Greene v. North Carolina

How later courts describe this case

• heinous, atrocious, or cruel; previous conviction of a violent felony; or course of conduct aggravating circumstance(s) found in thirty-six of thirty-seven “death-affirmed” cases
• where statement was elicited by defense counsel on cross-examination and admitted without objection, “[a]ny error thus was invited and defendant cannot complain of such error on appeal”
• common benefit theory unavailable to plaintiffs awarded damages only
• record established that ex parte communications were not prejudicial
• applying harmless error analysis to defendant's statement