State v. King

WHICHARD, Judge.

Defendant contends the court erred in refusing his request for a voir dire to “qualify” an identification witness.

The general rule in this State is that the failure ... to hold a voir dire examination and make findings of fact upon objection by a defendant to an in-court identification, while not approved, will be deemed harmless error where the record shows that the pretrial identification was proper or that the in-court identification of defendant had an origin independent from the pretrial identification.

State v. Jordan, 49 N.C. App. 561, 565, 272 S.E. 2d 405, 408 (1980).…