Episode 43: Phelps, Metcalf, and Tyson

In this episode, Hyde and Holbrook discuss three cases decided by the North Carolina Court of Appeals on June 3, 2026. In State v. Phelps, No. COA25-934 (N.C. Ct. App. June 3, 2026), the Court of Appeals ruled that simultaneous possession of multiple weapons constitutes a single instance of possession of a weapon of mass death and destruction. In State v. Metcalf, No. COA25-624 (N.C. Ct. App. June 3, 2026), the Court of Appeals found that repeated unanswered phone calls in violation of a DVPO constitutes felony stalking. And in State v. Tyson, No. COA25-604 (N.C. Ct. App. June 3, 2026), the Court of Appeals held that sexual exploitation of a minor by solicitation does not require that the material solicited actually exist.