Justia South Carolina Supreme Court Opinion Summaries

Petitioner Darryl Frierson pled guilty to assault and battery of a high and aggravated nature, criminal conspiracy, kidnapping, and armed robbery for his role in masterminding a $9.8 million heist from an armored truck. He was sentenced to an aggregate term of thirty-five years in prison. He applied for post-conviction relief (PCR), asserting he would not have pled guilty but instead would have proceeded to trial had his plea counsel adequately informed him of the possibility to suppress evidence gathered from law enforcement's warrantless placement of a mobile tracking device on his vehicle. The PCR court denied relief, and the court of appeals affirmed. The South Carolina Supreme Court determined the appellate court erred in its application of the standard of review, but corretly deferred to the OCR court's findings. Therefore, the Supreme Court affirmed as modified and took the opportunity to clarify the correct standard to determine prejudice when a defendant seeks PCR after pleading guilty. View "Frierson v. South Carolina" on Justia Law

Jonathan Miller appealed his conviction for possession of crack cocaine. He argued the trial court erred in denying his motion to suppress drug evidence seized during an inventory search of his vehicle after he was arrested for driving with a suspended license. The issue on appeal for the South Carolina Supreme Court’s review was whether it was reasonable under the Fourth Amendment, for the officers acting pursuant to their department policy to seize, search, and then tow the vehicle Miller was driving when he was arrested on private property away from his residence and the owner of the vehicle was not present. The Supreme Court found no conflict between the Columbia Police Department policy and any other state statutes regarding the authority to tow vehicles from private property; the inventory search was reasonable under the Fourth Amendment, and the trial court was correct to deny Miller’s motion to suppress. View "South Carolina v. Miller" on Justia Law

Samuel Brown Jr. filed a petition for a writ of certiorari seeking appellate review of an order granting summary judgment to the State in his application for post-conviction relief (PCR). Brown pled guilty to possession with intent to distribute marijuana (PWID) on May 20, 2014, and the court sentenced him to three years in prison. At the time of his plea, Brown was already serving a ten-year sentence for trafficking in cocaine. The PWID sentence began on June 25, 2013, due to credit for time served, and was imposed concurrent to the ten-year sentence. Brown did not appeal. Brown filed an application for PCR on November 20, 2014. No hearing was held until September 16, 2016. By then, Brown had completed his PWID sentence, although he remained incarcerated on the ten-year sentence. At the PCR hearing, the State made a motion for summary judgment, arguing Brown's claim was moot because he had already completed his PWID sentence. The PCR court granted the State's motion for summary judgment, and dismissed the PCR application. The South Carolina Supreme Court determined dismissing the PCR application was made in error. The case was reversed and remanded for a hearing on the merits. View "Brown v. South Carolina" on Justia Law

Appellant Michael Beaty Jr. was convicted of murdering Emily Asbill (Victim), for which he received a life sentence. The South Carolina Supreme Court affirmed Appellant's conviction on December 29, 2016. In affirming Appellant's conviction in its prior opinion, the Supreme Court found two of the issues Appellant raised merited discussion. First, the Court addressed the trial judge's use of certain language in his opening remarks to the jury and the content requirements and order of closing argument. The Court affirmed Appellant's conviction but instructed trial judges to avoid language urging jurors to "search for the truth," find "true facts," and render a "just verdict." Second, the Court adopted a rule for closing argument in criminal cases, requiring the party with the right to open and close to open fully on the law and facts and limit its reply to those matters raised by the other party in its closing argument. The Court affirmed all of Appellant's remaining issues under Rule 220(b), SCACR. The Court then granted the parties' petitions for rehearing and heard further argument. The Court issued this opinion to again address both the trial judge's use of certain language in his opening remarks to the jury and the rules governing the content and order of closing argument. The Court affirmed Appellant's conviction. View "South Carolina v. Beaty" on Justia Law

Respondent Brandon Garren pled guilty to assault and battery of a high and aggravated nature (ABHAN) and criminal domestic violence of a high and aggravated nature (CDVHAN) in connection with a series of brutal attacks on his live-in girlfriend (Victim). He was sentenced to concurrent prison terms of fifteen years and ten years, respectively. No direct appeal was taken. Garren then filed an application for post-conviction relief (PCR). The PCR court granted relief, finding plea counsel was ineffective for failing to obtain a competency evaluation prior to Garren's guilty plea and that Garren's plea was involuntary due to his use of medication. The South Carolina Supreme Court reversed, finding the record contained no evidence to support a finding that counsel's decision not to seek a competency evaluation fell below reasonable professional norms. Furthermore, the Court found the record was "utterly devoid" of any evidence that Garren had taken any medication on the day he pled guilty or that he was, as the PCR court found, "under the influence of medication which affected his ability to understand what he was doing on the day of his plea." Absent any evidence that Garren's ability to understand the guilty plea proceeding was diminished by the mind-altering effects of one or more specific medications, the Court ruled Garren failed to meet his burden of proving his plea was constitutionally infirm, and his claim failed as a matter of law. View "Garren v. South Carolina" on Justia Law

In 2008, Petitioner Yancey Thompson was convicted of first degree criminal sexual conduct (CSC) with a minor, second degree CSC with a minor, and disseminating obscene material to a minor. He was sentenced to concurrent prison terms of twenty-five years, twenty years, and ten years, respectively. Petitioner appealed and the South Carolina Supreme Court affirmed his convictions. Petitioner then sought post-conviction relief (PCR). The PCR court concluded Petitioner had established his trial counsel was deficient in certain respects but denied relief on the basis that Petitioner had not proven he was prejudiced by these deficiencies. The Supreme Court concluded Petitioner's jury trial was infected by “improper corroborating evidence,” and that there was no probative evidence in the record to support the PCR court's findings that Petitioner was not prejudiced by these deficiencies. Therefore, the Court reversed the PCR court's denial of post-conviction relief and remanded to the court of general sessions for a new trial. View "Thompson v. South Carolina" on Justia Law

