Justia Criminal Law Opinion Summaries

Articles Posted in South Carolina Supreme Court
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In South Carolina, the case revolves around the interpretation of a law concerning the calculation of the one-year maximum Community Supervision Program (CSP) revocation sentence. The key question is whether inmates arrested for alleged CSP violations should receive credit towards their potential CSP revocation sentence for the time they spent in jail awaiting the adjudication of the CSP violation charge. The Petitioner, Stacardo Grissett, violated the terms of his CSP and was denied credit for roughly six months he spent in jail awaiting his CSP revocation hearing. His appeal was dismissed as moot because he had completed his CSP revocation sentence and original sentence by the time it reached the Court of Appeals. The Supreme Court of South Carolina, however, chose to review the case due to its potential for repetition and the need for clarification. The court ruled that inmates must be given credit for any time served awaiting their CSP revocation hearing towards their CSP revocation sentence. The court's decision hinged on the interpretation of Section 24-21-560(C), which states that an inmate who is incarcerated for a CSP violation is not eligible to earn credits that would reduce the sentence. The court held that time served does not "reduce" a sentence, but only affects the date on which the sentence begins, thereby ruling in favor of the Petitioner. View "State v. Grissett" on Justia Law

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In South Carolina, a defendant, William C. Sellers, was convicted of murder in connection with the killing of Johnny Hydrick. The State presented evidence that Sellers personally murdered Hydrick during a burglary and robbery attempt to steal Oxycodone, guns, and cash from Hydrick's home. The State also presented an alternative theory that Sellers was guilty under the doctrine of "the hand of one is the hand of all" because he and another man agreed to carry out the burglary and robbery, during which one or both of them fatally beat Hydrick.The Supreme Court of South Carolina affirmed the lower court's decision. The court addressed two main issues. First, it considered whether the trial court's jury instruction defining malice partly as "the intentional doing of a wrongful act without just cause or excuse" improperly shifted the burden of proof to Sellers. The court found that the instruction did not shift the burden because the State was required to prove beyond a reasonable doubt that Sellers acted "without just cause or excuse."Second, the court examined whether the State presented sufficient evidence to support instructing the jury on Sellers' criminal liability under the doctrine of "the hand of one is the hand of all." The court found that the State had presented evidence that Sellers and another man had agreed to commit the burglary and robbery, and that both had beaten Hydrick during the course of these crimes. Thus, the instruction was supported by the evidence.Therefore, the court affirmed Sellers' conviction for murder. View "State v. William C.Sellers" on Justia Law

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The Supreme Court of South Carolina affirmed the decision by the court of appeals in the case of Tommy Lee Benton, who was convicted for the murder of Charles Bryant Smith, two counts of first-degree burglary, one count of first-degree arson, and one count of third-degree arson. Benton's first trial was declared a mistrial due to his failure to disclose his alibi, which he intended to support via his great-grandmother's testimony. Benton claimed that his second trial and ensuing convictions were barred by double jeopardy. The court, however, found that the mistrial was declared due to "manifest necessity," hence, there was no double jeopardy violation.Benton also argued against the admissibility of gruesome crime scene photographs and certain text and Facebook messages. The court upheld the trial court's decision, asserting that the photographs provided important context to the testimony and other key evidence. The court noted that while the photographs were disturbing, any error in admitting them was harmless as they did not significantly contribute to the verdict. The court also affirmed the admissibility of the text and social media messages. View "State v. Benton" on Justia Law

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James Heyward was convicted of multiple crimes arising from the armed robbery, brutal beating, and murder of Alice Tollison during the burglary of her home. The South Carolina Supreme Court granted Heyward's petition for a writ of certiorari to address the trial court's refusal to remove Heyward's leg shackles during the striking of the jury, and four evidentiary issues. As to three of the evidentiary issues, the authentication of a fingerprint card, the admission of gruesome autopsy photographs, and the State's use of Heyward's alias, the Supreme Court found the trial court acted within its discretion. As to the other evidentiary issue, a firearms expert's testimony Heyward's pistol was operational at the time of the crimes, the Supreme Court affirmed the court of appeals' ruling that if there was any error in the admission of that testimony it did not prejudice Heyward. As to the leg shackles, the Court found the trial court erred in failing to exercise its discretion in determining whether Heyward should have been required to wear leg shackles in the presence of the jury. However, because the State conclusively proved Heyward's guilt through overwhelming evidence such that no rational conclusion could have been reached other than Heyward is guilty of these crimes, the Court nevertheless affirmed. View "South Carolina v. Heyward" on Justia Law

