Justia South Carolina Supreme Court Opinion Summaries

Appellant Ronald Legg was convicted of lewd act on a minor. He was sentenced to twelve years' imprisonment, ordered to be placed on the sex offender registry, and subjected to GPS monitoring. Appellant argued at trial and before the South Carolina Supreme Court that South Carolina Code Annotated section 17-23-175 (2014) (permitting a videotaped forensic interview of an alleged child abuse victim to be played before a jury) arbitrarily allowed an alleged victim to testify twice therefore violating his Due Process right to a fair trial under the Fourteenth Amendment. The trial judge ruled the videotape at issue met the statutory requirement for admission, and that in his view, its admission was constitutional; therefore, the videotape was permitted to be played before the jury. Because the Supreme Court agreed that the statute was not facially unconstitutional on procedural Due Process grounds, it affirmed appellant's conviction and sentence. View "South Carolina v. Legg" on Justia Law

Respondent Nathaniel Teamer was convicted of first-degree burglary, felony driving under the influence (DUI) resulting in great bodily injury, and failure to stop for a blue light (FSBL) resulting in great bodily injury and sentenced to an aggregate term of thirty years in prison. Following the court of appeals' dismissal of Respondent's direct appeal, Respondent filed a post-conviction relief (PCR) application. The PCR court granted relief on four grounds. The Supreme Court granted the State's petition for a writ of certiorari to review the PCR court's decision. Finding that the PCR court erred in its interpretation of the applicable law, and in finding respondent's trial counsel was ineffective for failing to move for a directed verdict on the burglary charge. Accordingly, the PCR court's decision was reversed, and respondent's convictions and sentences were reinstated. View "Teamer v. South Carolina" on Justia Law

Petitioner Richard Burton Beekman was convicted of committing first-degree criminal sexual conduct (CSC) with a minor on his stepson (Stepson) and a lewd act upon a child on his stepdaughter (Stepdaughter). Beekman argued the court of appeals erred in affirming the trial court's denial of his motion to sever the charges because the crimes did not arise out of a single chain of circumstances and were not provable by the same evidence. Further, Beekman argued that trying the charges together unfairly prejudiced him because it allowed the jury to consider evidence the State would have been prevented from presenting in separate trials and likely created the impression in jurors' minds that Beekman had a propensity to sexually abuse children. Therefore, according to Beekman, the South Carolina Supreme Court should have reversed his convictions and remand his case for separate trials. Finding no error in the trial court's or the appellate court's decisions, the Supreme Court affirmed. View "South Carolina v. Beekman" on Justia Law

Respondent Alex Robinson was convicted of one count of trafficking in cocaine in an amount between 100 and 200 grams. He was sentenced to twenty-five years imprisonment and ordered to pay a $50,000 fine. The Court of Appeals reversed Robinson's conviction and remanded for a new trial, holding that the search-warrant affidavit did not include any information to establish the reliability of the informant. The South Carolina Supreme Court granted the State's petition for a writ of certiorari. After review, the Supreme Court held that because the search-warrant affidavit, on its face, supported a finding of probable cause, an objective law enforcement officer's belief in it could have been reasonable. Thus, the Court of Appeals erred in holding otherwise. However, because the information in the search-warrant affidavit concerning the informant/purported purchaser's reliability was intentionally false, the credibility of the entire affidavit was compromised. The Court affirmed the Court of Appeals' decision as modified. View "South Carolina v. Robinson" on Justia Law

Petitioner was convicted of murder, possession of a firearm during the commission of a violent crime, and pointing a firearm. He was sentenced to life imprisonment without parole. The Supreme Court affirmed petitioner's convictions and sentences on direct appeal. Petitioner then filed a post-conviction relief ("PCR") action, and sought certiorari to review the PCR judge's order denying relief. The Supreme Court granted the petition for a writ of certiorari on two issues: (1) whether the PCR judge erred in finding trial counsel was not ineffective by failing to cross-examine the State's "key" witness regarding prior inconsistent statements; and (2) whether the PCR judge erred in finding trial counsel was not ineffective by failing to preserve for appellate review the trial judge's refusal to charge the jury on the defense of others. After review, the Supreme Court found the PCR judge erred as to the first issue, and reversed on those grounds. View "Rutland v. South Carolina" on Justia Law

Michael Pearson was convicted of first-degree burglary, armed robbery, kidnapping, grand larceny, and possession of a weapon during the commission of a violent crime. The trial judge sentenced Pearson to an aggregate sentence of sixty years' imprisonment. The Court of Appeals reversed, holding the circumstantial evidence presented by the State was insufficient to submit the case to the jury. The State appealed. Viewing the evidence in the light most favorable to the State, the Supreme Court concluded the evidence could have induced a reasonable juror to find Pearson guilty. The Court found the Court of Appeals weighed the evidence and erroneously required the State, at the directed verdict stage, to present evidence sufficient to exclude every other hypothesis of Pearson's guilt. Accordingly, the Court reversed the Court of Appeals and affirmed Pearson's convictions and sentences. View "South Carolina v. Pearson" on Justia Law

