753 S.E.2d 545
S.C.2014Background
- Appellant was convicted of kidnapping and murdering Samuel Sturrup; jury found two aggravators: kidnapping and physical torture, and recommended a death sentence.
- Judge imposed death for the murder but no sentence for kidnapping; appellant challenged trial court rulings regarding Faretta, voir dire, Juror #203, and IAD-related dismissal.
- Appellant moved to proceed pro se under Faretta; the court questioned competence and ultimately denied the Faretta request based on Edwards-style heightened competency.
- Defense sought testimony from a defense psychiatrist (Dr. Price) to argue competency to waive counsel; objections centered on doctor‑patient privilege and Edwards framework.
- Trial court relied on Edwards to deny Faretta; majority held Edwards standard inappropriate for Faretta waiver in a capital case, reversing.
- Appellant’s IAD argument contends indictments should be dismissed; the court declined to reverse on this ground.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Edwards standard applied to Faretta waiver was reversible error | Barnes argues Edwards applies; higher competency required for self‑representation in capital cases | Barnes contends Edwards is correct and should not govern Faretta waiver | Faretta error reversed; Edwards standard not adopted for capital self‑representation |
| Whether Dr. Price testimony violated doctor‑client privilege and due process | Jones argues Price’s testimony aided competency determination without privilege violation | Barnes maintains privilege and mitigation focus preclude Price testimony | Pre-trial testimony allowed; no reversible error found |
| Whether voir dire limitations improperly restricted death‑penalty deliberations | Barnes contends voir dire restricted exploration of jurors' death‑penalty views | Winkler permits trial court discretion to limit voir dire to avoid prejudice | Limitations proper; no reversible error |
| Whether Juror #203 was improperly qualified | Barnes argues Juror #203 could be impartial despite hesitations about death penalty | Court found Juror #203 conflicted and not qualified | Juror #203 properly found unqualified |
| Whether IAD requires dismissal of indictments for noncompliance | Barnes contends dismissal required due to IAD violations | Court held no reversible error given lack of prejudice | No dismissal required; IAD concerns not satisfied |
Key Cases Cited
- Faretta v. California, 422 U.S. 806 (1975) (right to self‑representation; waiver must be knowing and intelligent)
- McKaskle v. Wiggins, 465 U.S. 168 (1984) (standby counsel may aid without destroying pro se defendant’s control)
- Indiana v. Edwards, 554 U.S. 164 (2008) (states may impose higher competency standards for self‑representation in capital cases)
- Dusky v. United States, 362 U.S. 402 (1960) (due process standard for defendant competency to stand trial)
- Woodson v. North Carolina, 428 U.S. 280 (1976) (death penalty requires heightened reliability)
- State v. Starnes, 388 S.C. 590 (2010) (state recognizes right to counsel waiver; Faretta inquiry governs)
- State v. Winkler, 388 S.C. 574 (2010) (voir dire and capital trial framework guidance)
- State v. Brewer, 328 S.C. 117 (1997) (Brewer pre‑Edwards; capital context balancing of rights)