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Corey Brown was convicted by jury of conspiracy to commit grand larceny, armed robbery, and kidnapping. In a post-trial motion, Brown moved for a new trial on several grounds, including the State's failure to disclose its negotiations with Shadarron Evans, the State's key witness. The trial court granted the motion, and the State appealed. Agreeing with the State, the court of appeals reversed the grant of a new trial, concluding that no plea offer had been extended and remanded the case to the circuit court to make specific findings as to whether the evidence was material to Brown's guilt under Brady v. Maryland, 373 U.S. 83 (1963). The South Carolina Supreme Court granted Brown's petition for a writ of certiorari to review the decision of the court of appeals. After that review, the Supreme Court reversed and remanded the case to the circuit court for a new trial. View "South Carolina v. Brown" on Justia Law

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Petitioner Robert Miller, III was convicted of murdering eighty-six-year-old Willie Johnson. Following the murder, Petitioner—who was fifteen years old at the time—confessed four times: twice to his close friends and twice to law enforcement. All four confessions were admitted at trial, three without objection. This appeal centered around the voluntariness of Petitioner's fourth and final confession to two agents of the South Carolina Law Enforcement Division (SLED). After examining the totality of the circumstances surrounding the fourth confession, the South Carolina Supreme Court held that Petitioner's free will was not overborne, and his confession was voluntary. It therefore affirmed. View "South Carolina v. Miller" on Justia Law

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The South Carolina Supreme Court issued a common-law writ of certiorari to review a "sealed" order of the circuit court reducing the prison sentence of Jeroid Price and releasing him from prison after he served only nineteen years of his thirty-five-year sentence on his murder conviction. The Court previously issued an order unsealing all documents in the case. Here, the Court vacated the order because: (1) the circuit court did not have the authority to reduce the sentence because the solicitor and the circuit court did not comply with any of the requirements set forth in the applicable statute; and (2) the circuit court did not have the authority to close the proceedings to the public or seal the order. The Court remanded Defendant to the custody of the South Carolina Department of Corrections. View "South Carolina v. Price" on Justia Law

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Tyrone Wallace Jr. appealed his convictions for murder and kidnapping, challenging the trial court's ruling that a witness who placed Wallace's phone near the two crime scenes based on cell site location information (CSLI) was "qualified as an expert by knowledge, skill, experience, training, or education" under Rule 702 of the South Carolina Rules of Evidence. The court of appeals affirmed. The South Carolina Supreme Court granted Wallace's petition for a writ of certiorari to address only this issue. The Court found the trial court acted within its discretion, and affirmed the judgment. View "South Carolina v. Wallace" on Justia Law

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Charles Dent was convicted and sentenced on one count of first-degree criminal sexual conduct (CSC) with a minor and two counts of disseminating obscene material to a minor. Dent appealed, and a divided court of appeals' panel reversed and remanded for a new trial, finding the trial court erred in failing to give the requested circumstantial evidence charge the South Carolina Supreme Court articulated in State v. Logan, 747 S.E.2d 444 (2013). Because this ruling was dispositive, the court of appeals did not reach Dent's other assignments of error. The Supreme Court granted the State's petition for a writ of certiorari and then reversed: while the Court agreed with the court of appeals' finding of error in the trial court's failure to charge circumstantial evidence pursuant to Logan, the error was harmless. The Court reversed and remanded to the court of appeals for consideration of Dent's remaining issues on appeal. View "South Carolina v. Dent" on Justia Law

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A jury found Petitioner Carmie Nelson ("Carmie") guilty of murdering her roommate, and the trial court sentenced her to life imprisonment. Carmie appealed, arguing, among other things, that the trial court erred in admitting gruesome autopsy photos in contravention of Rule 403, SCRE. The court of appeals, finding no error, affirmed in an unpublished opinion. The South Carolina Supreme Court granted Carmie's petition for a writ of certiorari, and reversed: “the photos admitted here surpassed ‘the outer limits of what our law permits a jury to consider.’” View "South Carolina v. Nelson" on Justia Law