Justia Constitutional Law Opinion Summaries

Justin B. was found delinquent for committing criminal sexual conduct with a minor in the first degree. The family court imposed the mandatory, statutory requirement that he register as a sex offender and wear an electronic monitor, both for life. Justin B. claimed the mandatory imposition of lifetime registration and electronic monitoring on juveniles was unconstitutional. Finding no reversible error, the Supreme Court affirmed the family court. View "In the Interest of Justin B." on Justia Law

Bobby Stone shot and killed Charlie Kubala of the Sumter County Sheriff's Office. After the Supreme Court affirmed his murder conviction and death sentence, Stone filed an application for post-conviction relief (PCR) alleging he received ineffective assistance of counsel. The PCR court denied relief. Finding no reversible error in the PCR court's judgment, the Supreme Court affirmed. View "Stone v. South Carolina" on Justia Law

Appellant Retail Services owned and operated three separate liquor store locations in Charleston, Greenville, and Columbia, South Carolina. SCDOR was charged with the administration of South Carolina's statutes concerning the manufacturing, sale, and retail of alcoholic liquors. Retail Services petitioned SCDOR to open a fourth store in Aiken, however, SCDOR refused to grant Retail Services a fourth liquor license under sections 61-6-140 and -150 of the South Carolina Code, which limited a liquor-selling entity to three retail liquor licenses. Additionally, ABC Stores lobbied the General Assembly on behalf of its members who are owners and holders of retail dealer licenses. Therefore, Retail Services brought this action against SCDOR and ABC Stores seeking a declaratory judgment that these provisions of the South Carolina Code were unconstitutional. The trial court found the provisions constitutional because: (1) they were within the scope of the State's police power; and (2) they satisfied the rational basis test, which, because they did not infringe on a fundamental right or implicate a suspect class, was all that was required. Therefore, the circuit court granted Respondents' motions for summary judgment. Appellant appealed the circuit court's decision. The Supreme Court reversed. "Not only is there no indication in this record that these provisions exist for any other reason than economic protectionism, the provisions themselves and statutory scheme to which they belong lend further support to Appellant's position. As Appellant points out, the provisions do not limit the number of liquor stores that can be licensed in a certain area-only the number than can be owned by one person or entity. Another provision governs the specific placement of retail establishments away from churches, schools and playgrounds. Therefore, Respondents' contention that the provisions advance the safety and moral interests of the State, no doubt a legitimate State interest, is unavailing with respect to sections 61-6-140 and -150." View "Retail Services & Systems, Inc. v. SDCOR" on Justia Law

Petitioner Alphonso Thompson was convicted of trafficking in cocaine in excess of 400 grams, possession of a weapon during the commission of a violent crime, and possession with intent to distribute ("PWID") marijuana. He was sentenced to concurrent sentences of twenty-five years' imprisonment, and two terms of five years' imprisonment, respectively. At a pre-trial hearing, Thompson challenged the admissibility of the evidence recovered during a search conducted at his parents' home located in Spartanburg County, arguing the affidavit supporting the search warrant for the property was invalid. The trial judge found the affidavit was sufficient, and denied the motion to suppress the evidence. The Court of Appeals affirmed Thompson's convictions and sentences. The Supreme Court granted Thompson's request for a writ of certiorari to review the Court of Appeals' decision. Because the Supreme Court found the affidavit supporting the search warrant failed to establish a fair probability that the evidence sought would be found at the home, the Court held the Court of Appeals erred in affirming the trial judge's denial of the motion to suppress the evidence recovered there. View "South Carolina v. Thompson" on Justia Law

A jury found Jeffrey Chapman met the statutory definition of a sexually violent predator (SVP) as set forth in South Carolina's Sexually Violent Predator Act (the Act), and the trial court subsequently signed an order to civilly commit him. In this direct appeal, Chapman presented a novel issue of law related to the right to counsel in SVP proceedings. The Supreme Court held that persons committed as SVPs have a right to the effective assistance of counsel, and they may effectuate that right by seeking a writ of habeas corpus. Therefore, although the Court affirmed Chapman's commitment on issue preservation grounds, he may reassert his ineffective assistance of counsel claims in a future habeas proceeding. View "In the Matter of Jeffrey Allen Chapman" on Justia Law

