The North Carolina Supreme Court issued a decision Thursday in *State v. Allison*, addressing the proper application of the state's castle doctrine law in a case where a homeowner fatally shot a man standing in his doorway. The case centers on whether the jury received adequate instruction on North Carolina's castle doctrine statute, N.C.G.S. § 14-51.2, following George Lee Allison's conviction for second-degree murder.
Allison was convicted by a Burke County jury for the December 13, 2020 shooting death of Brandon Adams and sentenced to 144 to 185 months in prison. The shooting occurred while Adams was standing in the doorway outside Allison's residence, raising questions about the boundaries of self-defense protections under North Carolina law.
According to trial testimony, the events leading to the fatal shooting began with a domestic dispute between Adams and his girlfriend, Pamela Rodgers. After an argument, Adams told Rodgers he was going to Allison's home. When Adams returned, Rodgers accused him of cheating and demanded to go to Allison's house to verify his whereabouts.
Rodgers drove to Allison's home, where he confirmed Adams had been there. The two began drinking bourbon, and Rodgers told Allison that Adams was physically abusive toward her. Allison advised Rodgers to leave and "go somewhere away from [Adams] if that's the case."
Later that evening, Adams arrived at Allison's home, and Allison invited him inside. Once inside, Adams "started pointing at" Rodgers, causing her to flinch and "physically draw back" each time he pointed. After several minutes of this behavior, Allison asked Adams to leave.
As Adams walked toward the door, he rammed his shoulder into Allison's shoulder. The confrontation escalated from there, ultimately resulting in Allison shooting Adams while Adams was positioned in the doorway of the residence.
The case proceeded through multiple levels of the North Carolina court system. Superior Court Judge Jacqueline D. Grant presided over the original trial in Burke County, where Allison was convicted on October 28, 2022. The North Carolina Court of Appeals reviewed the case and issued a unanimous, unpublished decision on March 19, 2024, finding no error in the trial court's proceedings.
Allison sought discretionary review from the North Carolina Supreme Court under N.C.G.S. § 7A-31. The high court heard oral arguments on April 22, 2025, and issued its decision on December 12, 2025.
The central legal question before the Supreme Court was whether the trial jury received proper instruction regarding North Carolina's castle doctrine law. The castle doctrine, codified in N.C.G.S. § 14-51.2, provides legal protections for individuals who use force to defend themselves in their homes under certain circumstances.
The castle doctrine represents a significant expansion of traditional self-defense law by removing the duty to retreat when a person is in their own home and faces an imminent threat. The doctrine typically allows homeowners to use reasonable force, including deadly force in some circumstances, to protect themselves and their property from intruders.
However, the application of castle doctrine protections can be complex, particularly in cases involving the physical boundaries of where the protection applies. The fact that Adams was shot while standing in the doorway, rather than clearly inside or outside the home, likely contributed to the legal complexity of properly instructing the jury on the applicable law.
Justice Berger authored the Supreme Court's opinion in the case. The court's review focused specifically on whether the jury instruction adequately conveyed the legal standards established by the legislature in the castle doctrine statute.
The case was argued by Craig M. Cooley representing Allison and Michael T. Henry, Special Deputy Attorney General, representing the state under Attorney General Jeff Jackson.
The decision comes as courts across the country grapple with the proper application of castle doctrine and stand-your-ground laws, which have been enacted in various forms by numerous states. These laws generally expand the circumstances under which individuals may use force in self-defense without facing criminal liability.
The Supreme Court's ruling in *Allison* will provide guidance to trial courts throughout North Carolina on how to properly instruct juries when castle doctrine defenses are raised. The decision may also influence how prosecutors and defense attorneys approach cases involving the use of force in residential settings.
The outcome of this case could affect future prosecutions and defenses in similar circumstances, particularly cases involving the use of deadly force at the threshold areas of homes where the boundaries of castle doctrine protection may be less clear.
Legal experts will closely analyze the court's reasoning to understand how North Carolina's highest court interprets the scope and application of the state's castle doctrine statute in situations involving complex factual scenarios at the boundaries of traditional self-defense law.