Justia South Carolina Supreme Court Opinion Summaries

Appellant Damien Inman was convicted and sentenced to life without the possibility of parole for the robbery, kidnapping, and murder of Mary Stutts. Appellant was seventeen years old at the time of the crimes. On appeal, Appellant challenged his convictions on several grounds, including that the circuit court improperly granted the State's motion pursuant to "Batson v. Kentucky" after Appellant offered a race-neutral explanation for striking a particular juror. The Supreme Court agreed after review and reversed and remanded the case for a new trial. View "South Carolina v. Inman" on Justia Law

Appellant William Mark Brockmeyer appealed his convictions for murder and possession of a weapon during a violent crime, raising constitutional challenges to both the trial court's refusal to enforce a subpoena concerning the identity of an internet commenter and the admission of certain chain-of-custody testimony and other photographic evidence at trial. The theory of appellant's defense was that the shooting was an accident. An issue arose over posted comments to a news article by a local television station. Appellant wanted evidence supporting his claim of accident and being emotionally upset after the shooting, and contended the online post suggested its author had direct knowledge of the incident and supported his claim of accident. Accordingly, appellant served the television station with a subpoena seeking the user's gender, year of birth, ZIP code, name and email address (all requirements for creating a user account on the station's website to publish comments online). The television station resisted the subpoena on First and Fourteenth Amendment grounds. Appellant argued his constitutional right to a fair trial required disclosure of the identity of the commenter. The Supreme Court concluded after its review of the trial court record, that the subpoena issue was not properly preserved for appeal, and even if it had been, the trial court's refusal to enforce the subpoena was not reversible error. Finding no other reversible errors, the Supreme Court affirmed the trial court in all other respects. View "South Carolina v. Brockmeyer" 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The Court granted the State's petition for a writ of certiorari to review an unpublished Court of Appeals decision that affirmed the circuit court's suppression of respondent Philip Sawyer's breath test results and video in a prosecution for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). In 2007, respondent was taken to the Spartanburg County Jail following a traffic stop made by a certified Data Master operator. Respondent was placed in the "subject test area" which is a room that adjoins the Data Master room. A deputy retrieved some forms from the Data Master room and then appeared to read respondent his Miranda rights and the implied consent information. Both respondent and the deputy signed the forms. There were separate audio and video recording devices in both the subject test area and in the breathalyzer room. In this case, the audio device in the subject test area did not function. Respondent moved to suppress the evidence relating to the breath test site alleging the videotape did not meet the requirements of S.C. Code Ann. 56-5-2953(A), which required that a person charged with DUI have his conduct at both the incident site and the breath test site videotaped. Upon review, the Supreme Court affirmed, holding 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. 56-52953(A)(2) (2006). View "South Carolina v. Sawyer" on Justia Law

Following his conviction for one count of assault and battery of a high and aggravated nature (ABHAN), one count of possession of a dangerous animal, and multiple counts of animal fighting, David Tant was remanded to the Department of Corrections. Upon receipt of his sentencing sheets, the Department recorded his sentence as fifteen years' imprisonment. However, the Department later determined the judge intended to sentence Tant to forty years' imprisonment and changed its records without notifying Tant. The issue this case presented to the Supreme Court was whether the Department of Corrections had the authority to alter its initial determination as to the length of an inmate's sentence. The Court held that when the Department decides its original recordation of a sentence was erroneous, it must afford the inmate formal notice of the amended sentence and advise him of his opportunity to be heard through the grievance procedure. Furthermore, "the Department is generally confined to the face of the sentencing sheets in determining the length of a sentence, but may refer to the sentencing transcript if there is an ambiguity in the sentencing sheets." Because the Court found that the sentencing sheets and the transcript in this case were ambiguous, it held Tant's sentences ran concurrently for a total of fifteen years' imprisonment. View "Tant v. South Carolina Dept. of Corrections" on Justia Law

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