Petitioner Manuel Marin was convicted of murder and possession of a firearm during the commission of a violent crime. Marin appealed, and the court of appeals affirmed, rejecting his argument that the trial court committed reversible error by refusing to instruct the jury that a person acting in self-defense has the right to continue shooting until the threat has ended. The Supreme Court, after review, disagreed but affirmed, finding that the common law rule was sufficiently encompassed in the jury charge provided by the trial court. "Because the thorough jury charge included consideration of the applicable principles of self-defense, the failure to incorporate the precise 'continuing to shoot' verbiage does not rise to the level of reversible error. We therefore affirm the court of appeals' decision as modified." View "South Carolina v. Marin" on Justia Law

From 1998 to 2000, an armed perpetrator committed six robberies of hotels in Lexington, Richland, Berkeley, and Charleston counties. During each of these robberies, the perpetrator entered the hotel, held the clerk at gunpoint, restrained the clerk with either duct tape or rope, and stole money out of the hotel safe and till. After an investigation, the police arrested Clifford Thompson for these robberies, and a grand jury indicted him on multiple counts of armed robbery and kidnapping. Thompson appealed the court of appeals' decision to affirm the circuit court's refusal to grant Thompson's request for declaratory judgments finding that: (1) his kidnapping offenses did not involve a sexual element; and (2) Thompson would not need to register as a sex offender upon his release from prison in 2020. Upon review, the Supreme Court reversed the court of appeals' decision affirming the circuit court's refusal to address whether Thompson's kidnapping offenses did not involve a sexual element, and remand for a hearing on this issue. However, because the issue of whether Thompson will be required to register as a sex offender upon his release from prison is not yet ripe, and because the SCDC's classification of Thompson as a sex offender in prison was subject to internal grievance procedures, the Court affirmed the court of appeals' decision with respect to those two issues, and allowed Thompson to file a grievance with the SCDC to become reclassified in the SCDC's system. View "Thompson v. South Carolina" on Justia Law

Donald Anderson was walking in the vicinity of a drug raid when police officers located in the periphery of the search ordered him to the ground. Upon searching him, officers found crack cocaine, and Anderson was thereafter indicted for possession with intent to distribute crack cocaine. He moved to suppress the drugs, arguing the detention and subsequent pat-down were unlawful under the Fourth Amendment. The trial court denied his motion to suppress and, following a bench trial, found Anderson guilty as charged. The court of appeals affirmed in an unpublished opinion, finding the police had both reasonable suspicion to detain him and reasonable belief he was armed and dangerous to justify the pat-down. The Supreme Court reversed. The South Carolina Supreme Court could not agree the evidence supported the conclusion that the officers had a particularized and objective basis to suspect illegal activity that would justify the detention. "We remain ever mindful of the difficult and often dangerous situations officers encounter daily and acknowledge that we give great deference to their experience and expertise. Here, however, the facts amount to no more than baseless conjecture that a person in a high crime area must be engaged in illicit activity. A person's proximity to criminal activity, without more, cannot establish reasonable suspicion to detain that individual. Taken to its logical conclusion, the erosion of an individual's Fourth Amendment right would necessarily accompany his or her misfortune of living in an area plagued by crime." View "South Carolina v. Anderson" on Justia Law

Donna Phillips was convicted of homicide by child abuse and sentenced to twenty-five years' imprisonment in the death of her 21-month-old grandson (Child). Phillips was alleged to have given the Child Tussionex, a prescription medication used to treat coughs and respiratory symptoms. Child was transported to the hospital after having been found in his bedroom, cold, not breathing and with no pulse. It was determined he was in opiate-induced cardiac arrest. After resuscitation, Child was taken by helicopter to a second hospital. Ultimately Child was pronounced brain dead and removed from life support; the cause of his death was documented as a hydrocodone overdose. Phillips held the prescription for Tussionex. The court of appeals affirmed Phillips conviction. Phillips argued on appeal that the court of appeals erred in affirming the denial of her motion for directed verdict because it considered the testimony offered by a co-defendant as well as Phillips' own testimony in its analysis. Although the South Carolina Supreme Court agreed the court of appeals erred in disregarding "South Carolina v. Hepburn," (753 S.E.2d 402 (2013)), the Court ultimately found the denial of Phillips' directed verdict motion was proper and affirmed as modified. View "South Carolina v. Phillips" on Justia Law