This Note will examine the court's decision in State v. Scott. First, the Note will address the facts of the case. Second, it will set out the background on how courts decide whether evidence of this nature should be admitted, mainly focusing on Rules 403 and 404(b) of the North Carolina Rules of Evidence. Next, the Note will analyze how the court arrived at this "bright-line" rule as well as the effect it will have in future cases. Finally, the Note will conclude that even though North Carolina adopted the "minority rule", this approach is proper under the concept of fundamental fairness and the constitutional parameters that underlie the court's decision.
Matthew S. Sullivan, The Admissibility of Prior Acquittal Evidence - Has North Carolina Adopted the "Minority View?" - The Effect of State v. Scott, 16 Campbell L. Rev. 231 (1994).