Justia South Carolina Supreme Court Opinion Summaries

Kenneth H. Eastwood was convicted of murder after the body of Cara Hodges was found strangled in a wooded area. Eastwood was the last person seen with the victim and, after being interviewed by police, he confessed to the crime both to his employer and later to law enforcement. During the investigation, Eastwood took a polygraph test and was told by police that he had failed. He subsequently confessed to the murder, describing details of the crime and disposal of evidence. At trial, Eastwood did not testify but presented a false confession expert who opined that his confession was consistent with an internalized false confession, citing factors such as alcohol use, sleep deprivation, and being confronted by police with allegedly objective evidence of guilt.The case was tried in the Circuit Court for Orangeburg County. Eastwood sought to introduce evidence through his expert that police told him he failed the polygraph, arguing it was relevant to his false confession defense. The trial court excluded this evidence, relying on Rule 702 and Rule 403 of the South Carolina Rules of Evidence, finding that polygraph evidence was unreliable and that its admission would confuse the jury and potentially prejudice Eastwood by bolstering the confession’s truthfulness.On appeal, the Supreme Court of South Carolina reviewed whether exclusion of the polygraph evidence was error. The court held that the trial court erred in excluding the evidence under Rule 702, as Eastwood was not offering scientific proof of the polygraph’s reliability but rather the fact that police told him he failed. The Supreme Court found the evidence relevant to the defense and not substantially outweighed by confusion or prejudice under Rule 403. However, the court concluded that the error did not affect the jury’s verdict, as the expert was able to present the core theory of false confessions. The conviction was therefore affirmed. View "The State v. Eastwood" on Justia Law

The case concerns a man who was convicted of murdering his estranged wife by shooting her in the back seat of a car outside a police station, in the presence of children. He was arrested the day before the murder for domestic violence, released on bond, and the next day followed his wife and her friend to the police station, where the shooting occurred. The prosecution presented evidence of prior domestic abuse and a previous conviction for a violent offense. The defense focused on the defendant’s troubled upbringing, mental health issues, and cognitive deficits. The jury found him guilty and recommended a death sentence, which the trial court imposed.After his conviction and sentence were affirmed on direct appeal, the defendant filed for post-conviction relief (PCR) in the Circuit Court for Spartanburg County, alleging ineffective assistance of counsel, particularly regarding the investigation and presentation of mitigating evidence during the penalty phase. The PCR court initially denied relief in an order that was identical to the State’s proposed order. The Supreme Court of South Carolina vacated that order and remanded for a new order with specific findings. On remand, the PCR court again denied relief, issuing an amended order after reviewing the parties’ proposed orders and making some corrections. The defendant’s requests for a new hearing or for the judge’s recusal were denied.The Supreme Court of South Carolina reviewed whether the PCR court erred by adopting the State’s proposed order and whether trial counsel was ineffective in preparing and presenting mitigation. The court held that the PCR court did not violate the defendant’s rights by adopting the State’s proposed order after adequate review, and that any deficiencies in trial counsel’s mitigation investigation or presentation did not prejudice the defendant. The court found no reasonable probability that additional mitigation evidence would have changed the jury’s recommendation. The decision of the PCR court was affirmed in result. View "Lindsey v. The State" on Justia Law

The case concerns a defendant who was arrested and indicted for the murder of an individual named Donald Blake, with the allegation being that the murder was committed by blunt force trauma. At trial, the court instructed the jury on both murder and, over the defendant’s objection, the lesser-included offense of voluntary manslaughter. After more than five hours of deliberation, the jury returned a verdict of not guilty on murder and guilty on voluntary manslaughter. During jury polling, the eleventh juror indicated that the guilty verdict for manslaughter was not her true verdict, explaining she had been pressured by other jurors and maintained a not guilty stance. The trial judge, without instructing the jury to continue deliberations and over the objections of both parties, questioned the dissenting juror individually and then declared a mistrial.Following the mistrial, the State sought to retry the defendant for murder. The defendant moved for habeas corpus and for entry of a verdict of acquittal, arguing that jeopardy had attached to the murder charge because the jury had returned a final not guilty verdict. The Circuit Court denied relief, holding that jeopardy had not attached and that the State could retry the defendant for murder. The defendant’s appeal to the South Carolina Court of Appeals was dismissed as not immediately appealable, and his petitions for supersedeas and habeas corpus were denied. The Supreme Court of South Carolina then issued a common law writ of certiorari to review whether the State could retry the defendant for murder, and later requested briefing on the voluntary manslaughter charge as well.The Supreme Court of South Carolina held that jeopardy attached to both the murder and voluntary manslaughter charges. The Court found the not guilty verdict on murder was final and that the trial court’s sua sponte declaration of a mistrial, without manifest necessity and without instructing the jury to continue deliberations, barred retrial on both charges under double jeopardy principles. The Court reversed the lower court’s ruling, holding the State may not retry the defendant for either offense. View "The State v. Erb" on Justia Law

