State v. Bennett
758 S.E.2d 743
S.C. Ct. App.2014Background
- Bennett was convicted of burglary in the second degree, petty larceny, and malicious injury to real property.
- An alarm at the C.C. Woodson Community Center triggered early on November 17, 2010, leading to a police investigation.
- A latent fingerprint from the community room television matched Bennett.
- Blood droplets found in the computer room matched Bennett’s DNA.
- The center director testified Bennett was a frequent visitor and that monitoring was imperfect due to hours and access.
- The trial court denied Bennett’s motion for a directed verdict; the appellate court reversed, finding insufficient circumstantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the circumstantial evidence sufficient to prove Bennett’s guilt beyond a reasonable doubt? | Bennett argues the evidence is insufficient and merely suggests presence. | State contends substantial circumstantial evidence reasonably proves identity. | Directed-verdict should have been granted; convictions reversed. |
Key Cases Cited
- State v. Cope, 405 S.C. 317 (S.C. 2013) (standard for reviewing directed verdicts; requires substantial evidence beyond suspicion)
- State v. Odems, 395 S.C. 582 (S.C. 2011) (circumstantial evidence sufficiency standard)
- State v. Lane, 406 S.C. 118 (Ct.App.2013) (identity proven beyond reasonable doubt in circumstantial cases)
- State v. Arnold, 361 S.C. 386 (S.C. 2004) (directed verdict if evidence raises only suspicion)
- State v. Bostick, 392 S.C. 134 (S.C. 2011) (circumstantial evidence must reasonably prove guilt; mere suspicion insufficient)
