Heatley v. State, 28344

Heatley was convicted of murdering his former girlfriend and armed robbery based primarily on circumstantial evidence, including texts, cell-phone location data, and ATM use of the victim's credit card. 1
The trial court gave a reasonable doubt charge and a circumstantial evidence instruction modeled on Grippon, and the jury convicted Heatley. 2
Heatley's direct appeal was dismissed, and he later sought PCR claiming trial counsel was ineffective for not requesting a Logan circumstantial evidence charge. 3
At the PCR hearing, trial counsel admitted he was unaware of Logan when Heatley was tried. 4
The PCR court denied relief, finding no deficient performance and no prejudice given the strength of the State's case. 5
The Supreme Court granted certiorari, overruled Logan in part, and affirmed the denial of PCR. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was trial counsel ineffective for not requesting a Logan circumstantial evidence charge? 7	Heatley said Logan was the required standard charge and counsel should have requested it.	The State said Grippon remained valid and no deficiency existed without a Logan request.	No; counsel was not deficient because a Grippon-style charge plus reasonable doubt was sufficient. 8
Should Logan's added circumstantial-evidence language remain controlling? 9	Heatley relied on Logan as the governing circumstantial-evidence instruction.	The State urged the Court to retain Grippon and reject Logan's added requirements.	Logan is overruled in part; courts may use Grippon or similar language but not Logan's extra requirement. 10

State v. Logan, 405 S.C. 83, 747 S.E.2d 444 (S.C. 2013) (modified Grippon to permit additional circumstantial-evidence language if requested 11)
State v. Grippon, 327 S.C. 79, 489 S.E.2d 462 (S.C. 1997) (recommended a circumstantial-evidence charge tied to reasonable doubt 12)
State v. Cherry, 361 S.C. 588, 606 S.E.2d 475 (S.C. 2004) (stated Grippon was the sole charge for circumstantial-evidence cases 13)
State v. Littlejohn, 228 S.C. 324, 89 S.E.2d 924 (S.C. 1955) (stated the traditional circumstantial-evidence rule later discussed in this line of cases 14)
State v. Edwards, 298 S.C. 272, 379 S.E.2d 888 (S.C. 1989) (affirmed Littlejohn and later distinguished directed-verdict from jury-charge issues 15)
State v. Manning, 305 S.C. 413, 409 S.E.2d 372 (S.C. 1991) (criticized a deviation from the Edwards charge that shifted the burden of proof 16)
State v. Raffaldt, 318 S.C. 116, 456 S.E.2d 393 (S.C. 1995) (found a similar circumstantial-evidence charge erroneous but harmless with a sound reasonable-doubt charge 17)
Holland v. United States, 348 U.S. 121, 75 S. Ct. 127, 99 L. Ed. 150 (U.S. 1954) (held a proper reasonable-doubt instruction makes a separate circumstantial-evidence instruction unnecessary and potentially confusing 18)