Justia Criminal Law Opinion Summaries

Shane Burdette shot and killed Evan Tyner (Victim). Victim died from a single shotgun pellet wound to the back of his neck. After the shooting, Burdette gave several inconsistent statements to law enforcement. The State's theory of the case and Burdette's theory of the case were substantially different. The State claimed murder; Burdette claimed accident. Burdette was indicted and tried for murder and possession of a weapon during the commission of a violent crime. Over Burdette's objection, the trial court charged the jury that it could infer the element of malice from the use of a deadly weapon. The jury convicted Burdette of the lesser-included offense of voluntary manslaughter and possession of a weapon during the commission of a violent crime. The court of appeals affirmed Burdette's conviction, holding that although the trial court erred in giving the inferred malice jury instruction, Burdette suffered no prejudice. The South Carolina Supreme Court granted Burdette's petition for a writ of certiorari to review the court of appeals' decision. After review, the Supreme Court found the trial court's erroneous jury instruction was not harmless beyond a reasonable doubt. It therefore reversed and remanded for a new trial on the offenses of voluntary manslaughter and possession of a weapon during the commission of a violent crime. The Court also held, regardless of the evidence presented at trial, a trial court would no longer instruct a jury that malice may be inferred from the use of a deadly weapon. View "South Carolina v. Burdette" on Justia Law

James Cross was convicted of first-degree criminal sexual conduct (CSC) with a minor and committing a lewd act on a minor. The trial court sentenced Cross to an aggregate prison term of twenty-five years. Cross appealed, and the court of appeals affirmed. After review, the South Carolina Supreme Court concluded the trial court erred in denying Cross's motion to bifurcate his trial, reversed the appellate court, and remanded for a new trial. Cross's conviction for a specific offense under section S.C. Code section 23-3-430(C) was admissible to prove the prior-conviction element of first-degree CSC with a minor. Therefore, the State should have been allowed to introduce the conviction. However, the Court concluded the probative value of the conviction, at the time it was introduced, was substantially outweighed by the danger of unfair prejudice to Cross. The trial court's limiting instruction did not overcome the resulting prejudice. Therefore, it was error by the trial court to refuse Cross's request that the trial be bifurcated. View "South Carolina v. Cross" on Justia Law

Petitioner Anthony Martin was convicted of armed robbery and criminal conspiracy in Aiken County, South Carolina. Petitioner alleged in his PCR application that his trial attorneys were ineffective for failing to elicit testimony from Petitioner's mother regarding the specific timeline of Petitioner's purported alibi: Petitioner contended he was in Atlanta, Georgia, at the time of the robbery in South Carolina. Relief was denied because Petitioner failed to present his mother's testimony at the PCR hearing regarding the alibi defense. Ordinarily, the absence of a purported alibi witness's testimony is fatal, but in this case, counsel admitted they were aware of the specific timeline furnished by the mother, yet failed to introduce it. That testimony, if presented and believed, would have made it impossible for Petitioner to be in Aiken County at the time of the robbery. The South Carolina Supreme Court therefore granted post-conviction relief and remanded for a new trial. View "Martin v. South Carolina" on Justia Law

A jury found Kenneth Campbell met the statutory definition of a sexually violent predator (SVP) under South Carolina's SVP Act, S.C. Code Ann. sections 44-48-10 to -170 (2018). Campbell appealed, and the court of appeals affirmed. On petition of certiorari, Campbell contended the court of appeals erred in affirming his civil commitment because the State inappropriately impeached the credibility of Campbell's expert witness by introducing evidence of a recent arrest warrant for an unrelated sex offender whom the expert had opined was unlikely to reoffend. The South Carolina Supreme Court found the admission of testimony about a mere arrest warrant of an unrelated individual in a collateral matter unduly prejudiced Campbell and, therefore, reversed and remanded for a new commitment proceeding. View "In the Matter of the Care & Treatment of Campbell" on Justia Law

Jalann Williams was convicted for murder, shooting and killing his victim with an unlawfully-possessed pistol defendant intentionally brought to an illegal drug transaction. Williams argued the trial court erred in refusing to charge the jury with the law of self-defense. The South Carolina Supreme Court found defendant was at fault in bringing on the violence. View "South Carolina v. Williams" on Justia Law

The State of South Carolina petitioned for certiorari review of the Court of Appeals' decision in South Carolina v. Andrews, 818 S.E.2d 227 (Ct. App. 2018). After a fatal shooting at Respondent's home, Respondent was indicted for murder and possession of a weapon during the commission of a violent crime. Respondent moved to dismiss the charges pursuant to the Protection of Persons and Property Act on the ground he shot the victim in self-defense. However, another eyewitness testified the victim was attempting to peacefully leave Respondent's home and that Respondent followed the victim out of the home, shooting him on the porch. Additional forensic evidence was presented at the hearing, but it did not conclusively support either version of events. Ultimately, the Court of Appeals affirmed the circuit court's denial of immunity, but reversed Respondent's convictions based on a separate evidentiary issue. To the extent the Court of Appeals relied upon the portion of South Carolina v. Curry, 752 S.E.2d 263 (2013). relating to the directed verdict procedural posture in affirming the circuit court's denial of immunity in this case, the South Carolina Supreme Court vacated that portion of the Court of Appeals' opinion and affirmed as modified. View "South Carolina v. Andrews" on Justia Law

