State v. Eggleston, 940 N.W.2d 645

Defendant Alex Kenny Eggleston was charged with murder (Class AA) and possession of a firearm by a convicted felon (Class C) after a witness observed him display a pistol and fire several times; an autopsy showed two mid‑back gunshot wounds, one fatal.
At trial the district court denied Eggleston’s Rule 29 motion for judgment of acquittal; a jury convicted him of both counts.
Eggleston was initially sentenced to life with the possibility of parole; the court later amended the judgment to include a remaining life expectancy calculation of 47.9 years using a 2017 life table.
Eggleston appealed, arguing (1) insufficient evidence to support the murder conviction and that the district court applied an incorrect legal standard on the Rule 29 motion, (2) the State failed to disprove his self‑defense claim, and (3) the sentencing calculation violated due process because N.D.C.C. § 12.1‑32‑09.1 and N.D. Sup. Ct. Admin. R. 51 are vague and the court used the wrong life table.
The Supreme Court of North Dakota affirmed the convictions, held the evidence was sufficient to disprove self‑defense, and reversed the amended judgment only as to the life‑expectancy calculation, remanding for recalculation under the 2002 life table mandated by Admin. R. 51.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court abused discretion denying Rule 29 motion and whether evidence was sufficient to sustain murder conviction	State: evidence (witness of shooting, shots to victim’s back, fatal wound) was sufficient for a reasonable jury to convict	Eggleston: court applied wrong legal standard at Rule 29 ("assume the truth" language) and evidence did not support guilt	Court affirmed denial of Rule 29 and conviction; viewing evidence in light most favorable to verdict, evidence was legally sufficient
Whether evidence disproved self‑defense	State: testimony and forensic evidence supported that victim was shot in the back while walking away, inconsistent with self‑defense	Eggleston: witness testimony conflicted with forensic timing/location; insufficient to disprove self‑defense beyond reasonable doubt	Court held evidence sufficient for a reasonable factfinder to find Eggleston was not acting in self‑defense
Whether sentencing scheme/statute is unconstitutionally vague and whether court used correct life table	State: sentencing used life expectancy calculation authorized by statute and rule	Eggleston: interplay of §12.1‑32‑09.1 and Admin. R. 51 is vague; district court used 2017 life table rather than the 2002 table required by Rule 51	Court remanded to recalculate remaining life expectancy using the 2002 United States Life Tables per Admin. R. 51; declined to decide vagueness claim on appeal

State v. Hafner, 587 N.W.2d 177 (N.D. 1998) (standard for viewing evidence on sufficiency review)
State v. Gunn, 909 N.W.2d 701 (N.D. 2018) (Rule 29 acquittal requires finding evidence insufficient to sustain conviction)
State v. Gonzalez, 606 N.W.2d 873 (N.D. 2000) (abuse of discretion standard for denying Rule 29 when evidence insufficient)
State v. Rai, 924 N.W.2d 410 (N.D. 2019) (defendant bears burden to show no reasonable inference of guilt when viewing evidence favorably to verdict)
State v. Wangstad, 917 N.W.2d 515 (N.D. 2018) (appellate review frames evidence and inferences in light most favorable to verdict)
State v. Carlson, 559 N.W.2d 802 (N.D. 1997) (framework for determining whether a reasonable factfinder could convict)
State v. Friesz, 898 N.W.2d 688 (N.D. 2017) (conflicting evidence does not alone require overturning a legally sufficient verdict)
State v. Thomas, 938 N.W.2d 897 (N.D. 2020) (illegal‑sentence claims need not be preserved to be raised on appeal)
State v. Abdiwali Mohamud, 925 N.W.2d 396 (N.D. 2019) (definition of illegal sentence exceeding statutory authority)
State v. Booth, 861 N.W.2d 160 (N.D. 2015) (sentence is illegal if contrary to statute)