I can't rule out a 97... heck, 98 isn't IMPOSSIBLE, but that seems very unlikely.
With a high profile game like this there will always be the handful of bizarrely low scores that trickle out and drag down the average. I don't believe we'll ever see another 99 going forward, as it resulted from a far smaller pool of reviewers. These days any dude with a blog and a few thousand followers can have his review listed on metacritic.