State v. Bracey: Inferring Knowledge of a Stolen Firearm from Flight, Concealment, and Deception under North Carolina’s Substantial Evidence Standard

I. Introduction

The Supreme Court of North Carolina’s decision in State v. Bracey, No. 32A25 (Dec. 12, 2025), squarely addresses a recurring evidentiary problem in property and weapons prosecutions: when does circumstantial evidence suffice to show that a defendant “knew or had reasonable grounds to believe” a firearm in his possession was stolen?

The defendant, Mack Vernon Bracey, a convicted felon, was apprehended after a prolonged and extraordinarily dangerous flight from police. Officers later discovered a loaded .38 Special revolver hidden behind a steering-column panel in his vehicle, along with .38 Special ammunition in his hotel room. The weapon had been reported stolen. At trial, Bracey moved to dismiss the charge of possession of a stolen firearm for insufficient evidence on the “knowledge” element. The trial court denied the motion; the Court of Appeals, in a divided decision, affirmed. The Supreme Court granted review based on the dissent in the Court of Appeals.

The question before the Court was narrow but significant: whether the evidence—primarily Bracey’s extreme flight, his concealment of the weapon (but not its holster), and his lie denying the gun’s existence—constituted “substantial evidence” from which a rational juror could find that he knew or had reasonable grounds to believe the gun was stolen. The majority answered “yes” and affirmed. Justice Earls, joined by Justice Riggs, dissented.

The case thus functions as a clarifying precedent at the intersection of three doctrinal areas:

• The standard for ruling on motions to dismiss for insufficient evidence (the “substantial evidence” test);
• The evidentiary meaning of flight, concealment, and deception as proof of “consciousness of guilt” and, more specifically, knowledge that property is stolen;
• The limits on considering alternative, equally plausible explanations for a defendant’s behavior—especially when the same conduct could reflect guilt of several different crimes.

II. Summary of the Opinion

A. The Majority’s Holding

Justice Barringer, writing for the Court, affirmed Bracey’s conviction for possession of a stolen firearm. The Court held that:

1. The State presented “substantial evidence” of each element of felony possession of a stolen firearm, and only the knowledge element was at issue on appeal.
2. Evidence that Bracey:
   • engaged in a prolonged, extremely dangerous flight by car and on foot;
   • hid the gun behind a steering-wheel panel rather than in ordinary storage spaces;
   • left the holster in plain view but concealed only the gun; and
   • lied to officers, denying that a gun existed;
   when viewed in the light most favorable to the State, constitutes substantial evidence from which a rational juror could find that Bracey knew or had reasonable grounds to believe the firearm was stolen.
3. Alternative explanations for Bracey’s behavior (e.g., that he fled and hid the gun solely to avoid a felon-in-possession charge) are not to be considered at the motion to dismiss stage because they are not “favorable to the State.”
4. The “substantial evidence” standard equates to “more than a scintilla of evidence,” and courts may draw “inferences on inferences” in favor of the State when determining sufficiency.

The Court explicitly rejected the Court of Appeals dissent’s proposition that “substantial evidence that a defendant is guilty of some crime is not substantial evidence that he committed a particular crime.” It held instead that where the same evidence can rationally support elements of multiple offenses, sufficiency is satisfied for each.

B. The Dissent’s Position

Justice Earls dissented, arguing that:

• The evidence did not rise above “suspicion or conjecture” that Bracey knew the gun was stolen, as opposed to merely knowing he illegally possessed a gun as a felon.
• Past cases upholding knowledge-of-stolen-property findings involved a clear transactional irregularity or conduct closely tied to the stolen nature of the item (e.g., extremely low sale price, removed serial number, or attempts to dispose of the item during flight).
• Here, there was:
  • no evidence how Bracey acquired the gun;
  • no obliteration of the serial number;
  • no attempt to throw away or dispose of the gun during the chase;
  • no forensic evidence tying him to the gun; and
  • only a hidden weapon and a holster left in the car.
• The majority improperly “stacks inference upon inference,” contrary to precedents warning that inferences must rest on “clear or direct evidence,” not upon other inferences.

Justice Earls would have reversed, holding that the State failed to produce substantial evidence that Bracey knew or had reasonable grounds to believe the firearm was stolen, and that his motion to dismiss should have been granted.

