Is a Single Drug Sale from a Residence Enough to Support a Conviction for Maintaining a Dwelling?

Last week, the court of appeals decided State v. Miller, a case in which the defendant was convicted of maintaining a dwelling based almost entirely on the fact that he conducted a drug sale there. Would the court of appeals find the evidence sufficient under State v. Rogers, __ N.C. __, 817 S.E.2d 150 (2018), which substantially expanded the scope of maintaining a dwelling and related offenses?

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