Law enforcement arrested the defendant after discovering large quantities of methamphetamine and fentanyl in his vehicle. He was indicted for trafficking in methamphetamine and trafficking in illegal drugs under South Carolina law. The defendant entered a deferred plea agreement, agreeing to cooperate as a confidential informant in exchange for deferred sentencing. However, after being re-arrested on new drug charges, he ultimately pled guilty to both trafficking charges. Two years later, he moved to vacate his guilty plea to trafficking in illegal drugs, arguing that the statute under which he was charged did not criminalize trafficking in fentanyl, a synthetic opioid, and thus he had pled guilty to a nonexistent offense.The Circuit Court for Greenville County denied the motion to vacate, reasoning that the defendant had received a benefit by pleading to trafficking rather than a more serious charge and that his conduct was clearly criminal. The court did not specifically address whether fentanyl fell within the statutory language but imposed concurrent sentences for both trafficking convictions. The defendant appealed, contending that the indictment failed to state an offense and that the court lacked subject matter jurisdiction to accept his plea.The Supreme Court of South Carolina affirmed the conviction and sentence. The court held that even if the statute did not encompass fentanyl, any defect in the indictment was non-jurisdictional and was waived by the defendant’s guilty plea. The court clarified that subject matter jurisdiction is not implicated by defects in an indictment charging a recognized crime, and that a guilty plea waives all non-jurisdictional challenges. Therefore, the defendant could not challenge his conviction on the grounds asserted after pleading guilty. View "The State v. Sweet" on Justia Law

Charles Dent was accused of sexually abusing his granddaughter, J.M., when she was eight or nine years old. The alleged abuse occurred during periods when Dent visited his daughter’s family in South Carolina. The victim disclosed various acts of abuse, including being forced to perform fellatio, digital penetration, cunnilingus, and being shown obscene material. The State indicted Dent on two counts of disseminating obscene material to a minor and two counts of criminal sexual conduct with a minor (CSCM) in the first degree, specifically alleging fellatio as the sexual battery in both CSCM indictments.At trial in the Circuit Court for Beaufort County, the State presented evidence through forensic interviews and the victim’s testimony. The victim described only one instance of fellatio, which she located at House 1, not House 2. Dent moved for a directed verdict on the CSCM charge related to House 2, arguing there was no evidence of fellatio at that location. The trial court denied the motion and, over Dent’s objection, instructed the jury on the full statutory definition of sexual battery, including acts not charged in the indictment. The jury convicted Dent of the CSCM charge for House 2 and both dissemination charges, but acquitted him of the CSCM charge for House 1. The South Carolina Court of Appeals affirmed the convictions after remand.The Supreme Court of South Carolina held that the trial court erred by denying Dent’s motion for a directed verdict on the CSCM charge for House 2, as there was no evidence of fellatio at that location, and by instructing the jury on unindicted acts of sexual battery. The Court reversed Dent’s CSCM conviction but affirmed his convictions for dissemination of obscene material to a minor. The Court also rejected Dent’s procedural challenge regarding the composition of the appellate panel. View "State v. Dent" on Justia Law

Meredith Logan Whitehurst was cited for violating the Town of Sullivan's Island's Disorderly Conduct Ordinance after loudly berating her Uber driver with profanity and racial and xenophobic epithets at nearly 2:00 a.m. The driver, an Egyptian-born immigrant, testified that Whitehurst's loud phone conversation disturbed his driving, and when he asked her to be quiet, she began mocking and cursing him. After stopping the car and asking Whitehurst and her friend to exit, Whitehurst continued to yell offensive remarks at the driver. The police were called, and Whitehurst was cited for public disorderly conduct.Whitehurst was tried by a jury in the Town's Municipal Court, which found her guilty and fined her $1,040. She moved for a new trial, which was denied, and then appealed to the circuit court, which affirmed the conviction. Whitehurst then appealed to the South Carolina Supreme Court, arguing that the Ordinance violated her First Amendment rights, was unconstitutionally vague, and that the trial court erred in various procedural rulings, including denying her motion to suppress the Uber video.The South Carolina Supreme Court affirmed the lower court's decision. The Court held that the Ordinance was content-neutral and served the Town's significant interest in controlling noise levels, thus not infringing on Whitehurst's First Amendment rights. The Court also found that the Ordinance was not unconstitutionally vague, as it provided fair notice of the prohibited conduct and included a scienter requirement. Additionally, the Court deemed Whitehurst's arguments regarding the multiple subsections of the Ordinance and the motion to suppress the Uber video as conclusory and abandoned due to lack of supporting authority. View "Whitehurst v. Town of Sullivan's Island" on Justia Law

