Justia South Carolina Supreme Court Opinion Summaries

The State appealed the court of appeals' decision to reverse the convictions of respondent William Coaxum, Sr., who was found guilty of armed robbery and possession of a firearm during the commission of a violent crime. In 2007, two men robbed a Pizza Hut in North Charleston. The respondent, driver of the get-away vehicle, refused to pull over, and a high-speed pursuit ensued. Within two miles of the start of the chase, Respondent lost control of the vehicle and crashed into a fire hydrant. Respondent and his passenger attempted to flee on foot. The police caught and arrested respondent at the scene of the crash, and their search of his car and person revealed a sawed-off shotgun and over $1,000 in cash. Prior to Respondent's trial, the trial court conducted voir dire of the prospective jurors. Specifically, the court asked: "Are there any members of the jury panel related [by] blood or marriage, socially or casually connected with [Respondent], or that have any business dealings, any connection whatsoever?" None of the prospective jurors responded. At trial, after the State presented the first four of its eight witnesses, the judge received a note from the jury foreperson indicating that Juror #7 recognized one of respondent's family members sitting in the courtroom. The solicitor requested Juror #7 be removed from the jury, arguing that although Juror #7's initial nondisclosure during voir dire was unintentional, "these types of relationships . . . [,] ultimately she may not be able to put it out of her mind." After conducting a lengthy inquiry, the trial court found that the alleged connection between Juror #7 and Respondent would have been a material factor in the State's exercise of its peremptory challenges. The court did not view Juror #7's connection with Respondent and his family as a basis for a challenge for cause. However, the court ruled that the connection would have been a legitimate basis for the State's exercise of its peremptory strikes, and that the State would have struck Juror #7 had she disclosed the connection. Therefore, the trial court excused Juror #7 from the jury and replaced her with the alternate juror. The State then called its remaining witnesses, and the jury ultimately convicted Respondent of armed robbery and possession of a firearm during the commission of a violent crime. The court of appeals reversed respondent's convictions and remanded the case for retrial, concluding that a trial court may not "automatically" remove a juror for an unintentional failure to disclose requested personal information during voir dire. Further, the court of appeals held that it was an abuse of discretion for the trial court to have removed Juror #7 because, in essence, a trial court may remove a juror mid-trial only if the juror has intentionally failed to disclose. As there was no question the jury was impartial after Juror #7's removal, the Supreme Court concluded that was not entitled to a new trial. Accordingly, it reversed the court of appeals decision reversing Respondent's convictions. View "South Carolina v. Coaxum" on Justia Law

Desmond Sams was convicted of voluntary manslaughter after he strangled the victim, Jake Frazier, during an altercation. Sams appealed, arguing the circuit court erred in denying his request to instruct the jury on involuntary manslaughter. The Court of Appeals affirmed. After review, the Supreme Court found Sams was not entitled to an instruction on involuntary manslaughter because, as found by the circuit court and the Court of Appeals, Sams' actions did not fall within the range of conduct constituting involuntary manslaughter. View "South Carolina v. Sams" on Justia Law

Officers from the North Charleston South Carolina Police Department (NCPD),believed Petitioner Alfred Adams was a drug dealer. Acting without a warrant, officers placed a Global Positioning System (GPS) device on petitioner's vehicle. After monitoring petitioner's travel to Atlanta, Georgia, and upon his return to South Carolina, law enforcement stationed a drug canine unit on the interstate within the NCPD's jurisdiction, with instructions to conduct a traffic stop on petitioner's vehicle. An officer conducted the requested traffic stop and discovered cocaine in petitioner's possession, which resulted in his arrest. Petitioner moved to suppress the drugs, arguing that the warrantless installation of the GPS device violated the Fourth Amendment. The trial court denied petitioner's motion, finding no constitutional violation. The court of appeals found the warrantless installation of the GPS device violated the Fourth Amendment but determined that the exclusionary rule did not apply because "Adams's traffic violations were intervening criminal acts sufficient to cure the taint arising from unlawfully installing the [GPS] device and monitoring the vehicle." Petitioner contended on appeal to the Supreme Court that the court of appeals erred in finding that his traffic violations were intervening criminal acts that dissipated the taint from the unlawful search and concluding the facts did not warrant suppression. The Supreme Court agreed, reversed and remanded for further proceedings. View "South Carolina v. Adams" on Justia Law

The Court granted the State's petition for a writ of certiorari to review an unpublished Court of Appeals decision that affirmed the circuit court's suppression of respondent Philip Sawyer's breath test results and video in a prosecution for driving under the influence (DUI). Upon review of the matter, the Supreme Court affirmed, finding that a videotape from the breath test site that lacked the audio portion of the reading of Miranda rights and the informed consent law did not satisfy the requirements of S.C. Code Ann. 56-5-2953(A)(2) (2006). View "South Carolina v. Sawyer" on Justia Law

Respondent Bentley Collins was convicted of involuntary manslaughter and three counts of owning a dangerous animal causing injury to a person after a ten-year-old boy was killed and partially eaten by his dogs, most of whom were pitbull mixes. The State appealed the Court of Appeals' decision reversing and remanding the case for a new trial based solely on the trial court's admission of seven pre-autopsy photos of the victim. The State argued that the Court of Appeals: (1) failed to give due deference to the trial court's decision; (2) erred in finding that photos entered into evidence were more prejudicial than probative; (3) erred in finding the photos were not material to the elements of the offenses charged and corroborative of other evidence; and (4) erred in making a purely emotional decision to reverse and remand for a new trial. The Supreme Court agreed and reversed the appellate court's decision. View "South Carolina v. Collins" on Justia Law

