South Carolina v. Johnson

In 2008, respondent Brittany Johnson was arrested in Darlington County by United States Marshals for the shooting death of Monica Burroughs. At trial, the State sought to introduce a videotaped recording of the police's interrogation of respondent after she was arrested, and the court held a "Jackson v. Denno" hearing to assess the voluntariness of the statement. During cross-examination, the State sought to discredit Respondent's testimony by eliciting testimony that she was experienced with the criminal justice system and had been represented by counsel in the past in the juvenile justice system. In addition, respondent acknowledged that despite understanding her rights, she wished to waive them at that time, and further confirmed the recorded statement displayed her telling officers that she wished to waive her rights. Based on this testimony, the trial court determined that the confession was voluntarily given. The State subsequently introduced respondent's videotaped statement at trial over defense counsel's objection. The jury ultimately found respondent guilty of murder, and the trial court sentenced her to thirty years' imprisonment. Without discussion, the court of appeals reversed and remanded the conviction, finding the trial court erred in admitting respondent's statement to police. On appeal, the State argued the court of appeals: (1) applied an incorrect appellate standard of review in assessing the trial judge's factual findings; (2) erred in reversing the trial court's ruling where respondent was not being interrogated when she inquired about counsel and did not unequivocally invoke her right to counsel; and (3) failed to consider if respondent was prejudiced by the admission of the evidence. Because the effect of the trial court's credibility finding was that respondent did not unequivocally invoke her right to counsel, the Supreme Court upheld the trial court's finding that respondent's statement was voluntary. View "South Carolina v. Johnson" on Justia Law