III. Detailed Analysis

A. The Substantial Evidence Standard Reaffirmed and Sharpened

The Court devotes a significant portion of its opinion to rearticulating the North Carolina standard for motions to dismiss for insufficient evidence in criminal cases. This is not new law, but the Court draws together and emphatically reasserts several key points.

1. “Substantial Evidence” = “More Than a Scintilla”

Relying on decisions such as State v. Earnhardt, State v. Powell, and State v. Gillard, the Court reiterates:

• “Substantial evidence” is evidence that is “existing and real, not just seeming or imaginary.”
• Functionally, it requires only “more than a scintilla of evidence” for each element of the offense.
• The question is whether the evidence could “persuade a rational juror” of guilt, not whether it does or must.

The majority quotes State v. Fritsch to stress that the trial court should be concerned only with whether the evidence is sufficient for jury consideration—not with its weight or credibility.

2. Viewing Evidence “in the Light Most Favorable to the State”

The Court reinforces the long-standing rule of State v. Barnes:

• The judge must view the evidence in the light most favorable to the State.
• The State is entitled to every reasonable inference that can be drawn from the evidence.
• Contradictions or discrepancies in the proof are for the jury, not the court, to resolve.

This orientation is critical in Bracey, because the same conduct (flight, concealment) can plausibly be interpreted in multiple ways. The majority insists that, at the sufficiency stage, courts must choose the inferences favorable to the State, leaving alternative inferences to be argued to the jury.

3. “Inferences on Inferences” Are Permissible

The Court cites State v. Dover and State v. Childress for the proposition that it is “appropriate” to make “inferences on inferences,” since that is “the way people often reason in everyday life.” The Court also repeats that:

• Circumstantial evidence need not “rule out every hypothesis of innocence.”
• The State is not required to eliminate “every hypothesis” for why a defendant acted as he did.

This is an important doctrinal move, because the dissent later invokes an older line of cases (Voncannon, Maines) warning that mere inference-upon-inference is impermissible. Here, the majority implicitly aligns North Carolina with the modern view that “stacking” reasonable inferences is allowed as long as each inference is grounded in some piece of evidence and yields a reasonable overall chain of reasoning.

4. Excluding Evidence “Not Favorable to the State” at the Dismissal Stage

The Court leans on State v. Tucker to underscore that when deciding a motion to dismiss:

• The court cannot weigh the evidence.
• The court may not consider evidence “that is not favorable to the State.”
• Alternative explanations of the defendant’s conduct, including those that portray the defendant as innocent or guilty of different crimes, are for the jury, not the judge.

Applying this to Bracey, the Court holds that it was improper to rely on the possibility that he fled merely to avoid a felon-in-possession charge. That alternative hypothesis, though plausible, is not “favorable to the State” and therefore is irrelevant at the motion-to-dismiss phase.

B. The Knowledge Element in Possession of Stolen Firearms

The governing statutory framework is N.C.G.S. §§ 14‑71.1 and 14‑72(b)(4), (c), interpreted by State v. Davis. To convict for felony possession of a stolen firearm, the State must prove:

1. The property was stolen;
2. The property was a firearm;
3. The defendant possessed it;
4. The possession was with a dishonest purpose; and
5. At the time of possession, the defendant knew or had reasonable grounds to believe the firearm was stolen.

Only element (5)—knowledge or reasonable grounds to believe—was contested in the Supreme Court.

Historically, North Carolina courts have found this element satisfied by:

• Transactional irregularities (e.g., a very low price, missing title, or unusual circumstances): see State v. Parker (sale of a nearly new sports car for $800 without title, in a motel parking lot).
• Efforts to dispose of the property when confronted: e.g., State v. Taylor (defendant tried to hide/throw away a gun when challenged by a pedestrian); State v. Wilson (defendant instructed accomplice to throw a gun out of a car while fleeing police).
• Alteration of identifying features: e.g., State v. Walker, where the serial number on a gun was removed, rendering it untraceable.
• Concealing multiple stolen items together: e.g., State v. Friend, where a cache of varied stolen goods hidden in a single location permitted an inference that the defendant knew (or had reason to know) each item was stolen.

In Bracey, by contrast, there was:

• No evidence of the circumstances under which Bracey acquired the gun;
• No obliteration of serial numbers (indeed, the serial number was intact and visible);
• No direct attempt to discard the gun when officers first approached or during the chase (the hiding apparently predated or at least was not observed during the flight); and
• No forensic analysis tying him to the weapon (no fingerprints, no DNA).