The State charged appellant "Kevin R." with possessing a weapon on school grounds. Prior to his adjudicatory hearing before a family court judge, Appellant moved for a jury trial on the grounds the federal and state Constitutions guaranteed him the right to a jury trial. The judge denied the motion and proceeded to hear Appellant's case in a bench trial. Ultimately, the judge adjudicated Appellant delinquent and deferred sentencing until an evaluation of Appellant was completed. The sentencing hearing was conducted before a second family court judge, who sentenced Appellant to an indeterminate period of time not to exceed his twenty- first birthday. The judge then suspended the sentence and placed Appellant on probation until his eighteenth birthday. On appeal, Appellant contended the family court judge erred in denying his motion for a jury trial. Recently, the South Carolina Supreme Court held a juvenile did not have a constitutional right to a jury trial in adjudication proceedings. However, the Court's decision in that case was not dispositive as it was presented with additional arguments raised by Appellant and the Amici Curiae. After consideration of these issues, the Court adhered to its decision in the earlier case, and affirmed the family court. View "In the Interest of Kevin R." on Justia Law

John Weik was convicted of murdering his former girlfriend following an argument over the couple's child. He confessed to the shooting and cooperated with law enforcement. There was never any dispute regarding guilt. During the sentencing phase, the State proceeded on two aggravating circumstances: burglary and torture. Regarding Weik's mental status, the defense relied on three mental health experts, who all of whom testified that Weik suffered from paranoid schizophrenia, including auditory and visual hallucinations, suicidal ideations, and paranoid delusions. The defense, however, failed to present readily available evidence concerning Weik's chaotic upbringing and dysfunctional family. It was the absence of the social history mitigation evidence that compelled the South Carolina Supreme Court, "under controlling United States Supreme Court precedents, to grant Weik a new sentencing hearing." View "Weik v. South Carolina" on Justia Law

In early 2006, Deputy Chris Farrell responded to a domestic call at the home of defendant James Ramsey's estranged wife (Wife). Farrell interviewed both parties and noticed a bruise on Wife's hand, which she indicated was the result of Ramsey attempting to grab a phone from her. Based on his observations, Deputy Farrell issued Ramsey a uniform traffic ticket for criminal domestic violence (CDV). Ramsey moved to dismiss the charges for lack of jurisdiction. He argued that because the CDV was not committed in the presence of the officer, Deputy Farrell could not issue him a uniform traffic ticket under section 56-7-15(A), and absent a valid uniform traffic ticket, the magistrate lacked authority to hear the case. The magistrate agreed and dismissed the charges. The circuit court affirmed the dismissal on the alternative basis that only offenses listed under Section 56-710 of the South Carolina Code (2006), amended by 56-7-10 (Supp. 2013), allowed for prosecution solely based on a uniform traffic ticket and at the time the alleged crime was committed, CDV was not listed in section 56-7-10. Therefore, the circuit court concluded the magistrate did not have jurisdiction to hear the CDV charge until an arrest warrant was issued. The court of appeals affirmed the dismissal. Although the court disagreed with the circuit court's conclusion that CDV could never be prosecuted in magistrate court absent an arrest warrant, it found that pursuant to section 56-7-15, an officer could only issue a uniform traffic ticket for CDV if the crime was committed in his presence. The Supreme Court granted certiorari to review the court of appeals' opinion. Finding no reversible error, the Supreme Court affirmed. View "South Carolina v. Ramsey" on Justia Law

Erick Hewins appealed his conviction for possession of crack cocaine. Hewins argued on appeal that the circuit court judge erred in ruling he was collaterally estopped from challenging the search of his vehicle, which precipitated the drug charge, because Hewins waived any challenge when he was convicted in municipal court of an open container violation resulting from the same search. The Supreme Court held the conviction in municipal court had no preclusive effect on Hewins's ability to litigate his motion to suppress in circuit court. Furthermore, the Court found the drug evidence should have been suppressed because it was discovered during an unlawful search. Accordingly, the Court reversed Hewins's conviction. View "South Carolina v. Hewins" on Justia Law

The Attorney General petitioned the Supreme Court to review two municipal courts' rulings addressing whether the Attorney General has the authority to prosecute criminal cases in magistrate and municipal courts. The first case involved Defendant Paul Gwinn who was charged with Criminal Domestic Violence (CDV). When the case was called for trial, Gwinn made a motion that the Attorney General could not prosecute the case because the municipal court was not a court of record, citing S.C. Const. art. V, sec. 24 (2009). The municipal court found that the Attorney General could prosecute the case. The second case involved the prosecution of Defendant Michael Long, also charged with CDV. Long moved to disqualify the Attorney General's office from prosecuting the case, arguing that the Attorney General is authorized to prosecute cases only in courts of record. The court granted the motion, ruling that the Attorney General did not have the authority to prosecute the case under art. V, sec. 24. Upon review, the Supreme Court held that art. V, sec. 24 does not prevent the Attorney General from prosecuting cases in summary courts. The Court therefore affirmed the trial court in Gwinn's case, and reversed the trial court in Long's case. View "South Carolina v. Gwinn" on Justia Law