755 S.E.2d 457
S.C.2014Background
- Beulah Butler appeals after convictions for voluntary manslaughter and a weapon during a violent crime, challenging the denial of a directed verdict on self-defense.
- The July 2006 incident occurred after an escalating domestic altercation between Butler and her boyfriend, during which a knife was wielded and injuries were sustained by both parties.
- Butler offered inconsistent accounts of how the stabbing occurred, including claims that the victim attacked her and that the knife incident was accidental.
- Police recovered the victim’s blood on multiple objects and Butler’s clothing, and the autopsy showed a fatal stab wound plus several other knife wounds.
- At trial Butler testified she acted in self-defense; the State presented evidence to rebut self-defense and the court charged the jury on self-defense and related principles.
- The trial court denied directed verdict motions, and Butler was convicted; the court of appeals affirmed, and the Supreme Court granted certiorari.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State must disprove self-defense beyond a reasonable doubt at a directed-verdict stage | Butler argues the State bears that burden at directed verdict. | State contends the standard is existence of evidence, not weight, at directed verdict. | Any-evidence standard governs directed verdict on self-defense |
| Whether the evidence created a jury issue on self-defense | Butler asserts the facts support self-defense as matter of law. | State maintains there was sufficient evidence to submit to the jury. | Evidence created a jury issue; trial court properly submitted to jury |
Key Cases Cited
- State v. Wiggins, 330 S.C. 538 (1998) (directed verdict standard focuses on existence of evidence)
- State v. Weston, 367 S.C. 279 (2006) (any direct or substantial evidence can support jury submission)
- State v. Cherry, 361 S.C. 588 (2004) (if evidence reasonably proves guilt, jury should hear it)
- State v. Richburg, 250 S.C. 451 (1968) (when evidence allows more than one reasonable inference, submit to jury)
- State v. Dickey, 394 S.C. 491 (2011) (Dickey creates confusion over directed-verdict standard for self-defense)
- State v. Burkhart, 350 S.C. 252 (2002) (proper jury instruction when self-defense is submitted)
- State v. Addison, 343 S.C. 290 (2000) (self-defense burden of proof discussed)