In a January 2026 unpublished opinion, the North Carolina Court of Appeals affirmed a first-degree murder conviction in State v. Terrance Lamont Williams, No. COA24-838. The case raises important questions for criminal defense: When can law enforcement officers identify a defendant in surveillance footage? What happens when an immunized witness refuses to testify? And how do recorded jail calls factor into a prosecution? The answers have real consequences for anyone facing serious charges in North Carolina.
Background: The Shooting of Shakur Hedgebeth
The case arose from the fatal shooting of Shakur Hedgebeth on August 21, 2019, outside Carol’s Variety Shop in Plymouth, North Carolina. Terrance Williams, known to his friend group as “T,” had grown up alongside Hedgebeth. Surveillance footage captured a man chasing Hedgebeth with a gun; Hedgebeth was found shot five times in the back. At trial, the State’s case rested on the surveillance footage, testimony from four officers who identified Williams in the video, phone records connecting Williams to co-defendant Jahmal James, statements Williams made from jail, and testimony from a fellow inmate that Williams admitted to the killing. The jury convicted Williams of first-degree murder, and the trial court sentenced him to life without the possibility of parole.
Can Police Officers Identify a Defendant in Grainy Surveillance Footage?
One of the most significant issues was whether four law enforcement officers could properly offer lay opinion testimony identifying Williams in the footage. Defense counsel argued the video was too grainy for reliable identification, and that having four officers testify to the same point was needlessly cumulative and unfairly prejudicial.
The Court of Appeals disagreed, relying on State v. Belk and Rule of Evidence 701. Under that rule, a lay witness may offer identification opinion testimony if it is rationally based on the witness’s own perception and helpful to the jury. Critically, lay identification testimony is more likely admissible when footage is grainy or of poor quality—when the jury cannot clearly see the subject, an officer with twenty years of familiarity with the defendant becomes uniquely positioned to make the identification. Chief Williams had known Williams for roughly twenty years; Investigator Spence had observed him nearly fifty times.
The court also rejected the cumulativeness argument. Because each officer knew Williams for different durations and under different circumstances, each contributed independent evidentiary value. Defense lawyers facing this type of evidence must challenge the foundation of each officer’s claimed familiarity with the defendant—not simply argue the footage was unclear.
The Fifth Amendment Problem: When a Witness Refuses to Testify
A separate issue arose with witness Walter Phelps, who had also fired a gun outside the shop. Phelps appeared under a material witness order and had been granted immunity, meaning he had no valid Fifth Amendment right to refuse to testify. Despite this, he invoked the Fifth Amendment when asked whether he knew the defendant and refused all further questions. The trial court held him in contempt and removed him before the defense could cross-examine him.
The Court of Appeals found no error. Because Phelps had immunity, the court reasoned that neither the State nor the trial court could have anticipated his refusal—so allowing him to take the stand was not an abuse of discretion. On the confrontation issue, the court drew a key distinction: if a witness refuses to answer questions about collateral matters, prejudice is minimal; but if the refusal goes to the substance of the direct testimony, the witness’s testimony may need to be stricken. Here, Phelps had only testified that he and Hedgebeth were close—nothing about the crime—so there was no basis to strike. For more on confrontation clause issues in North Carolina, see our earlier analysis of State v. Clark and the Confrontation Clause.
Jail Phone Calls and Phone Records as Evidence
The case also illustrates how thoroughly prosecutors use digital evidence and recorded jail communications. Records from phones found in James’ car showed that a contact named “T” called and texted James repeatedly on the day of the murder, and that those call records had been deleted—evidence the State used to imply consciousness of guilt. Williams also made calls from jail in October 2023, weeks before trial, commenting on the surveillance footage and the broken phone found at his home. The court found those statements relevant as evidence of his awareness of the case against him.
Every call from a jail or detention facility is recorded and may be used at trial. Statements that seem innocuous—even a vague reference to evidence—can support theories about consciousness of guilt or disposal of evidence. Anyone in custody should consult their attorney before making any statements by phone.
What This Case Means for North Carolina Murder Defense
The Williams decision reinforces several realities about how first-degree murder cases are tried in North Carolina today. Surveillance footage, even when grainy, can be a powerful State tool when law enforcement officers who know the defendant are permitted to identify him on the stand. Phone records, deleted or not, can be reconstructed. And jail calls are a constant risk that defendants in custody must take seriously.
A successful defense requires challenging the reliability of each identification, attacking the interpretation of digital evidence, scrutinizing witness testimony for confrontation clause issues, and moving to exclude improperly authenticated evidence. The overlapping issues in Williams show why experienced North Carolina criminal defense representation is critical from the earliest stages of an investigation. You can also read more about serious criminal sentencing in North Carolina and the role mental health evaluations can play in these proceedings.
If you or someone you know is facing murder charges or a serious violent crime investigation, contact The Chetson Firm for a consultation. Damon Chetson is a Board Certified Specialist in State and Federal Criminal Law—one of fewer than 100 attorneys in North Carolina to hold that distinction—with more than 25 jury trials and a record of results in complex criminal cases. Call 919-352-9411 or reach us online.