State v. Collins
398 S.C. 197
S.C. Ct. App.2012Background
- Bentley Collins convicted of involuntary manslaughter and three counts of owning a dangerous animal after his dogs killed a ten-year-old boy.
- Collins appeals, claiming the trial court erred by admitting seven autopsy photographs and denying directed-verdict motions.
- The court reverses and remands for a new trial due to an abuse of discretion in admitting the photos.
- Ten autopsy photos were offered; seven admitted after a hearing; they were asserted as probative on the dog attack elements.
- The case focused on Collins’ conduct and the dogs’ unprovoked attack; the photos predominantly depicted the victim’s condition rather than Collins’ actions.
- The court conducted Rule 403 balancing, found unfair prejudice substantially outweighed the photos’ minimal probative value, and reversed admission of the photos; remanded for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of autopsy photographs under Rule 403 | State argues photos are probative of unprovoked attack and cause of death | Collins contends photos are unfairly prejudicial and not necessary | Abused discretion; photos excluded on remand |
| Harmless error analysis of photo admission | Photos contributed to proof of elements | Prejudicial impact could be extreme | Not harmless beyond a reasonable doubt; reversal warranted |
| Directed verdict denial | Evidence supports each element of both crimes | Not needed; photos influenced the jury | No reversible error on directed verdict; specific issue resolved in favor of remand |
Key Cases Cited
- State v. Jarrell, 350 S.C. 90 (Ct. App. 2002) (photographs corroborating testimony may have high probative value depending on context)
- State v. Holder, 382 S.C. 278 (S. Ct. 2009) (corroboration role of autopsy photos; risk of prejudice in child-homicide context)
- State v. Torres, 390 S.C. 618 (S.C. 2010) (photos not necessary to substantiate material facts; appellate deference limited by context)
- Old Chief v. United States, 519 U.S. 172 (U.S. 1997) (unfair prejudice concept; photos appealing to emotion)
- State v. Crosby, 355 S.C. 47 (Ct. App. 2003) (defines recklessness standards for involuntary manslaughter)