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State v. Bennett
758 S.E.2d 743
S.C. Ct. App.
2014
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Background

  • 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)
Read the full case

Case Details

Case Name: State v. Bennett
Court Name: Court of Appeals of South Carolina
Date Published: May 28, 2014
Citation: 758 S.E.2d 743
Docket Number: Appellate Case No. 2012-207559; No. 5234
Court Abbreviation: S.C. Ct. App.