Justia South Carolina Supreme Court Opinion Summaries

In exchange for the State's promise not to seek the death penalty on three charges of murder, Anthony Sanders consented to a bench trial and waived his right to any appellate, post-conviction, or habeas corpus review. He was convicted of three counts of murder and sentenced to life imprisonment. His subsequent application for post-conviction relief (PCR) was dismissed based on the agreement. Sanders argued the PCR court erred in failing to allow him to present evidence that his waiver was entered into upon the advice of constitutionally ineffective trial counsel. The Supreme Court agreed, and remanded back to the PCR court for an evidentiary hearing. View "Sanders v. South Carolina" on Justia Law

This case arose from the death of Martin Gasque after a 2010 University of South Carolina football game against the University of Alabama. Both Appellant Curtis Simms and the victim tailgated near the stadium during the football game, and both were intoxicated as they left the area. Appellant, wearing an Alabama jersey, left the tailgate with friends, riding as the front-seat passenger in a green truck driven by a friend. As they attempted to exit the tailgate parking lot, the victim, a South Carolina fan, was the front-seat passenger in a black truck driven by his friend, and was boisterously engaging South Carolina fans through his open window. The two trucks and passengers crossed paths when the black truck blocked the green truck from exiting the parking lot. Appellant exited the green truck and approached the black truck's passenger side, where the victim was sitting. Appellant punched the victim once while he was seated in the truck, and then hit the victim four or five more times as he exited the black truck. The victim was knocked unconscious, and fell into the roadway parallel to the truck on the white line comprising the edge of the lane of traffic. After the victim hit the ground, the victim's friend began pulling his truck forward to the right in order to move the truck onto the shoulder and out of the roadway. As he did so, he unknowingly began to slowly roll over the victim between his legs, then over his groin, his abdomen, his chest, and finally, his head. Appellant yelled at the black-truck-driver to stop, and banged on the truck with his fists, but this only caused the driver to accelerate. The victim died at the scene after suffering a life-threatening hinge fracture. Appellant was charged with both aggravated breach of the peach and involuntary manslaughter. The jury returned a verdict of not guilty on the involuntary manslaughter charge, but found Appellant guilty of aggravated breach of the peace. The trial court sentenced Appellant to ten years' imprisonment, suspended upon the service of five years' imprisonment and three years' probation, but later reduced Appellant's sentence to ten years' imprisonment suspended upon the service of three years' imprisonment, plus three years' probation. Appellant argued on appeal of his conviction and sentence that: (1) the trial court erred in refusing to direct a verdict of acquittal with respect to the breach of the peace charge; (2) the trial court imposed an illegal sentence; and (2) the trial court erred in refusing to admit certain eyewitness testimony. Finding no reversible error, the Supreme Court affirmed. View "South Carolina v. Simms" on Justia Law

Respondent Richard Niles, Jr. was convicted of murder, armed robbery, and possession of a weapon during the commission of a violent crime. Respondent, his girlfriend and Ervin Moore met the victim, James Salter, in a store parking lot intending to purchase drugs. The evidence at trial focused on whether respondent was the aggressor in the encounter. On the facts entered into evidence at trial, the trial court instructed the jury on the law of murder and self-defense, but refused Niles's request to instruct the jury on voluntary manslaughter, reasoning that the evidence showed Niles was either guilty of murder or he was not guilty of any crime based on his claim of self-defense. The court of appeals reversed Niles's murder conviction and remanded the case for a new trial, finding the evidence compelled a jury instruction on the lesser-included offense of voluntary manslaughter. The Supreme Court granted the State's for certiorari review to consider the State's argument that the court of appeals erred in determining Niles was entitled to a jury instruction on voluntary manslaughter because there was no evidence at trial that Niles acted in the sudden heat of passion. The Supreme Court held that the evidence did not warrant a voluntary manslaughter charge, and reversed the court of appeals. View "South Carolina v. Niles" on Justia Law

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

Appellant Anthony Odom appealed his conviction for criminal solicitation of a minor. Appellant's conviction stemmed from a series of internet chat sessions with an undercover Westminster, South Carolina, city police officer posing as a fourteen-year-old girl. The internet chats took place May 4–6, 2006, in Oconee County, South Carolina. A jury found Appellant guilty of one count of criminal solicitation of a minor, based on the internet chats that occurred from May 4–5, 2006. Appellant was acquitted of the count involving a chat room conversation that allegedly occurred on May 6, 2006. The trial court sentenced Appellant to seven years' imprisonment, suspended upon the service of five years' probation, along with conditions including registering as a sex offender. Appellant appealed his conviction, arguing that the officer posing as a fourteen-year-old girl should have had a bond to act in his official capacity and therefore the trial court erred in refusing to instruct the jury on the law of bonding. Finding no error, the Supreme Court affirmed. View "South Carolina v. Odom" on Justia Law