Bobby Stone shot and killed Charlie Kubala of the Sumter County Sheriff's Office. Stone filed an application for post-conviction relief (PCR) alleging he received ineffective assistance of counsel. The PCR court denied relief. Stone filed a petition for a writ of certiorari, which was granted as to three sets of issues: (1) whether Stone's trial and appellate counsel were ineffective in dealing with victim impact evidence; (2) whether Stone's trial counsel was ineffective in investigating and presenting evidence of brain damage; and (3) whether Stone's trial counsel was ineffective in investigating and presenting evidence of the accident theory of the case. Finding trial and appellate counsel's performance was reasonable in almost every respect, the Supreme Court affirmed: counsel's performance did not meet an objective standard of reasonableness, and thus was deficient under the first prong of "Strickland." However, as to each of these failures, Stone did not prove a reasonable probability the outcome would have been different as required by the second prong. View "Stone v. South Carolina" on Justia Law

Petitioner-defendant Charles Cain appealed after he was convicted for trafficking methamphetamine. He argued the State produced insufficient evidence as to the quantity of drugs required for trafficking, and thus the trial court erred when it denied his motion for a directed verdict. The Court of Appeals found the core of Cain’s argument was not preserved for appellate review and affirmed. Finding however, that the argument was indeed preserved, the Supreme Court reversed and remanded for further proceedings. View "South Carolina v. Cain" on Justia Law

Petitioner Michael Gonzales was convicted for trafficking 400 grams or more of methamphetamine, for which he was sentenced to thirty years’ imprisonment. Petitioner applied for post-conviction relief (PCR), arguing his trial counsel had a conflict of interest that adversely affected counsel’s performance. The PCR judge denied relief, and in a split decision, the Court of Appeals affirmed the PCR judge’s order. The South Carolina Supreme Court found the Court of Appeals erred in affirming the PCR judge’s order, so it reversed denial of petitioner’s application for PCR. View "Gonzales v. South Carolina" on Justia Law

Ruben Ramirez was sixteen years old when he was indicted for assault and battery with intent to kill, kidnapping, first-degree criminal sexual conduct with a minor, first-degree burglary, and lewd act upon a child. The issue his case presented for the Supreme Court’s review was whether a severely mentally retarded individual should be afforded post-conviction relief (PCR) where his plea counsel failed to request an independent competency evaluation prior to his guilty plea. The PCR court denied relief, finding plea counsel was not deficient nor was Ramirez prejudiced by counsel's representation. Although the court of appeals disagreed that plea counsel was not deficient, the court affirmed based on its application of the "any evidence" standard to the PCR court's prejudice finding. The Supreme Court affirmed in part and reversed in part, upholding the court of appeals' finding of deficiency but reversing its finding as to lack of prejudice to Ramirez. View "Ramirez v. South Carolina" on Justia Law

Appellant Michael Beaty, Jr. was convicted of murdering his girlfriend, for which he was sentenced to life imprisonment. After the jury was sworn the trial judge gave preliminary remarks. Appellant objected to the use of the terms "search[ing] for the truth," "true facts," and "just verdict." Appellant complained these terms were especially concerning when linked with the Solicitor's "misstatement" of circumstantial evidence and reasonable doubt in his opening statement, and because the Solicitor had informed the jury that it would have to pick between two competing theories. Ultimately, the Supreme Court affirmed appellant's conviction, but took the opportunity of this case to discuss two issues appellant raised in his appeal. "We instruct trial judges to omit any language, whether in remarks to the jury or in an instruction, which might have the effect of lessening the State's burden of proof in a criminal case. Further, we hold that in criminal cases tried after this opinion becomes final, if requested by the party with the right to second argument, the party with the right to open and close will be required to open in full on the law and the facts, and be limited in reply to addressing the other party's argument and not permitted to raise new matters." View "South Carolina v. Beaty" on Justia Law