Respondent Michael Milledge was arrested and convicted of multiple drug-related offenses in Greenville County following a traffic stop. Milledge applied for post-conviction relief (PCR), arguing his defense counsel was deficient for failing to object at trial to the introduction of contraband found pursuant to an illegal search. The PCR court agreed and granted Milledge a new trial. After review, the South Carolina Supreme Court held the PCR court erred in finding Milledge met his burden of proof to establish prejudice. “The motivation of the deputies in this case is highly probative. While the protections of the Fourth Amendment may have been triggered had the deputies prolonged the detention and engaged in a search of Milledge and his vehicle for the purpose of finding evidence, the limited pat down performed by Deputy Lanning was solely for officer safety. To reach a different conclusion would prevent officers operating in similar high-crime areas from conducting a protective frisk when their specialized training indicates the person may be armed and would subject officers to the ‘unnecessary risks’ in performing their duties the Terry court warned against.” View "Milledge v. South Carolina" on Justia Law

Respondent Michael Milledge was arrested and convicted of multiple drug-related offenses in Greenville County following a traffic stop. Milledge applied for post-conviction relief (PCR), arguing his defense counsel was deficient for failing to object at trial to the introduction of contraband found pursuant to an illegal search. The PCR court agreed and granted Milledge a new trial. After review, the South Carolina Supreme Court held the PCR court erred in finding Milledge met his burden of proof to establish prejudice. “The motivation of the deputies in this case is highly probative. While the protections of the Fourth Amendment may have been triggered had the deputies prolonged the detention and engaged in a search of Milledge and his vehicle for the purpose of finding evidence, the limited pat down performed by Deputy Lanning was solely for officer safety. To reach a different conclusion would prevent officers operating in similar high-crime areas from conducting a protective frisk when their specialized training indicates the person may be armed and would subject officers to the ‘unnecessary risks’ in performing their duties the Terry court warned against.” View "Milledge v. South Carolina" on Justia Law

Stepheno Alston was tried in absentia and convicted by a jury of trafficking in cocaine. The trial judge sentenced Alston to twenty-five years' imprisonment. On appeal, the Court of Appeals affirmed Alston's conviction and sentence, upholding the trial judge's denial of Alston's motion to suppress evidence found in his vehicle following a traffic stop. Specifically, the Court of Appeals agreed with the trial judge that: (1) the arresting officer had (a) probable cause to stop Alston's vehicle for a violation of South Carolina's failure to maintain a lane statute and (b) reasonable suspicion to support a brief investigatory detention; (2) the officer had reasonable suspicion that illegal activity was occurring to justify extending the duration of the traffic stop; and (3) Alston voluntarily gave his consent to the officer to search his vehicle. The South Carolina Supreme Court granted Alston's petition for a writ of certiorari to review the decision of the Court of Appeals. Based on South Carolina rules of statutory construction, the Supreme Court held the offense of failure to maintain a lane was not a strict liability offense. As a result, an officer must consider all relevant circumstances in deciding whether to stop a vehicle for a violation of this statute. Applying this interpretation to the facts of the instant case, we conclude there is evidence to support the trial judge's finding that the initial traffic stop was valid. Further, the Court found evidence to support the trial judge's determination that the arresting officer had reasonable suspicion of criminal activity to extend the scope of the stop beyond its initial purpose and that Alston voluntarily consented to the warrantless search. Therefore, while the Supreme Court agreed with the result reached by the Court of Appeals, it modified its analysis regarding the interpretation of section 56-5-1900 and the basis for which the officer had reasonable suspicion to extend the duration of the traffic stop. Accordingly, the decision of the Court of Appeals was affirmed as modified. View "South Carolina v. Alston" on Justia Law

Kenneth Hilton appealed the denial of post-conviction relief (PCR), claiming the PCR court did not obtain a knowing and intelligent waiver of his right to counsel before allowing him to represent himself at his PCR trial. Hilton pled guilty to kidnapping and assault with intent to commit criminal sexual conduct in the second degree. When asked at the PCR trial about the quality of the State's evidence, plea counsel explained, "We had the actual recording of what went on, and when you listen to it, there is no defense to these charges." The plea court sentenced him to forty-five years in prison. He did not appeal. Hilton filed a PCR application alleging ineffective assistance of counsel. The State requested a hearing, and the court appointed counsel to represent him. Hilton then moved to "dismiss" his appointed attorney. A few weeks later, after learning his motion was set for a hearing, Hilton filed another motion, again seeking "dismissal of PCR Court Appointed Attorney." At the hearing on Hilton's motion, the PCR court informed him of his right to counsel but did not warn him of the dangers of proceeding without an attorney. After the hearing, the PCR court entered an order granting the motion to relieve counsel. Almost a year later, Hilton appeared without an attorney before a second PCR court for trial. The PCR court began by inquiring into Hilton's waiver of his right to counsel. Both sides presented testimony. As a part of its presentation, the State informed the PCR court of Hilton's seven prior convictions for criminal sexual conduct. The PCR court took the case under advisement, and later issued a written order denying relief. The South Carolina Supreme Court found Hilton declined to have the PCR court explain "the kinds of things that an attorney might do to be of service. ... the record here is clear Hilton was already aware of several of the specific advantages of having an attorney." Finding a valid waiver of his right to counsel, the Supreme Court affirmed the denial of relief. View "Hilton v. South Carolina" on Justia Law