Petitioner Derrick McDonald and two codefendants were convicted of murder and first-degree burglary. The court of appeals affirmed, rejecting McDonald's argument that his Confrontation Clause rights were violated when the trial court admitted the redacted confession of one of his nontestifying codefendants. No defendant testified at trial. The jury found Defendants guilty of both charges. McDonald appealed, arguing that given the context, Cannon's written confession clearly implicated McDonald in the crimes. The court of appeals affirmed, "find[ing] that the neutral phrase 'another person' inserted into Cannon's statement avoided any [Confrontation Clause] violation." Cannon's confession was redacted using the phrase "another person." The Supreme Court found, after review of the trial court record, that even a casual reading of the confession made it apparent that the confession describes the actions of Cannon and two other male individuals. The Court rejected the State's invitation to find no Confrontation Clause violation based on the trial court's limiting instruction. Despite this finding, the Supreme Court concluded that in light of the overwhelming evidence of guilt, the error in this case was harmless beyond a reasonable doubt. The Court therefore affirmed the court of appeals as modified. View "South Carolina v. McDonald" on Justia Law

In a joint trial, petitioner Kenneth Workman and codefendant Oshawn Robinson were convicted of assault and battery, conspiracy, possession of a weapon during the commission of a violent crime, and armed robbery. After petitioner's direct appeal was dismissed pursuant to Anders, petitioner filed an application for post conviction relief (PCR), alleging trial counsel was ineffective in failing to object to a coercive Allen charge and in failing to challenge the trial judge's ruling barring cross-examination of the State's witness, Timothy Wright, regarding the sentencing recommendation Wright received in exchange for testifying against petitioner and Robinson. The PCR judge denied petitioner's application for PCR, finding: (1) petitioner failed to meet his burden of proving trial counsel was ineffective in failing to object to the Allen charge, as the charge was not unduly coercive; and (2) petitioner was not prejudiced by trial counsel's failure to challenge the ruling barring cross-examination regarding Wright's sentence. After review, the Supreme Court found petitioner was prejudiced by trial counsel's deficient performance in failing to object to an unconstitutionally coercive Allen charge; accordingly, the Court granted his petition for a writ of certiorari, dispensed with further briefing, reversed the PCR judge's denial of relief, and remanded for a new trial. View "Workman v. South Carolina" on Justia Law

This case stemmed from the shooting death of James Salter (the victim) in a Best Buy parking lot in Myrtle Beach. It was undisputed that defendant Richard Niles, Jr., his fiancé, Mokeia Hammond, and Ervin Moore met the victim at the parking lot to purchase marijuana from him. Defendant was convicted of murder, armed robbery, and possession of a weapon during the commission of a violent crime. The trial court instructed the jury on the law of murder and self-defense, but refused defendant's request to instruct the jury on voluntary manslaughter, reasoning that the evidence showed defendant was either guilty of murder or he was not guilty of any crime based on his claim of self-defense. The court of appeals reversed defendant's murder conviction and remanded the case for a new trial, finding the evidence compelled a jury instruction on the lesser-included offense of voluntary manslaughter. Specifically, the court of appeals found there was evidence of sufficient legal provocation based on defendant's testimony that he shot at the victim only after the victim began shooting first. The Supreme Court granted the State's petition for a writ of certiorari to consider the State's argument that the court of appeals erred in determining defendant was entitled to a jury instruction on voluntary manslaughter because there was no evidence at trial that defendant acted in the sudden heat of passion. After review, the Supreme Court reversed: defendant's own testimony did not establish that he was overtaken by a sudden heat of passion such that he had an uncontrollable impulse to do violence. "Rather, Niles testified that he did not want to hurt the victim; that he shot with his eyes closed; that he was merely attempting to stop the victim from shooting; and that when he shot his gun, he was thinking of Hammond rather than of perpetrating violence upon the victim. In other words, there was nothing sudden about Niles's decision to shoot the victim. Thus, we hold that the evidence did not warrant a voluntary manslaughter charge." View "South Carolina v. Niles" on Justia Law

Mark Baker was convicted of four counts of committing a lewd act upon a minor. In October 2004, Victim Two, Baker's youngest niece, informed her mother that "Uncle Mark was messing with" her older sister, Victim One. At that time, Victim Two denied that Baker had molested her. The Court of Appeals affirmed. Following the denial of his petition for rehearing, Baker petitioned the Supreme Court for review. The Court granted certiorari to analyze whether: (1) the trial judge erred in refusing to quash the indictments, which alleged the offenses occurred over a six-year time frame; and (2) qualifying a witness as an expert in forensic interviewing. After review, the Court reversed Baker's convictions because the Court found the indictments were unconstitutionally overbroad. View "South Carolina v. Baker" on Justia Law

Appellant George Chavis was convicted of multiple crimes involving unlawful sexual conduct with a minor, Appellant's step-daughter. The issues this case presented for the Supreme Court's review concerned the qualification and testimony of two child abuse assessment experts. Finding no reversible error as to the trial court's actions with regard to the experts, the Supreme Court affirmed. View "South Carolina v. Chavis" on Justia Law