The majority therefore relies entirely on posture and behavior—flight, concealment, and denial—to draw the inference that Bracey had the requisite knowledge or at least “reasonable grounds to believe” the gun was stolen. That is the key doctrinal move in this case.

C. Evidence Relied on by the Majority: Flight, Concealment, and Lies

1. Flight as Consciousness of Guilt

The Court reaffirms the well-entrenched principle from State v. Parker (and many other cases) that:

“An accused’s flight is evidence of consciousness of guilt and therefore of guilt itself.”

Several points are salient in the Court’s analysis:

• The intensity and nature of flight matters. Citing State v. Jones, the Court notes that the “degree or nature of the flight is of great importance” in evaluating its probative force.
• Here, Bracey:
  • refused to exit his vehicle when ordered;
  • drove at extremely high speeds (up to 100 mph) through residential and commercial areas;
  • ran red lights and stop signs, swerved into oncoming traffic, and evaded roadblocks;
  • crashed his car into trees; and
  • fled into a swamp, stopping only when he was physically forced to by dense brush.
  The Court characterizes this as a “spirited” and extremely dangerous attempt to evade capture.
• Even though Bracey had multiple possible reasons to flee—including his status as a felon in possession of a firearm—the Court holds that the mere presence of other plausible motives does not diminish the State’s entitlement to use his flight as evidence of knowledge that the gun was stolen.

Crucially, the Court invokes State v. Winkler and State v. Tucker to insist that the existence of other plausible explanations for flight is legally irrelevant at the dismissal stage. So long as one reasonable inference is that the defendant fled because he knew the gun was stolen, the “substantial evidence” threshold is met.

2. Concealment of the Weapon

The majority finds independent probative value in the manner of storage:

• Rather than in conventional “storage” areas of the car (glove box, center console, door pockets, trunk), the gun was found:
  • behind a “little loose looking” panel to the left of the steering wheel;
  • in an “empty space” accessible only by dislodging the panel;
  • with the panel easily “popped open” from the front.
• The Court contrasts this with ordinary storage like a “bedroom closet,” and likens it instead to “stashing an item in one of the room’s air vents and replacing the grille.”

This characterization serves two functions:

1. It rebuts the Court of Appeals dissent’s reliance on State v. Wilson (2010) (a later Court of Appeals case discussing a shotgun in a closet) as showing that “mere storage” does not evidence knowledge of theft.
2. It elevates the concealment from ordinary storage to affirmative hiding, which the Court treats as a marker not merely of generic criminal consciousness of guilt, but of awareness that the gun itself was particularly incriminating.

3. Lying About the Gun and the Unhidden Holster

The Court also emphasizes two additional data points:

• Bracey’s denial: When confronted with Officer Jackson’s “trick question” (“We found the gun. . . . In the woods where you tossed it.”), Bracey responded, “Oh. There ain’t no gun.” The Court considers this a straight lie about the gun’s existence.
• The holster: Officers saw an empty Sticky-brand holster in the car near the driver’s seat. The holster was not hidden. Only the gun was hidden.

From this, the majority draws a nuanced inference:

• If Bracey were simply trying to avoid a felon-in-possession charge, it would make sense to hide both the gun and the holster, because the holster is a highly visible indicator of firearm possession.
• Because he hid only the gun but left the holster in plain view, a rational juror could infer that Bracey regarded the gun itself (not the holster) as especially incriminating—consistent with knowledge that it was stolen.

That is the precise point the dissent labels impermissible “stacking inference upon inference.” The majority, by contrast, treats it as an ordinary, reasonable inference grounded in common-sense reasoning about what a person seeking to conceal simple illegal possession of a firearm would do.

4. The Felon-in-Possession Context as an Additional Inference

In a footnote, the Court adds another layer:

• Because Bracey was a convicted felon, he could not lawfully obtain a firearm under 18 U.S.C. § 922(d)(1).
• A rational juror could infer that anyone willing to supply a gun to a known felon is likely operating illegally and may well have obtained the gun illegally—such as by theft.
• When combined with Bracey’s flight and concealment, this background illegality increases the plausibility that he knew, or at least had reasonable grounds to believe, that the weapon was stolen.

This is subtle but significant. The Court is not saying felon status alone proves knowledge; rather, it uses the inherent illegality of the transaction to inch closer to the knowledge requirement by making a stolen origin more probable.

