Justia South Carolina Supreme Court Opinion Summaries

Petitioner contended that the court of appeals erred by applying common law principles of accomplice liability to affirm his conviction for aiding and abetting homicide by child abuse for which he was not indicted. Petitioner was the father of the minor child (Victim) who died as a result of child abuse in 2004. Petitioner and the Victim's mother, Charlene Dandridge, were Victim's caretakers. An autopsy revealed seventeen rib fractures, some of which occurred several weeks prior to death and some that occurred in the forty-eight hours immediately prior to death. The autopsy also revealed that, on the day she died, Victim had been given approximately four times the adult dosage of pseudoephedrine. The trial court, on its own initiative, instructed the jury on both South Carolina Code section 16-3-85(A)(1), and 16-3-85(A)(2). The trial court indicated that it believed that section (A)(2) was a lesser-included offense of section (A)(1), or alternatively, that section (A)(2) was merely another means to convict a criminal defendant of the same underlying crime of homicide by child abuse but would lead to a lesser sentence. Petitioner's trial counsel objected to the jury instruction on section (A)(2) because he was not put on notice of the section (A)(2) offense. The jury subsequently found Petitioner guilty of violating the unindicted section (A)(2) offense without reaching the indicted section (A)(1) charge. The Supreme Court held that the court of appeals erred in affirming Petitioner's conviction under section (A)(2). Accordingly, the Court reversed the court of appeals and remanded this case to the trial court for a new trial on the indicted offense of homicide by child abuse pursuant to section (A)(1). View "South Carolina v. Smith" on Justia Law

Appellant Steven Barnes was convicted on kidnapping and murder charges. The jury found two aggravating circumstances and recommended the death sentence. The judge sentenced appellant to death for the murder, but no sentence for kidnapping. On appeal, appellant contended that the trial court erred in allowing his attorney to call a defense psychiatrist to testify regarding appellant's right to represent himself, by denying his "Faretta" request, in limiting voir dire, by qualifying a particular juror, and by refusing to dismiss the indictments because of the State's alleged failure to comply with the Interstate Agreement on Detainers Act. Finding that the trial court applied the incorrect competency standard in its denial of the Faretta request, the Supreme Court reversed on that ground.View "South Carolina v. Barnes" on Justia Law

Father appealed his conviction for sexually abusing his two young daughters. He challenged the trial court's order requiring that he be entered on the Central Registry of Child Abuse and Neglect, and that prohibited him from visiting his four children until successful completion of a treatment plan. Father argued the family court erred in its interpretation of S.C. Code Ann. 19-1-180 (Supp. 2012) and in permitting the playing of videotape forensic interviews of the non-testifying child victims. Upon review of the matter, the Supreme Court concluded the videotapes were inadmissible under 19-1-180(G) and reversed. View "SCDSS v. Pringle" on Justia Law

This case involves the payment of attorney's fees and expenses to attorneys, Appellant Tara Dawn Shurling and co-counsel, who were court-appointed to represent an indigent charged with multiple criminal offenses. Shurling was appointed to represent an indigent defendant in a criminal prosecution for murder, assault with intent to kill, criminal conspiracy, possession of a weapon during a violent crime, and possession of marijuana. Shurling sought approval for her fees and expenses to exceed the statutory caps provided by the South Carolina Indigent Defense Act. The trial court determined that the initial funding order precluded an award for the fees and expenses sought by appointed counsel, which total $46,388.66. Finding no reversible error, the Supreme Court affirmed. View "South Carolina v. Hackshaw" on Justia Law

The circuit court granted petitioner Joseph Walker's request for post-conviction relief on the ground that his trial counsel rendered ineffective assistance for failing to investigate a potential alibi witness. The court of appeals reversed, holding that while trial counsel's representation was deficient, petitioner was not prejudiced by it. Upon review of the matter, the Supreme Court disagreed with the appellate court and reversed its holding. View "Walker v. South Carolina" on Justia Law

Petitioner Beulah Butler appealed the court of appeals' decision to affirm her convictions for voluntary manslaughter and possession of a firearm or a knife during the commission of a violent crime. She claimed appellate court erred in affirming the denial of her motion for a directed verdict on self-defense. Finding no reversible error, the Supreme Court affirmed. View "South Carolina v. Butler" on Justia Law

Appellant Quashon Middleton was convicted on two counts of attempted murder and one count of possession of a weapon while committing a violent crime. Appellant pulled alongside his victims' stopped car one day in 2010 on his moped. He fired 5-7 times into the car, but none struck the car's occupants. But for the driver's hitting appellant as he sped away, the driver and passenger would have been killed. On appeal, appellant argued the trial judge erred in refusing to charge the jury on the lesser-included offense of assault and battery in the first degree, and this error required reversal. The Supreme Court agreed the trial court's failing to include the lesser-included charge was made in error, however, the Court concluded this error was harmless. View "South Carolina v. Middleton" on Justia Law

Petitioner Clarence Robinson appealed his conviction for armed robbery and possession of a firearm during the commission of a violent crime. He claimed the trial court erred in finding the police had a reasonable, articulable suspicion to stop and search the vehicle in which he was riding as a passenger. Finding no reversible error, the Supreme Court affirmed petitioner's convictions. View "Robinson v. South Carolina" on Justia Law

The issue before the Supreme Court in this case was whether the admission of appellant Davontay Henson's codefendant's redacted confession during a joint trial violated appellant's rights under the Confrontation Clause of the Sixth Amendment. Upon careful consideration of the trial court record, the Supreme Court found that the admission of the redacted confession indeed violated the Confrontation Clause because the jury could infer from the face of the confession that it referred to and incriminated Henson. View "South Carolina v. Henson" on Justia Law

Petitioner James Giles was convicted of first-degree burglary, strong arm robbery, and kidnapping. He was sentenced to thirty years', thirty years', and fifteen years' imprisonment, respectively, to be served concurrently. On appeal to the Supreme Court, he argued the appellate court erred in affirming his convictions and sentences on the basis that the trial court improperly sustained the solicitor's "Batson" motion. Finding no reversible error, the Supreme Court affirmed. View "South Carolinav. Giles" on Justia Law