South Carolina v. Heyward

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