In Re Tracy B., 704 S.E.2d 71

Tracy B., a juvenile, was convicted of murder, unlawful possession of a handgun, and unlawful possession of a handgun by a minor for a 2007 North Charleston shooting.
Teenagers on a porch were confronted by a Town Car; Twin and Kayron had guns; Twin handed a gun to Tracy, who was 14.
The Town Car returned with Jenkins in the back seat; shots were fired from the car, Tracy then fired one shot at the car, killing Jenkins.
Tracy was interviewed by police, was Mirandized, invoked counsel, and later gave a statement after his mother and a lieutenant mediated contact.
The family court held a Jackson/Edwards-type analysis, denied suppression, and Tracy was tried and convicted; a new-trial motion was denied.
This appeal challenges suppression of the statement, self-defense, and the denial of a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Edwards rule treatment required suppression	Tracy argues the police reinitiated after counsel invoked.	State contends Tracy reinitiated via mother and actions were permissible.	Edwards rule not violated; reinitiation was proper and voluntary.
Whether the statement was voluntary beyond reasonable doubt	Statement was involuntary due to youth and interrogation context.	Statement was voluntary under totality of circumstances.	Statement was voluntary; no due process violation.
Whether State disproved self-defense beyond a reasonable doubt	State failed to negate self-defense.	Appellant believed imminent danger; use of force was justified.	State disproved first and fourth elements; murder affirmed despite self-defense claim.
Whether denial of a new trial was an abuse of discretion	New trial should be granted due to insufficient trial evidence.	Evidence supported conviction; no basis for new trial.	No abuse; denial of new trial affirmed.

Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) ( Edwards rule governs post-invocation interrogation)
Montejo v. Louisiana, 556 U.S. _ (U.S. 2009) (overruled Jackson on Edwards extension; initiation question resolved)
Anderson, 357 S.C. 514 (Ct. App. 2004) (distinguishes Sixth Amendment vs Edwards context; third-party reinitiation)
Harvell v. State, 275 Ga. 129 (Ga. 2002) (limited-inquiry rationale when defendant’s mother relays willingness to talk)
Oregon v. Bradshaw, 462 U.S. 1039 (U.S. 1983) (questions that may prompt non-incriminating responses)
Spano v. New York, 360 U.S. 315 (U.S. 1959) (cautionary cautionary interrogation context analyzed in voluntariness)
State v. Bryant, 336 S.C. 340 (S.C. 1999) (defines four elements of self-defense)
State v. Burkhart, 350 S.C. 252 (S.C. 2002) (state must disprove self-defense beyond a reasonable doubt)