Petitioner Gerald Williams was convicted of three counts of attempted murder related to his alleged shooting into an occupied mobile home where he knew his intended victim was present, but did not realize two other individuals were also present. Under the common law, transferred intent “makes a whole crime out of two halves by joining the intent to harm one victim with the actual harm caused to another.” Normally, transferred intent applies to general-intent crimes. However, attempted murder is a specific-intent crime in South Carolina, and the South Carolina Supreme Court had not yet addressed whether transferred intent could supply the requisite mens rea for such a crime. Because this case was tried without objection as a general-intent crime, the Supreme Court found the doctrine of transferred intent applied in this instance. The Court declined to address the applicability of transferred intent to a specific-intent crime such as attempted murder and vacate the portion of the court of appeals' opinion dealing with this issue. The Court found in light of the facts of this case, there was no error in failing to charge the jury on the lesser-included offense of assault and battery in the first degree (AB-1st). The Supreme Court therefore affirmed the court of appeals as modified. View "South Carolina v. Williams" on Justia Law

In 2013, respondent Frederick Pfeiffer pled guilty to criminal conspiracy and two counts of securities fraud. The State and Pfeiffer entered into a negotiated plea. It was uncontested that the trial court sentenced Pfeiffer in accordance with the negotiated plea agreement. A dispute quickly arose with the South Carolina Department of Correction's interpretation of the sentencing sheets. To resolve any confusion, Pfeiffer timely filed his first Rule 29(a) motion to correct the clerical errors, which resulted in a hearing. Without objection, the trial court entered an amended sentence clarifying the sentencing sheets. On the same date, Pfeiffer's codefendant was sentenced. Pfeiffer believed his sentence was unduly harsh in comparison to his codefendant's sentence. As a result, twenty-nine days after the original sentence, Pfeiffer filed a second Rule 29(a) motion seeking a reduced sentence based on the codefendant's lighter sentence. As noted, there was never a suggestion Pfeiffer's original sentence was contrary to the negotiated plea agreement. Rather, the negotiated plea specifically allowed the State to control the order and timing of Pfeiffer and his codefendant's pleas and sentencing proceedings. The State argued that Pfeiffer's second motion was untimely because more than ten days had elapsed since the original sentencing and the second motion was in no manner related to the first. The trial court, however, found the motion was timely, and granted Pfeiffer's second motion by reducing his sentence. The issue this case presented for the South Carolina Supreme Court's review centered on whether, after the disposition of an initial Rule 29(a) motion, and more than ten days after imposition of the sentence, did the trial court have jurisdiction to hear a second Rule 29(a) motion? The Court held the trial court did not have jurisdiction to hear a second Rule 29(a) motion, unless the second motion challenged something that was altered from the original sentence as a result of the initial Rule 29(a) motion. View "South Carolina v. Pfeiffer" on Justia Law

Daniel Hamrick appealed his conviction for felony driving under the influence resulting in great bodily injury. Hamrick argued the trial court erred in: (1) denying his motion to suppress test results from blood drawn without a search warrant; (2) admitting the blood test results into evidence despite a violation of the three-hour statutory time limit for drawing blood; (3) permitting a police officer to give opinion testimony on accident reconstruction; and (4) excluding from evidence a video recording of an experiment conducted by Hamrick's expert in accident reconstruction. The South Carolina Supreme Court found the trial court erred in admitting the officer's opinion testimony, and accordingly reversed and remanded for a new trial. View "Hamrick v. South Carolina" on Justia Law

Petitioner Denzel Heyward was indicted for murder, attempted murder, armed robbery, and possessing a firearm during a crime of violence for an incident that resulted in the death of Kadeem Chambers. The jury could not reach a verdict as to murder, but found Heyward guilty of the remaining charges. The trial court sentenced him to an aggregate term of 65 years. Heyward appealed, claiming the trial court erred by admitting a photo lineup identification, and by finding his counsel opened the door to the admission of testimony that he had previously committed domestic violence. The court of appeals affirmed. With respect to the domestic violence issue, the South Carolina Supreme Court reversed, “we do not believe counsel opened the door to allegations Heyward physically abused [Quasantrina ]Rivers.” The Supreme Court believed the State used the open-door doctrine to introduce propensity evidence, with no evidentiary support for the court's decision. This, the Court concluded, amounted to an abuse of discretion. “The evidence was introduced solely to demonstrate Heyward's poor character, and given the close case presented, we are unable to find the error was not prejudicial.” The matter was remanded for a new trial. View "South Carolina v. Heyward" on Justia Law