704 S.E.2d 344
S.C.2011Background
- Bryant began a crime spree in October 2004, committing multiple offenses including two first-degree burglaries, ABIK, and three murders, culminating in a death sentence for the Tietjen murder.
- While awaiting trial, Bryant threatened a corrections officer and injured another, illustrating ongoing violent conduct.
- Bryant pleaded guilty to offenses in chronological order and received multiple concurrent and consecutive sentences, including a death sentence for Tietjen and life sentences for other murders.
- Mitigation evidence included childhood trauma, PTSD with a history of sexual abuse, ADD, chronic depression, and substance abuse.
- Appellant sought to introduce Aunt Terry’s testimony that she had been sexually abused by Bryant’s grandfather; the trial court sustained the objection.
- The issue presented is whether the trial court erred in excluding Aunt Terry’s testimony, given its relevance to mitigation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Testimony admissibility about abuse by grandfather | Bryant | State | No reversible error; not prejudicial |
Key Cases Cited
- State v. Winkler, 388 S.C. 574 (2010) (no abuse of discretion; admissibility matters resolved in mitigation context)
- State v. Mercer, 381 S.C. 149 (2009) (excluded evidence presented through other witnesses not reversible error)
- State v. Wyatt, 317 S.C. 370 (1995) (lack of prejudice supports affirmance when evidence excluded)
- State v. Shuler, 344 S.C. 604 (2001) (capital sentence review standards for proportionality)