Mitchell Rivers was convicted of Homicide by Child Abuse (HCA) following the death of his four-month-old adoptive child, who died from asphyxiation. During the trial, the State introduced evidence of the child's prior injuries, which were unrelated to the cause of death. Rivers' trial attorney objected to this evidence pretrial but failed to renew the objection during the trial, leaving the issue unpreserved for appeal. Rivers subsequently filed for post-conviction relief (PCR), claiming ineffective assistance of counsel.The PCR court denied relief, finding that Rivers was not prejudiced by his attorney's failure to renew the objection. However, the court of appeals reversed this decision, holding that Rivers was prejudiced by his attorney's errors, as there was no nexus between the collateral injury evidence and the circumstances surrounding the child's death.The Supreme Court of South Carolina reviewed the case and reversed the court of appeals' decision. The Supreme Court found that even if the collateral injury evidence had been excluded, there was no reasonable probability that the jury's verdict would have been different. The court noted that Rivers' actions, including his failure to seek medical assistance after the child resumed wheezing and his inability to perform CPR, demonstrated a conscious disregard for the risk of the child's death, thus establishing extreme indifference beyond a reasonable doubt. Consequently, Rivers failed to satisfy the prejudice prong of the Strickland test for ineffective assistance of counsel. The decision of the court of appeals was reversed. View "Rivers v. State" on Justia Law

In 2004, Jason McSwain, a former teacher, pled guilty to two counts of criminal sexual conduct with a minor in the second degree and one count of contributing to the delinquency of a minor. After serving his prison sentence, he registered as a sex offender as required by South Carolina's Sex Offender Registry Act (SORA). Initially, SORA mandated lifetime registration for all sex offenders. In 2022, the General Assembly amended SORA to implement a three-tier system based on the severity of the offense, with tier II offenders, like McSwain, required to register for 25 years before seeking removal.McSwain applied for removal from the registry in 2022, but the South Carolina Law Enforcement Division (SLED) denied his application as premature. He then filed a motion in the circuit court, arguing that the tier system and mandatory wait times violated his right to substantive due process. The circuit court denied his motion, finding that the amendments to SORA were rationally related to the government's interest in public safety and law enforcement.The South Carolina Supreme Court reviewed the case and upheld the circuit court's decision. The Court found that the tiered-registration system and corresponding mandatory-minimum time periods for registration were rationally related to SORA's legislative purposes of protecting the public and aiding law enforcement. The Court emphasized that the amendments brought SORA in line with federal law and the approach taken by a majority of states. Consequently, the Court held that McSwain failed to establish that SORA violated his right to substantive due process and affirmed the circuit court's decision. View "The State v. McSwain" on Justia Law

Rashawn Vertez Carter was involved in a violent home invasion and robbery in Aiken, South Carolina, on May 9, 2015. After the crime, law enforcement officers used Carter's real-time cell-site location information from his cell-service provider, T-Mobile, to track him down without obtaining a search warrant. Carter was subsequently arrested and made incriminating statements during interviews with the police.At trial, Carter moved to suppress the evidence obtained from his real-time cell-site location information, arguing that it was obtained in violation of his Fourth Amendment rights and the South Carolina Constitution. The trial court denied the motion, ruling that the information gathered did not constitute a search under either constitution. The jury convicted Carter of burglary, armed robbery, kidnapping, and illegal possession of a weapon, but acquitted him of the alleged sexual assault. Carter appealed to the South Carolina Court of Appeals, which affirmed the trial court's decision, holding that the exigent circumstances exception to the warrant requirement applied and that the good-faith exception to the exclusionary rule also justified the officers' actions.The South Carolina Supreme Court reviewed the case and affirmed Carter's convictions. The court did not address whether a search occurred or if the exigent circumstances exception applied. Instead, it focused on the good-faith exception to the exclusionary rule, concluding that the officers acted in good faith reliance on the federal Stored Communications Act, which allowed the disclosure of customer records in emergencies. The court held that the good-faith exception precluded the suppression of evidence obtained through Carter's real-time cell-site location information, as the officers reasonably believed their actions were lawful under the statute. View "State v. Carter" on Justia Law

In the early morning of March 7, 2015, Robert Xavier Geter and James Lewis engaged in a fight at Culler's Bar in Columbia, South Carolina. The altercation moved outside, where Geter stabbed Lewis, who later died from his injuries. During the incident, Geter also stabbed Clarence Stone, causing permanent blindness in one eye. Geter claimed self-defense, stating he was attacked by multiple people and only used his knife to defend himself.The State indicted Geter for murder and attempted murder, arguing that Geter intended to kill Lewis and that this intent transferred to Stone when he was stabbed. The trial court instructed the jury on the doctrine of transferred intent, and Geter was convicted of both charges. Geter appealed, arguing that transferred intent should not apply to attempted murder and that certain testimony constituted improper bolstering.The South Carolina Court of Appeals reversed Geter's attempted murder conviction, holding that the State needed to prove Geter specifically intended to kill Stone, which was not the State's theory. The court also found that some testimony constituted improper bolstering but deemed it harmless, affirming the murder conviction. Judge Geathers dissented on the transferred intent issue.The South Carolina Supreme Court reviewed the case and held that the doctrine of transferred intent does not apply to attempted murder. The court affirmed the Court of Appeals' decision to reverse Geter's attempted murder conviction and upheld the murder conviction, agreeing that the error in admitting the bolstering testimony was harmless. View "State v. Geter" on Justia Law