felony murder of his grandfather and the attempted murder of his mother with a deadly weapon. The events of the attack are disputed; Steen was at his mother’s house with his grandfather prior to the attack and claims that he returned to the house later that evening to find his mother badly injured and his grandfather dead. The state claims that Steen was the attacker.

Steen’s grandfather died from blunt force injuries to the head and neck, which could have been inflicted using a garden hoe found next to his body. Steen’s mother survived the attack but was diagnosed with “a skull fracture, hemorrhaging of the brain, a mild traumatic brain injury, hypothermia, a cervical neck injury, a collapsed lung, multiple rib fractures, and facial trauma.”

Steen’s mother’s memory was the subject of debate. At the hospital on the day following the attack, she told investigators that Steen was not her attacker because she had seen him leaving before she remembered being attacked. However, after talking with a traumatic brain injury counselor, Steen’s mother then testified at trial that Steen had attacked her and that she “had been dreaming all kind of crazy dreams laying up there in ICU.” She said that “she had had difficulty remembering specific details about the assault as a result of the brain injury that she had sustained.”

Steen was found guilty of the attempted murder of his mother and the first-degree murder of his grandfather. He was sentenced to life without the possibility of parole. He appealed, and the appeals court rejected his arguments and affirmed the judgement of the trial court. The North Carolina Supreme Court allowed Steen’s petition seeking discretionary review.

On appeal, the Supreme Court was “asked to resolve the questions of whether an adult’s hands and arms can ever qualify as a deadly weapon” and “whether the trial court’s erroneous jury instruction that the jury could find that defendant attempted to murder his mother using a garden hoe as a deadly weapon prejudiced defendant’s chances for a more favorable outcome at trial.” The Supreme Court partially agreed with Steen’s claims and remanded the case for a new trial to determine the issue of Steen’s guilt of the murder of his grandfather.

One judge dissented in part, stating that “[t]he real issue at trial was the identity of the perpetrator, not which weapon caused which of the injuries” and that when the jury found Steen guilty, it found the testimony of his mother to be credible. Thus, the specifics of the weapons used would not have changed the jury’s verdict, and Steen’s convictions should be upheld.

Key words: North Carolina, brain injury, memory

Citation: State v. Steen, 852 S.E.2d 14 (2020)

This post is the 58th post as part of an ongoing Center for Law, Brain & Behavior (CLBB) series tracking the latest developments in law and neuroscience cases. To see previous posts about recent cases, see the full case archive on the CLBB website. To see updates on legal scholarship, see the Neurolaw News, hosted by the MacArthur Foundation Research Network on Law and Neuroscience. This project is made possible through support of the Dana Foundation.

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