## Facts

- Meredith Mark Peaks was shot and killed in Winston-Salem, North Carolina.
- The State’s principal witness, Eric Shaw, testified that he sold cocaine for Ernest King and described King as running a drug distribution operation.
- Shaw testified that Peaks had recently robbed one of King’s drug dealers, and that King reacted by saying no one would take from him.
- Shaw testified King threatened Peaks, stating he would make Peaks “a ghost.”
- Shaw gave eyewitness testimony that he saw King shoot and kill Peaks.
- The defense objected to extensive testimony about King’s drug activities, arguing it was improper character/propensity evidence and unfairly prejudicial.

## Issues

1. Whether testimony describing King’s drug-trafficking activities was inadmissible propensity evidence under Rule 404(b), or admissible to prove motive, intent, or context for the killing.
2. Whether King’s alleged threats and related statements were inadmissible hearsay or otherwise improperly admitted.
3. Whether the combined effect of the challenged evidentiary rulings created unfair prejudice requiring a new trial.

## Decision

- The North Carolina Supreme Court affirmed the conviction and life sentence.
- The court held the drug-activity evidence was properly admitted to show motive, intent, and the chain of circumstances explaining the events leading to the homicide, and was not excluded by Rule 403.
- The court held the threat evidence (including “make Peaks a ghost”) was admissible as King’s own statements and probative of premeditation and deliberation.
- The court rejected a cumulative-prejudice claim, finding no abuse of discretion and concluding the defendant received a fair trial.

## Legal Principles

- Other-acts evidence is admissible when it tends to prove a fact in issue other than character (including motive, intent, or context), even if it reflects other criminal conduct.
- Evidence explaining the relationship among participants and the circumstances leading to the charged offense may be admitted as part of the chain of circumstances supporting the State’s theory of the case.
- A defendant’s pre-offense statements and threats toward the victim are admissible as statements of a party-opponent and may be used to prove malice, premeditation, and deliberation.
- Trial courts have broad discretion under Rules 403 and 404(b); appellate reversal requires a showing of abuse of discretion and resulting unfair prejudice.
- Multiple evidentiary rulings do not warrant reversal absent a showing that their combined effect denied the defendant a fair trial.

## Conclusion

The court upheld King’s first-degree murder conviction, ruling that detailed drug-operation testimony was admissible to explain motive and context for the killing, that King’s threats were admissible and strongly probative of premeditation, and that the challenged rulings—individually and collectively—did not amount to reversible unfair prejudice.


State v. King, 343 N.C. 29, 468 S.E.2d 232 (N.C. 1996)