D. Multiple Offenses and the Use of Common Evidence

A major point of contention between the majority and the Court of Appeals dissent (and echoed by Justice Earls) is how to handle evidence that equally supports multiple possible crimes.

The Court of Appeals dissent argued that where a defendant reasonably appears guilty of some crime, that does not automatically translate into substantial evidence that he committed this particular crime. For example, Bracey’s flight and concealment might clearly show guilt as a felon in possession of a firearm, but it does not necessarily prove knowledge that the firearm was stolen.

The Supreme Court rejects that framing as “an incorrect statement of law.” Drawing on State v. Ambriz, it stresses:

• If the same substantial evidence supports elements of more than one offense, that is not a reason to dismiss any of those charges.
• In the Court’s hypothetical: a defendant with two stolen laptops in his backpack who flees from police. A rational jury could view his flight as evidence that he knew or had reason to believe that each laptop was stolen.

Applied here, the majority holds that:

• Bracey’s flight and concealment can simultaneously support:
  • the felon-in-possession charge, and
  • the possession-of-stolen-firearm charge, including its knowledge element.
• The fact that the evidence fits more neatly or obviously with one crime does not reduce its sufficiency for the other.

This is a critical doctrinal clarification: sufficiency is assessed element-by-element, not crime-by-crime, and the presence of alternative offenses supported by the same facts does not lower the State’s evidentiary showing with respect to any particular offense.

E. The Dissent’s Competing View of Sufficiency and Knowledge

Justice Earls approaches the sufficiency question from a more restrictive standpoint.

1. Requirement of a Clear Nexus to the “Stolen” Nature of the Item

Relying on prior cases, she emphasizes that:

• Knowledge that property is stolen is typically inferred when there is some clear transactional imbalance or directly incriminating behavior tied to the stolen nature of the item—such as:
  • a suspiciously low price (Parker);
  • absence of customary paperwork or titles (Parker);
  • removal of serial numbers to evade tracing (Walker);
  • active attempts to discard the item during flight (Taylor, Wilson).
• In all those cases, there is something about the way the defendant handled the item that is linked specifically to its stolen character, not merely to its contraband status in general.

In contrast, Earls J. notes that:

• Bracey neither removed serial numbers nor tried to dispose of the gun when confronted.
• There is no evidence of the circumstances of acquisition or any abnormality in the “deal” by which he obtained it.
• The gun’s hidden location could as easily reflect generic consciousness of guilt as a felon in possession as it could knowledge of theft.

From this, the dissent concludes that the State has only created a strong suspicion—not substantial evidence—of the particular element that the gun was known to be stolen.

2. Concern about “Stacking Inference upon Inference”

The dissent criticizes the majority’s reliance on the difference between the hidden gun and the visible holster. That argument requires multiple inferential steps:

1. Bracey hidden the gun but chose not to hide the holster.
2. If his only concern were being caught as a felon in possession, he would likely hide both.
3. Therefore, he must have been especially concerned about the gun itself, beyond mere illegal possession.
4. Therefore, a likely reason for that concern is that he knew the gun was stolen.

The dissent invokes older cases (State v. Voncannon, State v. Maines) for the principle that:

“Inference may not be based on inference. Every inference must stand upon some clear or direct evidence, and not upon some other inference or presumption.”

Under that approach, the chain of reasoning the majority employs is too attenuated; it rests on layered conjectures about what Bracey “would have done” if his motive were X rather than Y.

3. “Some Evidence” vs. “Substantial Evidence”

Justice Earls also leans on Powell’s admonition that a motion to dismiss should be granted when the evidence “only creates a suspicion or conjecture” of guilt, “even though the suspicion so aroused by the evidence is strong.”

In her view:

• The State has essentially one bit of circumstantial evidence bearing on knowledge of theft: the gun’s concealment.
• The fact that the same behavior is equally explainable by illegal possession as a felon means the inference that he knew the gun was stolen is not sufficiently tied to this specific offense.
• When considered holistically, the evidence may show Bracey was obviously guilty of something, but not that he knew or reasonably should have known that the gun was stolen.

F. Reconciling “Inferences on Inferences” with Earlier Cautionary Cases

One of the more subtle but important doctrinal dynamics in Bracey is the tension between:

• Modern cases endorsing “inferences on inferences” (Dover, Childress), and
• Older cases (like Voncannon and Maines) that caution against stacking inferences on each other.

