State of North Carolina v. Brian Alexander Scott

Summary

The North Carolina Supreme Court reversed the Court of Appeals, holding that the proper standard of review for a post‑verdict motion to dismiss for insufficiency of the evidence is the substantial‑evidence test articulated in State v. Powell, not the beyond‑reasonable‑doubt standard, and that under that standard the evidence was sufficient to support the jury’s guilty verdict on habitual DWI. The case was remanded for sentencing on the habitual DWI charge.