Edwards v. State
392 S.C. 449
S.C.2011Background
- Edwards and co-defendant Marshall were indicted for murder, armed robbery, grand larceny of a motor vehicle, possession of a firearm by a person under twenty-one, and possession of a firearm during a violent felony.
- Marshall pled guilty to all five charges; Edwards proceeded to trial with defense counsel but Marshall was not interviewed or called as a witness.
- Evidence showed Marshall shot Blackston; Blackston was also assaulted, and Edwards assisted in hiding the body and had Blackston’s wallet and other items.
- SLED agent testified at Edwards’s trial, and the State pursued a theory of accomplice liability rather than principal liability.
- Edwards testified acknowledging some wrongdoing but denying murder; the circuit court denied PCR relief and this Court granted certiorari.
- PCR court found counsel’s decision not to interview or call Marshall was not deficient and that there was no prejudice to Edwards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance for failing to interview or call co-defendant | Edwards | State | No deficiency; valid strategic reasons supported decision |
| Prejudice from not calling co-defendant | Edwards | State | No prejudice; testimony would be cumulative and not likely to change outcome |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong standard for ineffective assistance of counsel)
- Ard v. Catoe, 372 S.C. 318 (S.C. 2007) (duty to investigate; reasonable investigation includes interviewing witnesses)
- McKnight v. State, 378 S.C. 33 (S.C. 2008) (duty to investigate; credibility of witnesses matters in strategy)
- Jackson v. State, 329 S.C. 345 (S.C. 1998) (no prejudice where co-defendant testimony would be cumulative or undermined by cross-examination concerns)
- Stokes v. State, 308 S.C. 546 (S.C. 1992) (strategic decision not to call witnesses reasonable when beneficial effect is uncertain)