The majority explicitly cites Dover and Childress and, by practice if not by name, moves away from the stricter “no inference upon inference” formulation. While the dissent continues to apply that older logic, the majority effectively normalizes layered inferential reasoning so long as:

• Each step is grounded in some piece of evidence (here: the hidden panel, the unhidden holster, the lie, the felon status, the nature of the flight); and
• The overall chain is reasonable, even if not compelled.

This reflects a broader, national trend in sufficiency jurisprudence: courts generally allow circumstantial chains of reasoning as long as a reasonable juror could follow them and reach the prosecution’s conclusion.

G. The Use of Felon Status as Circumstantial Evidence of a Gun’s Stolen Status

Though briefly addressed in a footnote, the Court’s reasoning on Bracey’s felon status bears attention for its potential broader implications:

• Because federal law (18 U.S.C. § 922(d)(1)) bars knowing sale or disposition of firearms to felons, any person who provides a gun to a known felon is themselves acting unlawfully.
• The Court suggests a rational juror may connect this background illegality with a higher likelihood that such a gun itself was unlawfully sourced—e.g., stolen.
• Thus, felon status becomes not merely a separate crime element for a felon-in-possession charge, but also a factor that can bolster the inference that the felon knew or had reason to believe the firearm was stolen.

If applied broadly, this line of reasoning could make it significantly easier for the State to meet the knowledge requirement in stolen-gun cases involving felons, even in the absence of direct evidence about how the firearm was obtained.

IV. Simplifying the Key Legal Concepts

To make the doctrinal moves in Bracey more accessible, it helps to restate the core concepts in more straightforward terms.

A. “Substantial Evidence”

“Substantial evidence” does not mean “a lot of evidence” or “proof beyond a reasonable doubt.” Instead:

• It is the minimum threshold of proof needed to allow a case to go to the jury.
• It means there is more than a mere trace (“more than a scintilla”) of evidence on each element.
• The judge asks: Could a reasonable juror, using this evidence and common sense, reasonably find that this element is satisfied?

If the answer is yes, the court must deny the motion to dismiss and let the jury decide.

B. “View in the Light Most Favorable to the State”

When the judge evaluates a motion to dismiss:

• The judge must assume the prosecution’s witnesses are telling the truth.
• Every reasonable factual inference that helps the State must be accepted.
• Conflicts or alternative explanations are left for the jury to weigh in deliberation.

Defense-friendly evidence is largely sidelined at this stage; it resurfaces in jury argument and instructions.

C. “Knowledge or Reasonable Grounds to Believe” Property Is Stolen

For possession of a stolen firearm, the State need not prove the defendant had actual, subjective knowledge that the item was stolen. It is enough if:

• The circumstances were such that a reasonable person in the defendant’s position should have known or strongly suspected the item was stolen; and
• The defendant went ahead and possessed it anyway.

This is often shown circumstantially: suspicious pricing, removal of identifying marks, sudden possession of expensive goods, or furtive conduct when confronted.

D. “Consciousness of Guilt” Evidence

Certain behaviors—flight from police, lying to officers, hiding evidence—are treated as evidence of a guilty conscience. The law assumes:

• People who know they’ve done nothing wrong typically have no reason to run, lie, or hide incriminating items.
• Therefore, such actions can be used as circumstantial proof that the person knew they’d committed a crime.

In Bracey, the Court goes further and uses these behaviors to support not just generic guilt, but a specific knowledge element.

E. Motion to Dismiss for Insufficient Evidence

A motion to dismiss at the close of the State’s evidence (or at all the evidence) asks:

• Is there enough evidence that a reasonable jury could convict?
• Not: Will the jury convict, or should it convict?

If the State’s proof on an element is purely speculative—raising only a strong suspicion or guess—the judge must dismiss. If it rises to an “existing and real” basis for a guilty finding, the jury must decide.

V. Likely Impact and Practical Implications

A. For Prosecutors

Bracey provides a robust blueprint for defeating motions to dismiss in stolen-firearm prosecutions:

• Emphasize consciousness-of-guilt behavior: Intense flight, creative hiding of the gun, and lies about its existence are all powerful circumstantial indicators of knowledge that can be argued as going beyond mere fear of being caught with a gun.
• Highlight unusual concealment: Placing a gun behind a dash panel, under floorboards, or in other non-obvious compartments can be framed as a deliberate effort to keep it from detection in a way that suggests special knowledge (including that it might be stolen).
• Use felon status strategically: While evidence of prior convictions is often prejudicial, where properly admissible, prosecutors can argue that the criminality of supplying a gun to a felon makes it more likely that the gun itself is stolen and that the felon knows it.
• Resist focus on alternative explanations: At the sufficiency stage, the State can rely heavily on Bracey to argue that competing innocent or alternative-crime explanations are for the jury, not a basis for dismissal.

