South Carolina v. Bruce

Petitioner-respondent Roger Bruce was convicted of murder for the death of his girlfriend Laura Creel. Police performed a welfare check on the home Bruce and Creel shared. Bruce allowed the officers inside. Finding nothing, officers questioned Bruce, who told them Creel had left after the two argued. During the conversation, the officers noticed a cell phone and car keys on a table nearby. Bruce informed the officers they both belonged to Creel and an officer picked up the keys and went outside to the vehicle. The officer looked through the windows into the interior of the car and then attempted to open the trunk, but it would not open. He then asked Bruce which key opened the trunk and Bruce moved toward the officer as if to grab the keys. The officer pulled the keys back, and a second officer pressed the trunk release button. Inside the trunk, the officers discovered Creel's body. During the course of testimony regarding how the police found Creel's body in the trunk, Bruce objected "to the discovery of the body in this fashion" on the basis that there was no consent and no search warrant was obtained. When the trial court asked what basis Bruce had to object, he responded that it was on his property and the keys were in his house. The solicitor argued it was Creel's car and Bruce therefore had no expectation of privacy. He further claimed the officer who initially took the keys had testified the previous day that Bruce offered to open the trunk for them. Ultimately, the court denied the motion stating, "[i]t appears that this is inevitable discovery; but/for hitting the release button and opening the trunk according to the earlier testimony Mr. Bruce was gonna [sic] open the trunk for them, or at least was providing the keys to do so." Bruce was convicted and sentenced to life imprisonment. On appeal, Bruce argued the trial court erred in denying the motion to suppress because Bruce never consented to the officers taking the keys from his home. Upon review, the Supreme Court concluded the trial court did not err in denying Bruce's motion to suppress. View "South Carolina v. Bruce" on Justia Law