State v. Talbot, 234 N.C. App. 297 (Jun. 3, 2014)

In the face of the State’s concession that there was no evidence supporting a restitution award, the court vacated the trial court’s restitution order and remanded for a rehearing on the issue. The court noted: “In the interest of judicial economy, we urge prosecutors and trial judges to ensure that this minimal evidentiary threshold is met before entering restitution awards.”