B. For Defense Counsel

Defense strategy will need to adapt to the more prosecution-friendly sufficiency standard reflected in Bracey:

• Expect denials of motions to dismiss: Where there is any significant flight or concealment evidence, dismissal on the knowledge element will be difficult.
• Reframe at trial and in closing: The battle shifts to persuading the jury that the same facts (flight, hiding, lying) reflect fear of being caught as a felon in possession or for other reasons, not knowledge of theft.
• Seek nuanced jury instructions: Defense counsel may pursue instructions separating “generic” consciousness of guilt from knowledge of theft, emphasizing the need for the jury to find that the defendant knew or had reasonable grounds to believe the gun was stolen—not just that he knew he illegally possessed it.
• Challenge the use of felon status: Where possible, counsel may seek to limit or exclude references to prior convictions, or at least to prevent the State from using that status to bootstrap inferences about theft without clear evidentiary support.

C. For Trial and Appellate Courts

Bracey gives clear instructions to courts:

• On motions to dismiss, courts must:
  • Accept “inferences on inferences” in favor of the State;
  • Refuse to weigh competing explanations or consider defense-friendly evidence; and
  • Recognize that evidence can simultaneously support multiple offenses without undermining sufficiency for any single one.
• On review, appellate courts will apply de novo review but are constrained to ask only whether a rational juror could find the element satisfied, not whether the majority of judges (or jurors) would personally draw that conclusion.

D. Broader Policy Concerns

The decision represents a modest but real tilt toward the prosecution in sufficiency-of-evidence doctrine. It raises at least two policy concerns:

• Conflation of crimes: There is a risk that evidence strongly probative of one offense (felon-in-possession) will be allowed to stand in for more specific elements of another (knowledge that the gun is stolen), potentially blurring doctrinal distinctions between separate crimes.
• Expanding inferences from criminal status: Using felon status as a basis for inferring not just firearm possession but knowledge of theft can compound the already substantial prejudice faced by defendants with prior convictions.

At the same time, Bracey reflects a broader recognition that criminal intent and knowledge are ordinarily proved by circumstantial evidence and common-sense reasoning, rather than direct admissions or paper trails.

VI. Conclusion

State v. Bracey clarifies and consolidates North Carolina law on the sufficiency of circumstantial evidence to prove that a defendant knew or had reasonable grounds to believe a firearm was stolen. The Court holds that intense flight from police, deliberate concealment of a gun in a non-obvious compartment while leaving the holster visible, and lies denying the gun’s existence constitute substantial evidence of the knowledge element, even where the same conduct could also reflect guilt of other crimes, such as felon-in-possession.

Doctrinally, the decision:

• Confirms that “substantial evidence” is synonymous with “more than a scintilla” and that courts may make “inferences on inferences” in favor of the State;
• Insists that alternative explanations favorable to the defendant are irrelevant at the motion-to-dismiss stage;
• Rejects the notion that evidence pointing to “some crime” cannot be sufficient to establish a particular crime when the same evidence supports both; and
• Subtly broadens the inferential significance of a defendant’s felon status in assessing knowledge that a gun is stolen.

The dissent warns that this approach risks converting strong suspicion into sufficient proof of specific mental states, blurring the line between generic consciousness of guilt and knowledge that property is stolen, and weakening the traditional bar on convictions resting on “suspicion or conjecture.” That tension—between a flexible, common-sense view of circumstantial evidence and a stricter insistence on a clear nexus to each element—will likely continue to shape North Carolina’s criminal jurisprudence.

What is clear after Bracey is that, in North Carolina, prosecutors have substantial leeway to rely on flight, concealment, and deception to establish not only that a defendant is guilty of something, but that he knew or had reasonable grounds to believe the firearm in his possession was stolen. The decision thus stands as a significant precedent in the law of stolen property and firearms, and a reaffirmation of a prosecution-friendly conception of the substantial evidence standard.